Renting out after EPBD. New obligations for the landlord

The revised EPBD 2026 puts pressure on the energy class of rented homes. What this means for a small landlord and what documentation they will need to keep at hand.

You rent out a flat in a panel-built block with an EPC in class F. In 2030 you find out you can no longer sign a new tenant until specific renovations are done. You don’t have the old bathroom refurbishment invoices, you can’t remember when the boiler was last inspected. The scramble begins.

What EPBD adds for landlords

The directive EPBD EU/2024/1275 puts two obligations on member states that land hardest on landlords:

Minimum energy performance standards. Each country must cut residential primary energy use by 16 % by 2030 and 20–22 % by 2035. The directive leaves the method to states. Several — France (Loi Climat), Belgium, the Netherlands — have already opted for the rental ban on the worst-rated dwellings. France bans letting class G from 2025, F from 2028, E from 2034. Similar bans can be expected in other states after EPBD transposition.

Tenant information obligations. The EPC is already mandatory at listing. EPBD adds the requirement to display the class in the listing and to share the EPC before contract signature. A missing or outdated certificate will, from 2026, be grounds for a fine or contract invalidity in most states.

What this looks like in practice

Before the contract

• A current EPC, valid for at least the contract duration.
• Documentation of the heat source and domestic hot water — type, age, inspections.
• Envelope documentation — windows, insulation, roof — at least in outline.
• Inspection reports for electrics and gas where legally required.

During the contract

• A running record of reported defects and how they were handled — a dispute will want to see response time.
• Periodic inspection certificates (boiler annual in many countries, chimney per local rules, electrics every ~5 years).
• For renovations in a commonhold (condominium / WEG) — meeting minutes, the building renovation plan.

At exit

• Handover protocol, before/after photos.
• Utilities settlement with exact dates.
• If renovations happened during the tenancy — documents for the buyer or next tenant.

Where it starts to hurt

The most painful scenario: a class F or G flat in an 80s/90s block, owned by a landlord who inherited it and never actively worked on it. When a French-style rental ban arrives, the landlord has three options:

1. Renovate (heat pumps, insulation, new windows) — typically EUR 8–20 k for a standard flat, 10–20 year payback from rent.
2. Sell — at the price the market pays for class F (with the discount covered in the previous article).
3. Leave it empty — absurd, but in some cities some landlords will see it as logical.

Making the decision needs data: how much was put into the flat historically, what exactly is its state, what would it cost to reach class D. Without documentation this cannot be calculated.

Small landlord vs. developer

Large players have building managers keeping these records in order. A small landlord with 2–5 units is on their own. And that landlord is the one EPBD transposition hits hardest — precisely because they might not be aware it is coming.

A landlord with three flats in January 2027

She owns three flats in a mid-sized city. One from 1975 with original windows, two partly refurbished. In January 2027 the building manager emails: „Under the EPBD transposition we need a current EPC for every unit by end of March.” She has one certificate. Not the other two. For the 1975 flat she has no idea what class it will get. If F, it may mean that within two years she cannot legally rent it without investing in insulation.

She does not know the numbers yet. But the clock just started.

This is the fifth article in a series on EPBD and property in Europe. The next one looks at holiday homes — the cottage, the stuga, the mökki.

I write this series as the founder of Helpick, a property management app for Europe.