Commercial Real Estate · Energy Performance Certificate 2027
It is an inconspicuous document, only a few pages long, usually filed somewhere between the land register extract and the floor area schedule. For years, buyers and tenants of commercial property have taken note of the energy performance certificate and turned the page. On 1 January 2027, that changes. For offices, warehouses and commercial buildings, the certificate gets a new scale, a new calculation basis and a new role: it becomes the ticket into the negotiation.
The essentials in 30 seconds
Contents
Chapter 1 · The framework
For months, the political debate revolved around heating: heat pumps, gas boilers, the 65 percent rule. On 28 July 2026, the result was promulgated in the Federal Law Gazette, and since 29 July the Building Energy Act has officially been called the Building Modernisation Act, GModG for short. The heating rules have applied ever since.
For owners of commercial property, however, the real news lies in Article 2 of the act. It transposes the EU Energy Performance of Buildings Directive into German law and enters into force on 1 January 2027. Until the end of the year, newly issued energy certificates still follow the previous rules. After that, a new era begins.
The timeline
28 July 2026
The GModG is promulgated in the Federal Law Gazette.
29 July 2026
The GEG becomes the GModG. The new heating rules apply.
1 January 2027
New certificate rules for non-residential buildings: demand-based certificates only, efficiency classes A to G.
1 January 2030
First stage of minimum energy performance standards for existing non-residential buildings.
1 January 2033
Second, stricter stage of the minimum standards.
“From January, the energy certificate becomes a building's business card. And business cards get read closely.”
Alexander Gruhler, Managing Partner, Angermann NRW
What that business card says can be summed up in seven letters.
Chapter 2 · The scale
For residential buildings, the coloured scale running from deep green to red has long been familiar. Offices, warehouses and commercial buildings had nothing comparable. From 2027, non-residential buildings also receive an efficiency class, on a seven-step scale from A to G. Residential buildings keep their existing scale from A+ to H.
The logic behind it is what makes it interesting. The yardstick is not kilowatt hours per square metre but a so-called primary energy reference factor. It compares the building with its statutory twin, the reference building. A factor of 2.0 means the property needs twice as much primary energy as that twin.
The new scale for non-residential buildings from 2027
Values = primary energy reference factor, i.e. the ratio to the reference building. Basis: Annex 10a GModG.
Class A is more than just a good score. To earn it, a building must also be a zero-emission building that operates on site without fossil energy. For the market, though, the middle and the lower end of the scale matter most. A letter is compared faster than any metric.
“Every investor grasps a letter in three seconds. That is exactly where the new scale gets its punch.”
Alexander Gruhler, Managing Partner, Angermann NRW
But where will the letter come from? This is the second, less noticed change.
Chapter 3 · The calculation basis
Until now, owners of existing buildings had a choice. The consumption-based certificate was quick and inexpensive, fed by the utility bills of previous years. The demand-based certificate, by contrast, calculates the building from the ground up: envelope, building services, usage zones.
From 2027, that choice is over for non-residential buildings. New certificates are issued only on the basis of an energy balance calculation, in other words as demand-based certificates. The difference is fundamental. A consumption certificate shows how a building was used. A demand certificate shows what the building itself delivers. A frugal tenant can no longer make a weak building look good.
Consumption-based
Basis: energy actually billed
Reflects user behaviour
No longer issued for non-residential buildings from 2027
Demand-based
Basis: calculation of envelope and services
Reflects building quality
Standard for non-residential buildings from 2027
What this means for you
A certificate issued by 31 December 2026, including a consumption-based one, remains usable until the end of its ten-year validity, also for sales and lettings. A new certificate is only due once no valid one exists.
What is new is the trigger: from 2027, a certificate is also required when a lease, rental or leasing agreement is to be extended. Anyone who needs a new certificate should allow more lead time for the demand-based version: plans, building specifications and details of the building services have to be compiled. Going forward, it is issued digitally in a machine-readable format.
Specialised energy consultants such as GREENOX prepare demand-based certificates for non-residential buildings and know the new calculation rules. That is more than a formality. The new certificate uses exactly the measure by which the law will judge, from 2030, whether a building must be upgraded.
Chapter 4 · The deadlines
With Section 40 GModG, Germany introduces binding minimum energy performance standards for existing non-residential buildings for the first time, known as MEPS. They target the least efficient buildings in the stock. The obligation comes in two stages.
16 %
of non-residential buildings with the weakest performance come into focus from 2030.
26 %
from 2033, when the second stage applies.
Permitted primary energy demand relative to the reference building
Reference building
Limit from 1 January 2033
Limit from 1 January 2030
Covers annual primary energy demand for heating, hot water, ventilation, cooling and built-in lighting.
