EPBD 2028 Architect Requirements: Zero-Emission Buildings and Whole-Life Carbon Under Directive 2024/1275 (2026)

Directive (EU) 2024/1275 requires all new buildings to be zero-emission buildings from 1 January 2030 (Article 7(1)). New buildings owned by public bodies face the same requirement two years earlier: 1 January 2028. Member States had to transpose the directive by 29 May 2026. Architects with projects delivering in 2028 or later should plan the life-cycle global warming potential (GWP) calculation from appointment, because the result goes into the energy performance certificate.

What are the EPBD 2024/1275 requirements at a glance?

EPBD 2024/1275 is the EU’s recast Energy Performance of Buildings Directive. It sets phased zero-emission requirements for new buildings and a life-cycle GWP disclosure rule. Directive (EU) 2024/1275 entered into force on 28 May 2024, and Member States had to transpose it by 29 May 2026.

Until those dates, all new buildings must be nearly zero-energy buildings and meet the minimum energy performance requirements of Article 5. Article 7(4) lets Member States choose not to apply the ZEB and GWP rules to buildings whose permit applications (or equivalent applications, including for a change of use) were submitted before the relevant dates. Life-cycle GWP is calculated under Annex III, which Delegated Regulation (EU) 2026/52 (published in the Official Journal on 4 May 2026) updates; read it for the modules, reference study period and unit. Cost-optimal levels of minimum energy performance requirements are calculated under Article 6, and Member States may set requirements stricter than the EU floor.

What is a zero-emission building under Directive 2024/1275?

A zero-emission building (ZEB) is defined in Article 2(2) and set out in Article 11 of Directive (EU) 2024/1275. It is a building with a very high energy performance, as set out in Annex I, that causes no on-site carbon emissions from fossil fuels and has zero or very low operational greenhouse gas emissions.

Article 11 sets four main conditions. First, the building shall not cause any on-site carbon emissions from fossil fuels. Second, its energy demand must stay below a maximum threshold set by the Member State: at least at the cost-optimal levels of the latest national report under Article 6, and at least 10% lower than the national total primary energy threshold for nearly zero-energy buildings that applied on 28 May 2024. Third, operational greenhouse gas emissions must meet a maximum threshold set nationally. Fourth, the total annual primary energy use must be covered by on-site or nearby renewable energy, renewables from a renewable energy community, efficient district heating and cooling, or carbon-free sources; where that is not technically or economically feasible, other grid energy meeting national criteria may cover the shortfall.

Because Member States set the numeric thresholds, a project in Germany faces different numbers than one in Spain. The no-on-site-fossil-emissions condition is part of the EU text, not a national option. Architects working across jurisdictions must track each national transposition.

When does whole-life carbon disclosure become mandatory?

Under Article 7(2) of Directive (EU) 2024/1275, the life-cycle global warming potential of a new building must be calculated under Annex III and disclosed in the building’s energy performance certificate. This applies from 1 January 2028 to new buildings with a useful floor area above 1,000 m², and from 1 January 2030 to all new buildings.

The threshold is based on useful floor area, not gross floor area. Article 2(51) defines useful floor area as the floor area needed as a parameter to quantify specific conditions of use expressed per unit of floor area. Use the national method for useful floor area when testing the 1,000 m² threshold, not a gross floor area figure from the drawings.

Article 7(2) requires calculation and disclosure. It does not set a GWP limit, though Member States may add national limits. The practical effect for architects: a life-cycle GWP calculation is needed for new buildings above 1,000 m² useful floor area from 2028, and for all new buildings from 2030.

What should architects plan at appointment?

The Directive does not list architect deliverables. The following is practice guidance for meeting the Article 7(2) duty, not a legal checklist.

1. Life-cycle GWP calculation per Annex III. Check the modules, reference study period and unit in Annex III as updated by Delegated Regulation (EU) 2026/52, and in the national transposition.

2. Material quantities. The calculation needs structured quantities by assembly and material. Plan the model or schedules so they can be exported to LCA software.

3. Product environmental data. EPDs under EN 15804+A2 are the usual source of product data; generic datasets can stand in at early design stages and be replaced as products are selected.

4. Operational energy and emissions. The energy performance calculation that feeds the certificate, and the operational emissions the ZEB thresholds refer to, are a separate calculation from the GWP disclosure.

Because the GWP result is entered into the energy performance certificate, agree who prepares each input, and by when, in the appointment.

What are the common EPBD compliance mistakes architects make?

Four misunderstandings cause late rework.

1. Ordering the LCA at construction stage, not appointment stage. An LCA commissioned after structural elements are fixed cannot inform material substitution decisions.

2. Using unstructured takeoffs as LCA inputs. A calculation needs material quantities by assembly. Quantities taken from a PDF drawing set by hand are slow to update and easy to get wrong.

3. Mixing EPD versions. EPDs under EN 15804:2012 without the +A2 amendment report different indicators and are not directly comparable with +A2 EPDs.

4. Confusing the 1,000 m² disclosure threshold with a ZEB exemption. The 1,000 m² useful floor area threshold applies only to the 2028 start of GWP disclosure. ZEB requirements apply to new buildings from 2028 (public bodies) or 2030 (all), whatever their size, subject to the exemptions Member States adopt.

Frequently asked questions

What does ZEB mean under EPBD 2024/1275?

A zero-emission building (ZEB) under Directive (EU) 2024/1275 (Article 2(2) and Article 11) is a building with very high energy performance, no on-site carbon emissions from fossil fuels, and zero or very low operational greenhouse gas emissions. “Zero-emission” refers to operational emissions; it does not mean zero embodied carbon.

When does the ZEB requirement apply to private-sector new buildings?

From 1 January 2030, all new buildings (public and private) must be zero-emission buildings under Article 7(1) of Directive (EU) 2024/1275. New buildings owned by public bodies face the earlier 1 January 2028 deadline.

Which buildings are exempt from the EPBD ZEB requirement?

Article 7(4) lets Member States choose not to apply the ZEB and life-cycle GWP rules to buildings whose permit applications were submitted before the relevant dates. Further exemptions are set at national level in the transposition. Verify the national transposition for the project jurisdiction before assuming any exemption applies.

What is a major renovation under the EPBD?

Article 2(22) defines a major renovation as a renovation where either the cost of renovating the building envelope or the technical building systems is higher than 25% of the value of the building (excluding the land), or more than 25% of the surface of the building envelope is renovated. Member States choose which of the two tests to apply.

When does life-cycle GWP disclosure apply to all new buildings?

From 1 January 2030, all new buildings must have their life-cycle GWP calculated and disclosed in the energy performance certificate under Article 7(2). New buildings with a useful floor area above 1,000 m² face the earlier 1 January 2028 date.