“Green Homes” Directive: What It Provides and the State of Transposition in Italy
Updated 4 October 2026
Directive (EU) 2024/1275 on the energy performance of buildings, known as EPBD IV or, in public debate, the “Green Homes Directive”, is one of the European Union’s main measures concerning the energy efficiency of buildings. Published in the Official Journal of the European Union on 8 May 2024, it entered into force on 28 May 2024 and pursues the objective of transforming the European building stock into a zero-emission building stock by 2050.
The Directive does not, by itself, impose a general obligation on every owner to renovate their home by a specific date. Rather, it establishes objectives, standards and deadlines that must be translated by the Member States into national rules, financial measures and support mechanisms. The deadline for transposition expired on 29 May 2026; as at the date of this update, the Italian framework is still evolving.
1. What the Directive provides
Zero-emission new buildings
From 1 January 2030, all new buildings must be zero-emission buildings. For new buildings owned or occupied by public bodies, the deadline is brought forward to 1 January 2028.
A “zero-emission building” is a building with very high energy performance, with zero or very low energy needs, no on-site carbon emissions from fossil fuels and zero or very low operational greenhouse-gas emissions. The Directive also introduces the progressive assessment of the global warming potential (GWP) over the building’s life cycle, taking into account the production and transport of materials, construction, use, replacement of products and demolition.
Existing residential buildings
The Directive sets objectives for the national residential building stock as a whole, rather than imposing an automatic European renovation obligation on each individual owner.
Compared with 2020, Member States must ensure that the average primary energy consumption of the entire residential building stock decreases by at least:
16% by 2030;
20–22% by 2035;
further by 2040 and subsequently every five years, in accordance with a national trajectory consistent with the transformation of the building stock into a zero-emission building stock by 2050.
At least 55% of the required reduction by 2030 and 2035 must be achieved through the renovation of the 43% of residential buildings with the worst performance. The Directive therefore requires Member States to concentrate a significant share of renovation efforts on the least efficient buildings, while leaving national authorities to choose the relevant regulatory, financial and administrative instruments.
The Directive does not provide for disproportionate exemptions for rented residential buildings or residential units and requires particular attention to vulnerable households and energy-poverty situations.
Non-residential buildings
For non-residential buildings, Member States must establish maximum energy-performance thresholds. The thresholds must be set so that:
by 2030, all non-residential buildings are below the threshold corresponding to the worst-performing 16% of the national stock;
by 2033, all non-residential buildings are below the threshold corresponding to the worst-performing 26%.
Member States must then identify further deadlines for 2040 and 2050, consistently with the pathway towards zero-emission buildings. Exemptions may be allowed for specific categories or individual buildings on the basis of clear and strict criteria, for example where heritage protection applies, where there is serious hardship or where a cost-benefit assessment is unfavourable.
Solar installations
The Directive requires the installation of solar-energy systems where technically appropriate and economically and functionally feasible, according to a timetable that includes, among other measures:
by 31 December 2026, all new public and non-residential buildings with a useful floor area exceeding 250 m²;
by 31 December 2027, public buildings with a floor area exceeding 2,000 m² and certain existing non-residential buildings undergoing major renovation or works requiring an administrative permit;
by 31 December 2028, public buildings with a floor area exceeding 750 m²;
by 31 December 2029, public buildings with a floor area exceeding 250 m², new residential buildings and covered car parks adjacent to buildings.
The obligations remain subject to technical, economic and functional feasibility and must be implemented through national criteria and any exemptions established at national level.
Heating and fossil-fuel boilers
From 1 January 2025, Member States may no longer provide financial incentives for the installation of stand-alone fossil-fuel boilers, subject to transitional exceptions connected with specific European programmes selected before 2025.
The Directive does not establish an immediate and general ban on the use or installation of every gas boiler. Member States must draw up national plans for the gradual phase-out of fossil-fuel boilers and may introduce incentives for switching to systems that do not rely on fossil fuels.
Energy performance certificates
The Directive requires energy-performance certification systems to use a closed scale from A to G. Class A corresponds to zero-emission buildings, while class G identifies the worst-performing buildings in the national building stock when the new scale is introduced. Member States that already use the designation A0 for zero-emission buildings may retain it.
This does not mean that the energy-performance certificates currently used in the different Member States will automatically become perfectly uniform. Each State must adapt and recalibrate its system in accordance with the European model, ensuring a coherent distribution of the intermediate classes. The Directive also allows, on an optional basis, the introduction of an A+ class for buildings with even higher performance.
The energy-performance certificate must include technically feasible recommendations for improving energy performance and reducing emissions, as well as information on support instruments and one-stop shops. It must be available, among other situations, when a building is constructed, undergoes a major renovation, is sold or is newly let, in accordance with the procedures established by national law.
Renovation passports and one-stop shops
By 29 May 2026, Member States must introduce a system for renovation passports. This is a tailored roadmap for the deep renovation of a specific building, divided into stages and accompanied by indications of the works required to achieve progressively higher levels of energy performance.
The passport is generally voluntary for owners, unless the Member State decides to make it mandatory. The Directive also provides for one-stop shops offering technical, administrative and financial advice, support measures for vulnerable households and financing tools targeted in particular at the worst-performing buildings.