Put the figures next to the new scale and the law's logic becomes clear: 3.5 and 2.95 are exactly the boundaries between classes F and G and between E and F. Classes and upgrade obligation rest on the same ratio to the reference building. A class G building therefore misses the 2030 stage on paper, a class F building the 2033 stage. The letter on the certificate becomes an early-warning system. And the obligation attaches to each individual building. The law makes no provision for offsetting it against an efficient property elsewhere in the portfolio.
Whether an upgrade obligation actually applies depends on the individual case. Among other things, the requirement is deemed met or does not apply
Listed buildings as well as industrial facilities and workshops with low energy demand are also exempt. The upgrade obligation is therefore relevant above all for older, fossil-heated existing properties. This assessment belongs in the hands of an energy consultant.
Our partner recommendation
Energy certificates and energy consulting from one source: GREENOX
For everything related to energy certificates, we recommend our partner GREENOX. The team prepares demand-based certificates for commercial buildings, develops refurbishment concepts and advises on funding programmes, including here in Cologne.
“2030 sounds like the distant future. For an investor with a ten-year holding period, it sits right in the middle of the business plan.”
Alexander Gruhler, Managing Partner, Angermann NRW
And this is exactly where regulation turns into market dynamics.
Chapter 5 · The market
In our daily work with owners, investors and tenants, we have been watching the weights shift for some time. Today, the energy certificate is among the first documents buyers ask for, often right after location and tenant structure. The pressure comes from three directions.
Investors
Institutional investors have ESG targets to meet. A property with unclear efficiency is harder to fit into a portfolio.
Banks
Lenders increasingly tie their terms to a building's energy efficiency.
Tenants
Corporate occupiers bring their own climate targets and report on the emissions of their space.
What this means at the negotiating table is quickly told. An efficient property attracts more buyers. For a property in need of refurbishment, every buyer factors in the upcoming investment, with a safety margin. The thinner the data, the larger that margin becomes. Suddenly the negotiation is about cost estimates rather than about pricing in potential. With the new scale and fixed deadlines, this calculation becomes more visible to everyone involved, and therefore something the owner can shape.
“Owners who know and can document their building's energy status set the pace of the negotiation.”
Alexander Gruhler, Managing Partner, Angermann NRW
That leaves the question of what owners should actually do. The answer fits into five steps.
Chapter 6 · The roadmap
Review your documents
Which certificate exists, what type is it, how long is it valid? That determines whether to act before or after the deadline.
Get the class estimated
An energy consultant can estimate in advance where the building will land on the new A to G scale.
Check the deadlines
Year of construction, insulation standard and heating type show whether the 2030 and 2033 minimum standards are relevant at all.
A refurbishment roadmap with numbers
A roadmap with cost estimates turns a vague risk into a figure a buyer can work with.
Make the documentation market-ready
If a certificate exists, its key data belong in the property listing. From 2027, with a new certificate, this means for commercial properties too: certificate type, date of issue, primary energy demand, efficiency class, year of construction and main heating energy source. The certificate must be presented at the latest at the viewing.
Your next step
What is your commercial property worth, today and with 2030 in view?
Read how we support owners with a sale under Sales Advisory for Owners, and with lettings under Owner Representation. Our free indicative valuation (in German) provides a first orientation.
“Creating lasting value starts with a clear assessment, long before the first exposé is written.”
Alexander Gruhler, Managing Partner, Angermann NRW
Yes, provided it was properly issued before 1 January 2027 and is still valid. The new rules do not invalidate it. From 2027, however, new certificates for non-residential buildings are issued as demand-based certificates only.
The A to G class is based on the primary energy reference factor, the ratio of primary energy demand to that of the reference building. Class A additionally requires a zero-emission building. The scale applies to non-residential buildings from 2027; residential buildings keep A+ to H.
No. The minimum standards target the least efficient buildings. They are deemed met, among other cases, for buildings constructed from 1996 onwards and for buildings heated predominantly by heat pump or biomass or supplied with district heating. Listed buildings are also exempt. Whether a property is affected should be assessed case by case by an energy consultant.
From 2027, yes, unless a valid certificate already exists. The extension of a lease, rental or leasing agreement then becomes a trigger in its own right. For non-residential buildings, the new certificate is issued as a demand-based certificate.
From 2027, that depends on the certificate. With a new certificate, listings for commercial properties must also state certificate type, date of issue, primary energy demand, efficiency class, year of construction and main heating energy source. With a certificate issued before 2027, the requirements remain certificate type, final energy split into heat and electricity, and the heating energy source. In both cases the obligation applies if a certificate exists when the listing is placed.
Authorised energy consultants, architects or engineers. Effort and cost depend on size, usage zones, building services and the documents available.
Legal status: October 2026. Based on the Building Modernisation Act (GModG, Federal Law Gazette 2026 I No. 226) in the version applicable from 1 January 2027 (in particular Sections 40, 79 to 87 and 112 and Annex 10a) and on the information provided by the federal GModG information portal. This article is for general guidance and does not replace individual legal or energy advice.