Commission Delegated Regulation (EU) 2025/2273 of 30 June 2025 supplementing Directive (EU) 2024/1275 of the European Parliament and of the Council as regards the establishment of a comparative methodology framework for calculating cost-optimal levels of minimum energy performance requirements for buildings and building elements

This Regulation establishes the comparative methodology framework to be used by Member States for calculating the cost-optimal levels of minimum energy performance requirements for new and existing buildings and building elements. It also sets out rules for the application of the comparative methodology framework to selected reference buildings.

In addition to the definitions set out in Article 2 of Directive (EU) 2024/1275, the following definitions shall apply for the purposes of this Regulation: (1) ‘global cost’ means the sum of the present values of the initial investment costs, running costs, replacement costs (referred to the starting year), waste management costs, if applicable and, for the purposes of the calculation at macroeconomic level, it includes costs of greenhouse gas emissions as well as health and environmental externalities of energy use; (2) ‘initial investment cost’ means all costs incurred up to the point when the building or building element is delivered to the customer, ready to use. Those costs include design, purchase of building elements, connection to suppliers, installation and commissioning processes; (3) ‘energy cost’ means the annual energy costs, including energy price, capacity tariffs and grid tariffs, and national taxes, taking into account the cost of greenhouse gas allowances. (4) ‘operational cost’ means all costs linked to the operation of the building, including annual costs for insurance, utility charges and other standing charges and taxes; (5) ‘maintenance cost’ means the annual costs for measures to preserve and restore the desired quality of the building or building element including annual costs for inspection, cleaning, adjustments, repair and consumable items; (6) ‘running cost’ means the annual maintenance, operational and energy costs; (7) ‘waste management cost’ means the cost of a building or building element at the end of its life, including dismantling, removal of building elements that have not yet come to the end of their lifetime, transport, disposal and recycling; (8) ‘replacement cost’ means a substitute investment for a building element, in accordance with the estimated economic life cycle during the calculation period; (9) ‘annual cost’ means the sum of running costs and replacement costs paid per year; (10) ‘cost of greenhouse gas emissions’ means the monetary value of environmental damage caused by CO2 emissions, related to the energy consumption in buildings; (11) ‘environmental and health externalities of energy use’ means, but is not limited to, the monetary value of the health and environmental damage caused by emissions of PM2,5 and NOx, related to the energy consumption in buildings; (12) ‘reference building’ means a hypothetical or real building that represents the typical building geometry and systems, the typical energy performance for both building envelope and systems, the typical functionality and typical cost structure in the Member State, and that is representative of climatic conditions and geographic location; (13) ‘discount rate’ means a specific value to compare the value of money at different times expressed in real terms; (14) ‘discount factor’ means a multiplicative number used to convert a cash flow occurring at a given point in time to its equivalent value at the starting point, which is derived from the discount rate; (15) ‘starting year’ means the year from which the calculation period is determined; (16) ‘calculation period’ means the time period considered for the calculation, usually expressed in years; (17) ‘residual value of a building’ means the sum of the residual values of building elements at the end of the calculation period; (18) ‘price development’ means the development over time of prices for energy, products, building systems, services, labour, maintenance and other costs which can be different from the inflation rate; (19) ‘energy efficiency measure’ means a change to a building or building element resulting in a reduction of the building’s final energy use; (20) ‘package’ means a set of energy efficiency measures or measures based on renewable energy sources applied to a reference building, or both; (21) ‘variant’ means the global result and description of a full set of measures or packages applied to a building that can be made up of a combination of measures on the building envelope, passive techniques, measures on building systems or measures based on renewable energy sources, or a combination of those measures; (22) ‘subcategories of buildings’ means categories of building types that are more disaggregated according to size, age, construction material, use pattern, climatic zone or according to criteria other than those established by point 6 of Annex I to Directive (EU) 2024/1275, for which reference buildings are generally established;

1 When calculating cost-optimal levels of minimum energy performance requirements for buildings and building elements, Member States shall apply the comparative methodology framework laid down in Annex I.

