The French environmental regulations: obligations and their effect on the works, 2026

The previous thermal standard had been a major advance, imposing a maximum primary energy consumption of 50 kWh/m²/year, dividing consumption by two to four against the earlier standard. It also introduced the bioclimatic coefficient, valuing the intrinsic quality of the envelope independently of the technical systems.

It had two major limits, however. First, it took no account of the carbon footprint of construction itself — materials, transport, the site. Second, it structurally disadvantaged electric heating against gas, through a primary energy conversion factor of 2.58 for electricity against 1 for gas, whereas the French electricity mix, largely nuclear, has a markedly better carbon balance than gas.

The environmental regulations correct both biases: they introduce a carbon requirement covering materials and equipment while revising the electricity conversion factor to 2.3. They set the building within a circular-economy and low-carbon perspective, consistent with the Paris Agreement and the national low-carbon strategy.

Former standard — indicators: primary energy, bioclimatic need, summer comfort

Former standard — electricity factor: 2.58

Former standard — carbon: not taken into account

Former standard — life-cycle assessment: not required

Environmental regulations — indicators: non-renewable primary energy, bioclimatic need, degree-hours, construction carbon, energy carbon

Environmental regulations — electricity factor: 2.3, moving progressively towards 2.1

Environmental regulations — carbon: construction and energy carbon mandatory, with thresholds

Environmental regulations — life-cycle assessment: a dynamic assessment mandatory from the outline stage

The regulations apply to new residential buildings and to new offices and primary and secondary schools. Extensions to existing buildings are not subject to them, falling instead under the element-by-element regime for existing buildings. Agricultural buildings, temporary construction under two years and buildings heated below 12 °C are exempt.

Table 1. The implementation timetable. The thresholds tighten progressively to push the industry towards buildings with a very low carbon footprint.

They apply to applications filed from the dates above. Applications filed under the former standard continue to be determined under it.

A compliance certificate must accompany the planning application. A second certificate is required at completion.

The thermal and environmental study, including the life-cycle assessment, should start as early as possible — ideally at concept stage, since the bioclimatic indicator is directly governed by fundamental architectural choices: orientation, glazing ratio, shading.

Two decrees published in 2026 amend the regulations and must be checked before any application is filed.

The decree of 15 January 2026, published on 17 January, extends the scope to thirteen categories of building until now exempt: libraries and media centres, atypical and university teaching buildings, hotels, restaurants, shops, early-years facilities, healthcare establishments, air terminals, changing facilities, sports facilities, and industrial and craft buildings. It applies to applications filed from 1 May 2026. Almost all new construction thereby enters the scope.

The decree of 18 March 2026, published on 20 March with an order of the same date, adjusts the requirements for applications filed from 1 July 2026. It widens the exemptions applicable to roof extensions below 150 m² or under 30 % of the existing area, and introduces three modulating coefficients for apartment buildings: the area of outdoor amenity space such as balconies, loggias and terraces; the average floor-to-ceiling height of the storeys; and the presence of cooling in buildings connected to district heating. Both texts implement part of the recommendations of an official review.

For the economist the consequence is twofold. Commercial operations until now outside the scope enter the regulatory calculation and must bear the study cost, while the new modulations can lighten the compliance cost of some apartment schemes. Which version applies is read from the date the application is filed, not the date work starts.

The regulations define six performance indicators, five of which carry regulatory thresholds not to be exceeded. They cover the two dimensions of the regime: energy performance and environmental impact.

Table 2. The six indicators and their regulatory status.

This measures the building's need for heating, cooling and lighting, independently of the systems installed. It quantifies the intrinsic quality of the envelope: insulation, air-tightness, orientation, glazed area, solar protection, thermal mass. Inherited from the previous standard, it is reinforced with thresholds 20 to 30 % more ambitious according to zone.

Its originality is to value bioclimatic design independently of the heating system chosen. A well-designed building has a low figure whatever its heating. Conversely, a poor figure cannot be compensated by high-performance equipment — a fundamental difference from earlier regulation.

This indicator replaces the earlier consumption measure. It covers only the non-renewable fraction of the primary energy consumed. Changing the electricity conversion factor from 2.58 to 2.3 recognises the favourable carbon balance of French electricity. It favours electric heating, heat pumps in particular, and reflects the intention to eliminate fossil gas progressively from new buildings.

