Directive (EU) 2024/1275, known as EPBD 2024 or the recast EPBD, entered into force on 28 May 2024 following publication in the Official Journal of the European Union on 8 May 2024 (reference DOUE-L-2024-80664), according to EUR-Lex. The directive sets 29 May 2026 as the deadline by which all EU Member States must complete transposition into national law. According to the European Commission Directorate for Energy, failure to transpose exposes Member States to infringement proceedings. The directive repeals and replaces Directive 2010/31/EU and its 2018 amendments, with the central objective of achieving a fully decarbonised EU building stock by 2050. That objective is articulated through concrete obligations covering energy performance certification, renovation passports, smart readiness indicators, solar energy infrastructure, and life cycle analysis. The staged timeline of these obligations means that building owners, developers, certifying engineers, and asset managers operating across the EU face multiple active compliance deadlines running simultaneously between now and 2030. | In Spain, the directive must be integrated with existing instruments, including the Technical Building Code (CTE), the Thermal Installations in Buildings Regulation (RITE), and the energy certification royal decrees. According to MITECO, the institutional page for building energy efficiency confirms that some measures in the directive were already aligned with existing Spanish regulation, while other obligations, particularly those relating to renovation passports and life cycle analysis, require additional regulatory development. According to BUILD UP, the European Commission platform for building energy efficiency, an analysis of implementation in Spain indicated that the country had reached approximately 60% adaptation around the May 2026 transposition deadline. This means a significant portion of the technical and administrative obligations derived from the directive still required specific regulatory development or updating of existing national instruments at that point. This implementation gap has direct practical consequences for property owners and technical teams: energy performance certification procedures, minimum performance requirements, and building information systems may all be subject to regulatory amendments in the coming months. | One of the most immediate changes under the recast directive concerns energy performance certificates (EPCs). According to BUILD UP, from 29 May 2026 all EPCs must mandatorily use the A-to-G scale and the template model defined in Annex V of the directive. The harmonised format serves two purposes: it facilitates comparability between real estate assets across the EU, and it provides more actionable information on recommended improvement measures. In Spain, EPCs are currently regulated by Royal Decree 390/2021, which already introduced the A-to-G scale. However, Directive (EU) 2024/1275 adds further requirements to certificate content, including information on embodied global warming potential, smart readiness capacity (the Smart Readiness Indicator, or SRI), and integration with the renovation passport. These elements require updating of the inspection, calculation, and registration procedures currently managed by the autonomous communities, which hold competence for certification registers. For asset types with high energy demand and complex HVAC systems, such as hospital and healthcare facilities or educational estates, accurate modelling of the revised EPC indicators is particularly critical to meet deadlines and avoid administrative penalties. | The renovation passport is one of the most substantive innovations introduced by EPBD 2024. According to MITECO, the directive requires Member States to establish a renovation passport scheme based on Annex VIII of the directive, with a deadline of 29 May 2026. A renovation passport is a tailored document describing a staged deep renovation roadmap for a specific building, with the objective of reaching the highest possible energy performance level, ideally nearly zero-energy building (NZEB) standard or above. Unlike a standard EPC, the renovation passport is not a snapshot of the current state of a building. It is a structured plan of sequential interventions, each accompanied by estimates of energy savings, approximate costs, and temporal priority. Its technical value lies in enabling phased investment planning, minimising the risk of stranded assets, and maximising access to grant funding and financing mechanisms such as the Recovery, Transformation and Resilience Plan (PRTR) and the Recovery and Resilience Facility. Building owners with renovation plans should assess whether applying for a renovation passport is preferable to undertaking isolated measures, given that the passport may be a prerequisite for accessing certain public financing streams. | The EPBD 2024 also establishes concrete obligations on solar energy integration in new buildings. According to MITECO, in the Spanish implementation guidance for the directive, all new public buildings and new non-residential buildings with a usable floor area exceeding 250 square metres must have solar installations in place before 31 December 2026, where technically and economically feasible. This obligation is progressively extended to other building categories in subsequent phases. This requirement overlaps with provisions already established in CTE DB HE (the Basic Document on Energy Saving), which in its 2019 revision set minimum solar contribution requirements. EPBD 2024 raises that threshold and makes it binding under tighter deadlines, treating solar energy as default infrastructure rather than an optional measure. For new-build projects above the 250 square metre threshold in public or non-residential use, technical and economic feasibility of solar installation must be assessed from the outline design stage, with exception assumptions properly documented where applicable. | The EPBD 2024 compliance calendar extends well beyond the May 2026 transposition deadline. According to BUILD UP, the first binding life cycle analysis (LCA) requirements will begin to apply to large buildings from 2028, extending to all new buildings in 2030. In the context of EPBD 2024, LCA measures the global warming potential across the full life cycle of a building, encompassing construction materials, the operational phase, and demolition, expressed in kilograms of CO2 equivalent per square metre per year. This means that projects currently being designed for large floor areas must already incorporate LCA methodologies into their technical documentation in order to be compliant when those requirements come into force. Integration of LCA into BIM models, following information management protocols such as those described in ISO 19650, is the most efficient route to ensuring that documentation is coherent, traceable, and updatable across the life of the asset. This is particularly relevant for building typologies that combine high technical loading with floor areas that frequently exceed the thresholds triggering the most demanding obligations. Additionally, according to the European Commission Directorate for Energy, Member States are required to submit their final national building renovation plans before 31 December 2026. Those plans must quantify the existing building stock, set renovation targets by decade, and define associated financing measures, providing the priority framework against which national and European funding calls will be aligned. | The regulatory landscape resulting from EPBD 2024, in combination with the CTE, RITE, and the energy audit obligations under Royal Decree 56/2016 (which transposes Directive 2012/27/EU on energy efficiency and requires large enterprises to carry out audits every four years), creates a complex compliance environment with multiple active deadlines. The principal practical implications are as follows. EPCs issued before May 2026 may require revision if they do not comply with the Annex V format of the directive, particularly in property transactions occurring after that date. Owners of buildings with renovation plans should evaluate whether requesting a renovation passport is preferable to carrying out isolated measures, given that the passport may be a condition of access to certain public financing lines. New-build projects exceeding 250 square metres in public or non-residential use must assess solar installation feasibility from the outline design phase, with exception assumptions properly documented. Engineering teams working on large buildings should incorporate LCA procedures into their workflows now to be prepared for the 2028 requirements. Energy audits conducted under Royal Decree 56/2016 must be consistent with the new EPBD 2024 indicators, in particular the global warming potential and the Smart Readiness Indicator. Across the EU, Member States at varying stages of transposition face the same underlying obligations, and the European Commission has made clear, through its infringement procedure mechanism, that incomplete or delayed transposition will not be treated as a technical formality.