Exemptions
Subject to the conditions laid down by the Directive, Member States may exclude certain categories of buildings from minimum performance standards. These may include officially protected buildings because of their historical or architectural value, places of worship, temporary buildings, certain agricultural or industrial buildings, dwellings used for limited periods of the year and detached buildings with a total useful floor area of less than 50 m².
The exemptions do not automatically apply in Italy: they must be identified and regulated by the national transposition rules.
National building renovation plan
Each Member State must prepare a national building renovation plan aimed at planning the renovation of the residential and non-residential building stock, both public and private, through to 2050.
For the first plan, the Directive provided for:
submission of the draft to the Commission by 31 December 2025;
a public consultation on the draft, involving local and regional authorities and other stakeholders;
submission of the final plan by 31 December 2026.
The plan must include, among other elements, an assessment of the national building stock, objectives for 2030, 2040 and 2050, thresholds for zero-emission buildings, minimum standards for non-residential buildings, the trajectory for reducing consumption across the residential stock and the investment and financing framework required.
2. The state of transposition in Italy
As at 4 October 2026, Italy’s transposition does not appear to have been completed through a comprehensive legislative decree that has already entered into force. The national process has been marked by delays both concerning the national building renovation plan and the adoption of the legislative measures necessary to adapt the Italian system.
The position must nevertheless be considered on three separate levels:
transposition of the Directive, which requires national legislative, regulatory and administrative measures;
the national building renovation plan, which is the planning instrument provided for by Article 3;
the European Commission’s procedures, which may separately concern the failure to submit the plan and the failure to communicate transposition measures.
According to the information available at the date of this update, the Government has stated that it intends to include the Directive in the legislative process concerning the 2026 European Delegation Act, including through an amendment. The inclusion of a directive in a delegation act does not, however, amount to transposition: the delegated legislative decrees and any necessary implementing measures must subsequently be adopted.
As regards the national building renovation plan, failure to submit the draft by 31 December 2025 exposes Italy to a separate infringement finding by the Commission. Reports concerning the opening or progression of the procedure must be distinguished from the transposition measures and verified against official communications from the Commission and the Italian authorities. As at 4 October 2026, there does not appear to be a judgment of the Court of Justice of the European Union finding Italy in breach, nor a financial penalty already imposed on Italy.
At territorial level, regional or provincial rules adopted before national transposition may operate only within the powers of the authority that enacted them and do not replace national transposition of the Directive. Provincial and regional provisions must therefore be examined carefully, with particular regard to their subject matter, scope and coordination with the national legislation in force.
3. Consequences for owners and real-estate operators
No general immediate renovation obligation
The Directive does not currently make it mandatory for each individual owner in Italy to renovate their home by 2030 or 2035. The thresholds and objectives for residential buildings are principally addressed to Member States and the national building stock as a whole.
A directive that has not been transposed is not normally capable of directly imposing new enforceable obligations on private parties in horizontal relationships. Effects in relations with the State may arise within the limits recognised by EU law, and obligations already deriving from existing Italian legislation remain applicable. The specific obligations, penalties, exemptions and incentives will nevertheless depend on the future choices of the Italian legislature.
Risks and obligations for the State
Failure to transpose the Directive may lead to the opening or continuation of infringement proceedings under Article 258 TFEU, potentially resulting in proceedings before the Court of Justice of the European Union. If a judgment is subsequently not complied with, the financial mechanisms provided for by the Treaties may also apply. As at the date of this article, there does not appear to be a financial penalty already imposed on Italy for failure to transpose the Directive.
Real-estate transactions
Even before transposition, energy performance may affect real-estate transactions. The energy-performance certificate, the quality of the building envelope, systems, running costs, access to incentives and the financing of works may influence negotiations, market value and the assessments carried out by banks and investors.
In sales and leases, it is therefore advisable to verify the validity of the energy-performance certificate and its consistency with the actual condition of the property, without confusing obligations already imposed by current Italian legislation with those that may result from the future transposition of the Directive.
What to monitor
The most relevant developments will include:
the possible approval of the legislative delegation and the subsequent transposition decrees;
submission of the national building renovation plan to the Commission and the outcome of the related consultation;
reform of the Italian energy-performance certificate system and any new structure of the energy classes;
the rules concerning minimum standards for non-residential buildings;
exemptions for protected buildings, places of worship, agricultural buildings, seasonally used dwellings and small detached buildings;
incentives, financing, renovation passports and one-stop shops;
any national and territorial measures concerning solar installations and the replacement of fossil-fuel heating systems.
4. Conclusions
The “Green Homes” Directive establishes a binding European pathway towards a highly energy-efficient building stock and zero-emission buildings by 2050. It does not, however, currently impose an immediate European obligation on every homeowner to renovate their dwelling.
The Italian transposition process is still evolving. The practical impact of the Directive on owners, tenants, condominium associations, businesses and professionals will depend on the content of the national rules, the renovation plan and the financial measures adopted.
In the meantime, energy performance remains relevant to real-estate transactions and building management. Verifying the energy-performance certificate, the condition of the systems, consumption and the feasibility of possible works may therefore be a prudent step, without anticipating obligations that the Italian legislature has not yet defined.
© Avv. Gabriele Lanzi
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