Thresholds vary with the climate zone, the use, the altitude and the area of the dwellings. For an apartment building in the coldest zone, the maximum is of the order of 65 kWh/m²·year, against an achievable consumption of 30 to 50 with a high-performance heat pump.

This is the summer comfort indicator, replacing the earlier internal temperature coefficient. It measures the number of hours the internal temperature exceeds a reference, weighted by the intensity of the excess. The lower it is, the better the summer comfort. The regulatory threshold for housing is 1,250 °C·h, beyond which the scheme fails.

It gives value to passive protection against heat: shading through vegetation, roof overhangs and movable devices; thermal mass; night ventilation; limitation of internal gains. It strongly discourages systematic air-conditioning as the answer to summer comfort, pushing towards bioclimatic architectural solutions.

This is the most innovative indicator. It measures the greenhouse gas emissions generated by manufacturing the materials, transporting them, installing them on site, the losses and waste of construction, and the end of life of the building — demolition and waste treatment. It is expressed in kg CO₂ eq. per square metre of floor area, over a 50-year life.

The threshold for apartment buildings is around 650 kg CO₂ eq./m² at the 2022 level, lowered to around 580 at the 2025 level. For individual houses the thresholds are higher, around 750 falling to 640. They tighten progressively, forcing the industry to reduce the carbon footprint of its materials and methods.

The indicator strongly rewards bio-based materials — structural timber, plant or animal fibre insulation, low-carbon concrete, unfired earth brick. These sequester biogenic carbon and have a manufacturing balance far below conventional materials:

• Conventional reinforced concrete: 200–350 kg CO₂ eq./m³

• Low-carbon concrete: 100–180 kg CO₂ eq./m³

• Cross-laminated timber: −500 to −800 kg CO₂ eq./m³, through sequestration

• Mineral wool insulation: 30–50 kg CO₂ eq./m³

• Wood fibre insulation: 5–15 kg CO₂ eq./m³

• Cellulose insulation: −50 to +10 kg CO₂ eq./m³

Building in timber, or in mixed timber and concrete, can reduce construction carbon by 30 to 50 % against an all-concrete building.

This measures the greenhouse gas emissions from energy use in operation over the conventional 50-year life. It depends both on the energy performance of the building and on the emission factor of the energy used. French electricity, at roughly 50–80 g CO₂ eq./kWh according to the hour and the year, has a very clear advantage over gas at around 230 and oil at around 300. The regulations therefore make fossil gas heating in new buildings very difficult both economically and legally.

The regulations make a dynamic life-cycle assessment mandatory, in accordance with the European standard. It covers every module of the life cycle: manufacture, transport and installation of the products; operation of the building; deconstruction, transport and waste treatment; and benefits and loads beyond the system boundary, notably reuse and recovery.

A dynamic assessment differs from a conventional static one by taking account of when impacts occur: emissions close in time have a stronger climate impact than future ones. That approach is more rigorous but also more complex, requiring specialist calculation tools.

The assessment rests on environmental data specific to construction products:

• Environmental and health declarations: data from a product life-cycle assessment carried out by the manufacturer, verified by a third party and declared in the national database

• Environmental product profiles: the equivalent for electrical, electronic and mechanical equipment

• Default conventional data: usable where no specific declaration exists, but penalising, since they are loaded by 30 %

The national database now holds more than 12,000 declarations. Manufacturer data is improving but remains incomplete for some materials.

The regulations carry over and reinforce the earlier air-tightness requirements. The thresholds remain the same — 0.6 m³/h/m² for individual houses, 1.0 for apartments — but testing is systematised: an air permeability measurement or an approved quality process is mandatory to certify compliance at the end of the works.

The regulations contain a trajectory out of fossil gas for heating new buildings. In new housing, a principal gas heating system is tolerated only where the scheme simultaneously satisfies the primary energy, summer comfort and energy carbon requirements, which becomes very difficult from the 2025 threshold. In practice clients are turning massively to air- and ground-source heat pumps, to district heating connections and to solar thermal.