2 Member States shall use the comparative methodology framework to compare the following measures, based on the primary energy and emission performance and the cost attributed to their implementation: (a) energy efficiency measures; (b) measures incorporating renewable energy sources; (c) packages and variants of such measures.

3 For the purpose of the calculation referred to in paragraph 1, Member States: (a) shall establish the year in which the calculation is being performed as the starting year for the calculation; (b) shall use the calculation period set out in Annex I; (c) shall use the cost categories set out in Annex I; (d) are recommended to use the projected carbon price trajectories, set out in Annex II, for carbon costing.

4 For the purposes of the calculation referred to in paragraph 1, Member States shall complement the comparative methodology framework by determining all of the following: (a) the estimated economic life cycle of buildings and building elements; (b) the discount rate; (c) the costs for energy carriers, products and systems, the maintenance costs, the operational costs and the labour costs; (d) the forward-looking renewable and non-renewable primary energy factors or weighting factors in accordance with Annex I to Directive (EU) 2024/1275 and the greenhouse gas emission factors; (e) the estimated energy price developments for all energy carriers, taking into account the information set out in Annex II to this Regulation; (f) the air pollutant emission factors, specifically those for PM2,5 and NOx.

5 Member States shall endeavour to calculate and adopt cost-optimal levels of minimum energy performance requirements in relation to those building categories where there are no set specific minimum energy performance requirements.

6 Member States shall carry out an analysis to determine the sensitivity of the outcome of the calculation to changes in the applied parameters, covering at least the impact of different energy price developments and the discount rates for the macroeconomic and financial perspectives referred to in Article 4(1) and ideally also to changes in other parameters that are expected to have a significant impact on the outcome of the calculations, such as price developments other than for energy.

1 Member States shall decide, after calculating the cost-optimal requirement levels from both a macroeconomic and financial perspective, which of the two is to be the national benchmark, and shall report their decision to the Commission as part of their reporting obligations in accordance with Article 6.

2 Member States shall compare the outcome of the calculation chosen in accordance with paragraph 1, with the current energy performance requirements for the relevant building category.

3 Member States shall use the result of the comparison referred to in paragraph 2 of this Article to ensure that minimum energy performance requirements are set with a view to achieving cost-optimal levels, in accordance with Article 5(1) of Directive (EU) 2024/1275.

4 Where a Member State has defined reference buildings in such a way that the result of the cost-optimal calculation is applicable to several building categories, it may use that result to ensure that minimum energy performance requirements are set with a view to achieving cost-optimal levels for all relevant building categories.

1 Member States shall review their cost-optimal calculations for the purposes of the review of their minimum energy performance requirements pursuant to Article 5(1) of Directive (EU) 2024/1275. The review of the cost-optimal calculations shall in particular include the price developments for the input cost data, and an update of such price developments where appropriate.

2 The results of the cost-optimal calculations review shall be provided to the Commission in the report required by Article 6(2) of Directive (EU) 2024/1275.

1 The report required by Article 6(2) of Directive (EU) 2024/1275 shall include the primary energy factors or weighting factors applied, the results of the calculations at macroeconomic and financial level, the sensitivity analysis referred to in Article 3(5) of this Regulation and the assumed energy and carbon price developments, as set out in Annex III to this Regulation.

2 Where Member States have to adjust the minimum energy performance requirements pursuant to Article 6(3) of Directive (EU) 2024/1275, the report shall include a plan outlining appropriate steps to make such adjustments. To that effect, the level of the minimum energy performance requirements in force, which is significantly less energy-efficient, shall be calculated as the difference between the average of all the minimum energy performance requirements in force and the average of all cost-optimal levels of the calculation used as the national benchmark for all reference buildings and building types used.

3 Member States shall make use of the reporting template provided in Annex III.

Delegated Regulation (EU) No 244/2012 is repealed as of 1 January 2026.

This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 1 January 2026 for the calculation of the cost-optimal levels of minimum energy performance requirements for buildings and building elements, which are to be reported to the Commission by 30 June 2028.