The EU's new energy label scale explained (and what it does to your rating).

Your building's energy label rating is about to change (potentially). The odd thing is that you won't have to touch a brick for it to happen.

The recast EPBD (Energy Performance of Buildings Directive) doesn’t just mean added obligations; it redraws the entire scale against which those obligations are measured. Same building, same boiler, same windows – potentially a whole different rating. So a C today isn't guaranteed to be a C tomorrow. Denmark's a good example – today's top tiers (A2020, A2015, A2010) are pegged to old building-regulation standards; A2010 is simply the 2010 building code's energy level.

It might sound messy, but it’s not really. Here's an overview of what's changing, and what it means for your portfolio.

The scale itself is moving

Or should that say “scales”, seeing as – today – every country runs its own scale, its own boundaries and sometimes a different underlying measure entirely.

Germany rates buildings on final energy use in kWh per m². France uses primary energy demand and greenhouse gas emissions. Belgium runs more than 15 sub-classes. And, as we’ve already seen, Denmark layers its own A2010, A2015, and A2020 tiers on top of the other letters.

As you might have guessed, this all means the ratings aren't comparable across borders. France's A demands low primary energy and low emissions at once. Germany's A is a single final-energy threshold. Same letter, different bar.

You know that GIF of the confused woman? That’s how it feels.

The recast directive aims to fix this. It pulls everyone onto a common A–G scale:

• A is reserved for zero-emission buildings. Not "very efficient" – zero-emission, as the directive defines it. Low energy demand, zero or very low operational emissions, no fossil fuel burnt on site
• B to F get distributed across what's left, with no artificially small or large classes
• G is the very worst-performing buildings in the national stock at the moment the scale is introduced. The Commission's guidance recommends drawing that line inside 14–18% of the stock, and no wider than 26%

Although the directive harmonises the letters, it isn't trying to level the energy behind them. Each country still sets its own thresholds – and both ends of the scale stay national too. G is defined as the worst performers in each country's own stock, and A imports each country's own zero-emission definition. So even once the dust settles, a C in Denmark won't mean the same thing as a C in Germany. The Commission says so itself, in its guidance on the new rules: "A direct comparison of buildings across countries based only on their classes could be misleading and imprecise given the possible differences between national methodologies."

It’s not Boyz II Men harmony, but it’s getting there.

Your rating can move while you stand still

If a building sits near a class boundary today, rescaling can move it – down or up – without a single change to the asset. The letter isn't a property of your building alone; it's a property of where your building sits in a distribution that's being redrawn. For a portfolio, that matters far more than for one asset. Rescale 900 buildings, and the shape of your risk changes. Some assets you'd written off turn out fine. Others you thought were safe suddenly aren’t.

When will this happen

When this will all happen is still up in the air. It was supposed to happen by 29 May 2026, but every single member state missed the deadline. And, on 15 July 2026, the Commission opened infringement proceedings against all 27 (Denmark included).

Some countries, however, do get a little longer. The directive allows a delay to 31 December 2029 for member states that already rescaled their classes between January 2019 and May 2024. Denmark's current scale has been in force since July 2018 – before that window opens – so the extension shouldn't apply here.

What nobody can tell you, despite what you might see online, is the day it all comes into effect. The direction is fixed, but the timing isn't, and that combination is exactly why waiting is the expensive option – you can't schedule a response to a date nobody has published.

What else is included

Two additions are worth knowing, and it's worth being precise about which buildings they touch.

Life-cycle carbon, for new buildings. From 2028, new buildings over 1,000 m² must have their life-cycle global warming potential (GWP) calculated and disclosed in the energy performance certificate. From 2030, this is all new buildings. This is a new-build requirement – it doesn't reach back across an existing portfolio.

Life-cycle carbon, for deep renovations. Separately, existing buildings renovated to the top A+ class have to show life-cycle GWP on the certificate. If you're renovating to the very top of the scale, carbon comes with it.

The validity period doesn't change, by the way. An EPC is still valid for ten years.

What this actually asks of you

Nothing about the rescaling requires you to renovate. What it requires is that you know where your buildings genuinely sit – because the rules that follow the scale get enforced against a ranking, and a ranking is only as good as the data underneath it. That's harder than it sounds. A certificate is a calculation, not a measurement. Some of what goes into it is measured at your building. A lot of it is standard assumption – the same figures applied to every property, whether or not they fit yours.

Plus the fact that the methodology officially used to calculate the energy requirement of a building for EPC generation in Denmark was created specifically for single-family homes – no other types of property. In our own data, we've seen buildings using more than twice what their certificate estimated – and others using barely half.

Then the result is frozen for up to ten years.

Where comundo fits

And that's the gap comundo was built to close. The static certificate becomes a live picture: where the building actually stands, what a change actually did, and what the next round of work actually buys you.

The regulation is turning the EPC into a number that matters, more than ever before. What you need is the software to make sure your numbers add up (that’s us).