Without imposing a single technical solution, the regulations push indirectly towards renewables through the energy carbon thresholds. The solutions most commonly adopted for compliance in apartment buildings are a communal air-to-water heat pump on a shared water loop, connection to a district heating network supplied more than half from renewable or recovered energy, and photovoltaics combined with an electric heat pump.

A compliance certificate must accompany the application. It is drawn up by the design team, architect or engineer, and certifies that the scheme incorporates the requirements at design stage across all the indicators. It engages the signatory's professional liability.

At completion a second certificate is required. It is drawn up by a certified assessor, a technical controller or a certifying body independent of the designer. It states the real calculated values of the indicators and certifies their compliance with the applicable thresholds. It accompanies the notice of completion.

Compliance at completion rests on the materials actually installed. If they differ from those assumed in the assessment filed with the application, the construction carbon must be recalculated. Several practices secure this point:

• Write specific environmental declaration requirements into the specification for high-impact materials: concrete, steel, insulation

• Require contractors to supply the declarations for the products installed, at handover

• Allow time in the programme after handover for the final recalculation

The regulations are the minimum regulatory base. Voluntary labels allow more to be done and a higher environmental performance to be valued commercially.

Table 3. The principal environmental building labels in France.

The positive-energy label is particularly relevant for clients wishing to place their output in sustainable investment markets. It requires on-site renewable generation at or above the building's consumption, including plug loads, which generally means a significant photovoltaic installation on the roof or the façade.

Studies published between 2021 and 2024 put the construction premium at 3–8 % for apartment buildings and 4–10 % for individual houses, according to the constructional and equipment choices. It arises mainly from the reinforced envelope requirement, the move to heat pumps, the mandatory life-cycle assessment and the choice of low-carbon materials.

Table 4. Economic impact item by item, estimated for new apartment buildings.

If the regulations generate a capital premium, they also produce significant operating savings. Reduced energy consumption and the move to heat pumps bring the energy charges of an apartment down to 200–400 € a year against 600–900 € for a building of the mid-2000s standard. Over 20 years, assuming energy prices rise 4 % a year, the discounted saving per dwelling is 5,000 to 12,000 € — amply erasing the capital premium.

The construction economist is pivotal to compliance: they must be able to price the effect of each constructional choice on the regulatory indicators — which technical package best optimises construction carbon, primary energy and summer comfort together? — assess the premium of low-carbon materials against conventional options, and weigh the technical solutions with the thermal engineer. That transversality between regulation, technique and economics is at the heart of Quostra's value added.

• From concept stage: engage the thermal engineer and launch an indicative envelope calculation

• At outline stage: a preliminary life-cycle assessment, the choice of heating system, a summer comfort check

• Overall premium against the previous standard: + 3–8 % for apartments, + 4–10 % for houses

• Principal items: insulation (+ 5–15 €/m²), heat pump (+ 510–1,530 € per dwelling), low-carbon materials (+ 2–6 % on structure)

• Assessment and certificates: 4,500–11,500 € excl. VAT of additional fees per operation

• Long-term operating gain: 5,000–12,000 € discounted per dwelling over 20 years

• In the specification: require manufacturers' environmental declarations for high-carbon materials

→ Construction regulations in France: the overview and general framework

→ Accessibility in construction: obligations and measures

→ Fire safety and fire resistance

→ Buildings open to the public: classification, categories and compliance

→ Planning permission: procedures, timescales and parties

→ Timber and bio-based construction: regulation and economics

→ Thermal regulation of existing buildings: renovating in compliance

Environmental compliance has a cost only a specialist economist can price precisely. Submit your programme on quostra.com.

Reference basis of the figures

The ratios per square metre and per item on this page are stated in January 2026 values. They were updated from January 2025 values, the basis adopted for the whole cocoon, using the BT01 all-trades index published monthly by INSEE on its 2010 base: 132.0 in January 2025, 134.7 in January 2026, a coefficient of 1.0205.

The global amounts quoted as examples, and any rents, charges or receipts expressed per year or per night, remain on their own basis: a building cost index does not apply to them.

To bring the ratios forward, apply the usual revision formula: updated value = page value × (BT01 for the month in question / 134.7). The BT01 measures contractors' input costs, labour at 44.9 % and materials at 36.5 %, not the prices actually tendered.

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