Policy Lab


Europeans rightly consider climate change a very serious challenge, probably the most serious of our times.

As European Commission President, Ursula von der Leyen said, fighting climate change is our generation’s task and we take it seriously.

Social, cooperative, and public housing’s historic mission of providing affordable and quality homes has for many years now taken the climate change challenge on board and are now frontrunners for the fair energy transition. The sector continues to complete its mission to renovate 4 million homes by 2030.

The European Affordable Housing Consortium, SHAPE-EU is all about leading by example while being driven by a vision of climate-proof and fair transition.

However, where do we stand with EU legislation?

In July and December 2021, the European Commission published proposals to revise the EU legislation (Energy Efficiency directive  (EED), the Renewable Energy Directive (RED), the Energy Performance of Buildings directive). This revised legislative framework will have an impact on the activities of housing providers (for new construction and for the renovation of existing buildings).

The obligation to renovate

EED article 6

Each Member State shall ensure that, at least  3 % of the total floor area of heated and/or cooled buildings owned by public bodies is renovated each year to at least meet at least be transformed into nearly zero energy buildings.

Here public bodies mean contracting bodies in the sense of the Public Procurement Directive, which means that social housing providers would have to follow this obligation.

EPBD article 9

Minimum Energy Performance Standards require class G buildings to be renovated and improved to at least energy performance class F at the latest by 2027 and to at least energy performance class E at the latest by 2030, and the worst-performing residential buildings to at least class F by 2030 and to at least class E by 2033. The focus on the very lowest performing classes of the building stock ensures that efforts focus on buildings with the highest potential for decarbonisation, energy poverty alleviation and extended social and economic benefits. Member States shall also, as part of the national building renovation plans, establish specific timelines for achieving higher energy performance classes (for buildings falling in the scope of Article 9(1)) by 2040 and 2050, in line with their pathway for transforming the national building stock into zero-emission buildings. In addition to the minimum energy performance standards in accordance with Article 9(1), Member States have the option to introduce national minimum energy performance standards in their national renovation plans. Member States must support compliance with minimum energy performance standards with an enabling framework including financing support, in particular targeting vulnerable households and people affected by energy poverty or living in social housing, technical assistance, and monitoring mechanisms. The proposed provisions allow Member States to exclude several categories of buildings from the obligation to comply with minimum energy performance standards.

The requirement to have more transparent data on buildings

EPBD article 14

Member States shall ensure that the building owners, tenants and managers can have direct access to their building systems’ data. At their request, the access or data shall be made available to a third party. Member States shall facilitate the full interoperability of services and of data exchange within the Union in accordance with paragraph . For the purpose of this Directive, building systems data shall include at least all data related to the energy performance of building elements, the energy performance of building services, building automation and control systems, meters and charging points for e-mobility.

The promotion of renewable energy sources

EPBD article 8

a clear legal basis for national bans of boilers based on fossil fuels is introduced, allowing Member States to set requirements for heat generators based on greenhouse gas emissions or the type of fuel used. Several Member States consider such measures as essential to achieve a decarbonised building stock and to improve air quality and health

 RED article 15a

Member States shall introduce measures in their building regulations and codes and, where applicable, in their support schemes, to increase the share of electricity and heating and cooling from renewable sources in the building stock, including national measures relating to substantial increases in renewables self-consumption, renewable energy communities and local energy storage, in combination with energy efficiency improvements relating to cogeneration and passive, nearly zero-energy and zeroenergy buildings. To achieve the indicative share of renewables, Member States shall, in their building regulations and codes and, where applicable, in their support schemes or by other means with equivalent effect, require the use of minimum levels of energy from renewable sources in buildings, in line with the provisions of Directive 2010/31/EU. Member States shall allow those minimum levels to be fulfilled, among others, through efficient district heating and cooling.

Funding for the renovation of social housing

EED article 22

Member States shall implement energy efficiency improvement measures and related consumer protection or information measures, in particular those set out in Article 21 and Article 8(3), as a priority among people affected by energy poverty, vulnerable customers and, where applicable, people living in social housing to alleviate energy poverty.

  1. To support vulnerable customers, people affected by energy poverty, and, where applicable, people living in social housing, Member States shall: a) implement energy efficiency improvement measures to mitigate distributional effects from other policies and measures, such as taxation measures implemented according to Article 9 of this Directive, or the application of emission trading in the buildings and transport sector according to the ETS Directive; b) make the best possible use of public funding available at national and Union level, including, where applicable, the financial contribution Member State received from the Social Climate Fund and revenues from allowance auctions from emission trading pursuant to the EU ETS, for investments into energy efficiency improvement measures as priority actions.