What should building owners know about the EPBD and building automation?

The EU's recast Energy Performance of Buildings Directive, Directive (EU) 2024/1275, makes building automation and control a defined requirement for many non-residential buildings and sets out what those systems must be capable of. A directive, however, does not apply directly to buildings. Each EU country turns it into national law, so owners need to understand the EU framework and then confirm the national rules that apply to each property. Compliance depends on the building, its systems and the national implementation. Having a BMS installed does not settle it either way.

Key dates

The European Commission's summary gives the key dates. The recast directive entered into force on 28 May 2024, and the general deadline for transposing it into national law was 29 May 2026. In June 2025 the Commission adopted a support package with guidance for EU countries on implementing the recast directive. Whether, when and how a particular country has transposed the relevant provisions has to be checked country by country; the passing of the EU deadline shows neither that a national rule is in force nor what it says.

What Article 13 requires

Article 13(9) requires EU countries to lay down requirements so that, where technically and economically feasible, larger non-residential buildings are equipped with building automation and control systems, by the end of 2024 or the end of 2029 depending on the rated output of their heating, air-conditioning and ventilation systems (over 290 kW and over 70 kW respectively).

Article 13(10) states that these systems must be capable of:

The thresholds are easy to misread

The thresholds refer to the effective rated output of the specified systems, not to floor area, and national guidance explains how to count it. Ireland's guidance on its regulations under the previous directive, for instance, applies the threshold to each system individually and sums units that operate jointly; other countries may differ.

What your automation can actually do

A proper review compares the installed automation with each capability in turn. Which energy flows are metered and integrated? How long is data retained? Is anyone told when efficiency falls? Which interfaces are open and documented, and is indoor environmental quality monitored at all? Along the way, look for functions that exist in the product but were never configured or commissioned. A product name or a controls cabinet is not evidence of compliance. Industry bodies have published checklists that translate the requirements into evidence, and they can help structure a review, but national rules decide.

Feasibility provisions, exemptions and inspection regimes are matters of national law, to be confirmed with appropriate local legal and engineering advisers.

A method for a portfolio

Owners with several buildings need a repeatable method that works the same way in every building. A workable sequence runs as follows:

1. List each building's heating, air-conditioning and ventilation systems with their effective rated output, counted in the way the applicable national guidance requires.
2. Group the buildings by whether they are above the relevant thresholds, and flag any where planned plant changes would carry them across one.
3. For each building in scope, collect the evidence: the metering schedule, the BMS points list, data-retention settings, how efficiency losses are notified and to whom, interface documentation and any indoor-environment sensors.
4. Classify the gaps as configuration and commissioning work on existing systems, additional metering or sensors, or new or replacement automation.
5. Align the work with planned plant replacements and refurbishments, so that automation is specified with the plant and need not be retrofitted later.
6. Confirm feasibility, exemptions and deadlines for each country with local advisers before committing budgets.

The evidence gathered at the third step is useful whatever the legal outcome. It shows what the existing automation can really do, and it is the starting point for any upgrade specification.