The mechanism
Simple to state, and considerable in its effects. A renovation becomes compulsory after a transfer of ownership.
The purchaser of a residential property rated E or F must reach at least rating D.
The obligation applies to notarial deeds executed since 1 January 2023.
Proof is by a new energy certificate, obtained after the works.
The former owner is not covered. So long as they do not transfer, they remain outside the scheme, which clearly distinguishes this regime from the Brussels one.
The 2026 relaxation
A decisive point, and older information would today be wrong. The period and the level required have been amended.
The period moved from five to six years in early 2026. The purchaser therefore now has six years from acquisition to reach the required rating.
The rating to reach remains D, whereas a tightening had initially been envisaged. That tightening was abandoned.
That double relaxation shows the scheme remains politically mobile, which justifies systematic checking before any commitment.
| Element of the scheme | Applicable rule |
|---|---|
| Properties concerned | Dwellings rated E or F |
| Level to reach | Label D at least |
| Triggering event | Notarial deeds executed since 1 January 2023 |
| Period | Six years since early 2026, previously five |
| Proof | A new energy certificate issued after the works |
What counts as a transfer
The notion is wider than a sale, and this is a frequent source of error. It covers several forms of transfer.
Covered are sale, gift, the creation or transfer of long lease or building rights, and certain forms of contribution to a company. The exact list is checked in the applicable text.
The test is a change of ownership or of a right in rem, not the nature of the transaction.
A gratuitous transfer may therefore trigger the obligation, which the parties generally do not anticipate.
Penalties
They exist and they are not symbolic.
Failure to meet the deadline exposes the owner to an administrative fine, whose amount for dwellings ranges from 500 to 5,000 euros, within a considerably higher general framework.
The fine does not release from the obligation. The authority then sets a new period for carrying out the renovation.
Enforcement operates through the certificate. The absence of a new certificate at the deadline, or one not meeting requirements, may trigger proceedings.
Extension to non-residential
A recent development widening the scope.
The certificate obligation now extends to non-residential buildings above a floor area threshold.
That directly concerns construction professionals, whose projects on office or retail buildings are progressively entering the scheme.
The case of major renovation
A combination worth knowing, distinct from the transfer-based obligation. Other obligations attach to certain buildings irrespective of any sale.
An application for consent for deep transformation may bring the project within its own energy requirements regime, that applicable to major renovations.
That regime has its own requirements and its own period, aligned with the general obligation.
Two logics may therefore apply to the same property: that of transfer and that of the scale of works, covered in the article on permits and exemptions.
What it changes in negotiating a purchase
Three practical effects, all favouring the informed purchaser. They bear on the price, the calendar and the negotiation.
The rating becomes a price factor. A property rated E or F carries a quantifiable obligation, which may legitimately weigh in negotiation.
The certificate must be read before the offer, not after the preliminary agreement.
The cost of upgrading must be estimated before commitment, which calls for an audit rather than a mere certificate, as the article on energy assessments explains.
What this means for a professional
Four rules.
Check the applicable period before advising, it having been amended in early 2026.
Check the nature of the transaction, several forms of transfer triggering the obligation.
Estimate the cost of upgrading before acquisition, while it remains negotiable.
Provide for the new certificate at completion, proof governing compliance with the obligation.
This article reflects the position of the rules at the date of checking and serves professional orientation. It does not replace technical advice or consultation of the regional administration.