EU Taxonomy for buildings: Activities 7.1, 7.2, and 7.7 requirements explained (2026)

Regulation (EU) 2020/852, the EU Taxonomy, classifies economic activities as environmentally sustainable for investment purposes. The technical screening criteria for buildings are in Annex I of Commission Delegated Regulation (EU) 2021/2139 (the Climate Delegated Act). For Activity 7.1, construction of new buildings, the primary energy demand (PED) must be at least 10% below the threshold set for the nearly zero-energy building (NZEB) requirements. For buildings larger than 5,000 m², the life-cycle global warming potential (GWP) must also be calculated for each life-cycle stage and disclosed to investors and clients on demand.

EU Taxonomy building activities at a glance

The criteria above follow the European Commission’s summary of the technical screening criteria. Confirm the exact wording and any later amendment in Annex I of Delegated Regulation (EU) 2021/2139 before relying on a threshold in a submission.

What is the EU Taxonomy and why does it affect buildings?

The EU Taxonomy is a classification system established by Regulation (EU) 2020/852 that defines which economic activities count as environmentally sustainable for investment purposes. Undertakings that must publish sustainability information report the share of their activities that is Taxonomy-aligned (Article 8 of the Regulation). For a developer or owner, a Taxonomy-aligned building supports that reporting and can open access to green-finance products.

The Regulation has six environmental objectives: climate change mitigation, climate change adaptation, sustainable use of water and marine resources, the transition to a circular economy, pollution prevention and control, and the protection of biodiversity and ecosystems. An activity is Taxonomy-aligned when it makes a substantial contribution to at least one objective, does no significant harm (DNSH) to the others, meets minimum social safeguards and complies with the technical screening criteria. The Climate Delegated Act holds the criteria for climate change mitigation and adaptation.

What does Activity 7.1 require for new construction?

Activity 7.1 covers construction of new buildings. Three criteria apply for substantial contribution to climate change mitigation.

First, for all new buildings, the PED must be at least 10% lower than the threshold set for the NZEB requirements, and the energy performance is certified with an as-built energy performance certificate (EPC).

Second, for buildings larger than 5,000 m², the building is tested for air-tightness and thermal integrity, and any deviation or defect is disclosed. As an alternative, robust and traceable quality-control processes must be in place during construction.

Third, for buildings larger than 5,000 m², the life-cycle GWP of the building is calculated for each stage in the life cycle and disclosed to investors and clients on demand. The criterion asks for a calculation and disclosure on request. It does not set a GWP ceiling. For the calculation method, see EN 15978 explained.

The DNSH criteria add, for climate change adaptation, a climate risk and vulnerability assessment and adaptation solutions; for water, specified water use for appliances where installed (except in residential buildings); and for the circular economy, at least 70% by weight of non-hazardous construction and demolition waste prepared for reuse, recycling and other material recovery, plus measures to limit waste and to support circular building design. Pollution criteria also apply to building components and materials.

What does Activity 7.2 require for building renovations?

Activity 7.2 covers renovation of existing buildings. Either of two criteria qualifies: the renovation complies with the applicable requirements for major renovations, or it leads to a reduction of PED of at least 30%. The EPBD definition of major renovation is in Article 2(22) of Directive (EU) 2024/1275 (see EPBD 2028 architect requirements); the criterion refers to the applicable requirements for major renovations.

Renovations also have to meet the DNSH criteria, including the 70% construction and demolition waste criterion. Activity 7.2 has no whole-life GWP criterion in the Commission’s summary; that criterion sits with Activity 7.1. For the 30% pathway, an energy model that shows the PED before and after the works supports the claim.

How does Activity 7.7 apply to building acquisitions?

Activity 7.7 covers acquisition and ownership of existing buildings. For buildings constructed from 1 January 2021, the criteria for new buildings apply. For buildings constructed before 1 January 2021, the building must have at least EPC class A or be within the top 15% of the national or regional building stock, expressed as operational PED and demonstrated with adequate evidence. For large non-residential buildings with a heating, air-conditioning or combined system rated output above 290 kW, the building must also be efficiently operated through energy performance monitoring and assessment.

Because the top-15% test refers to the stock, the answer can change as the stock changes. An investor buying a building needs the EPC or equivalent evidence in the due-diligence pack.

Why do the Taxonomy building thresholds exist?

The 10%-below-NZEB criterion is relative, so it applies across Member States that each set their own NZEB level under the EPBD. The 70% waste criterion matches the 70% target for non-hazardous construction and demolition waste in Article 11(2) of the Waste Framework Directive 2008/98/EC, which applied by 2020. The life-cycle GWP criterion asks for a calculation and disclosure, which builds a data base of building-level carbon figures.

Which Taxonomy alignment mistakes should you avoid?

1. Reading the 5,000 m² threshold into the energy criterion. The PED criterion applies to new buildings of every size. The testing and life-cycle GWP criteria apply to buildings larger than 5,000 m².

2. Treating GWP disclosure as a pass/fail test. Activity 7.1 asks for a calculation per life-cycle stage and disclosure on demand. It sets no GWP ceiling.

3. Ignoring the circular economy DNSH. The energy criteria are not enough. Document the 70% construction and demolition waste figure in the project record.

4. Using EPC class A as a proxy for 7.1. For new buildings the test is PED at least 10% below the NZEB threshold, not an EPC class. EPC class A is an option for acquisitions of buildings constructed before 1 January 2021 under Activity 7.7.

5. Missing that the 7.7 top-15% test refers to the stock. The comparison group changes as the national or regional stock changes, so keep the evidence date-stamped.

Frequently asked questions

What buildings does Activity 7.1 apply to?

Activity 7.1 applies to construction of new buildings. All must meet the PED criterion (at least 10% below the NZEB threshold). Buildings larger than 5,000 m² must also be tested for air-tightness and thermal integrity (or have robust quality control) and have their life-cycle GWP calculated and disclosed on demand. Renovation of existing buildings falls under Activity 7.2.

Does the EU Taxonomy require buildings to pass a maximum GWP value?

The Commission’s summary of the criteria for Activity 7.1 asks for the life-cycle GWP to be calculated for each stage and disclosed to investors and clients on demand. It sets no maximum value. A separate rule applies under the EPBD: Article 7(2) requires disclosure in the energy performance certificate (see EPBD 2028 architect requirements).

What is the DNSH test for the circular economy under Activity 7.1?

At least 70% by weight of the non-hazardous construction and demolition waste generated on the site must be prepared for reuse, recycling and other material recovery, including backfilling operations using waste to substitute other materials, in line with the waste hierarchy and the EU Construction and Demolition Waste Management Protocol. Operators must also limit waste generation, and the design must support circularity.

How does the EU Taxonomy relate to CSRD?

The Taxonomy sets the criteria; undertakings that must report sustainability information disclose their Taxonomy-aligned share under Article 8 of Regulation (EU) 2020/852. The scope of CSRD reporting was narrowed by the Omnibus I amendments (Directive (EU) 2026/470, in force 18 March 2026) to companies with more than 1,000 employees and more than EUR 450 million net turnover. Check whether a client is in scope before assuming a Taxonomy documentation request will arrive.