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Sweden has now transposed most of the EU’s revised Energy Performance of Buildings Directive (EPBD) into national law. Several changes took effect on 1 October 2026, and further steps are already set out to 2033. The aim is a zero-emission building stock across the EU by 2050. For property owners, this is more than a technical update. It changes how a building’s energy performance is measured, how it is rated, and, for non-residential property, what minimum standard it must meet.

Why it matters

Buildings account for a large share of energy use and greenhouse gas emissions in the EU. The revised directive raises the ambition: New buildings are to be zero-emission, the worst-performing non-residential buildings are to be upgraded, and building energy information is to be more comparable across member states. Sweden already had energy requirements and energy performance certificates (EPCs), both rooted in earlier versions of the directive. The new rules build on that system but change it in important ways.

For property owners, this is more than a technical update. It changes how a building’s energy performance is measured, how it is rated, and, for non-residential property, what minimum standard it must meet.

Ebba Ramel, Head of Sustainability Business Analysis

A new way of measuring performance

Energy performance is now expressed through a new energy performance number, which replaces the previous primary energy number. The basic principle remains the same. The energy a building uses is multiplied by a weighting factor for each energy carrier, such as electricity or district heating, and divided by the heated floor area. The weighting factors themselves are unchanged, so the relative treatment of different heating solutions stays the same.

What changes is what goes into the calculation. The building’s use is now further standardised to typical values for each building category, so the figure reflects the building and its technical systems rather than how it happens to be used. Climate is now handled on the requirement side meaning that a building’s energy performance figure reflects its local climate, while requirements and class limits are scaled by a geographic factor (Fgeo). Some items are defined differently, and non-residential buildings are split into seven categories, each with its own requirement levels. As a result, the new figure is not comparable with the old one, even though the method rests on the same foundation.

A new rating scale, and a decade of two parallel systems

The A–G scale is kept, but with the new performance metric and new, fixed class boundaries, a building can move class without any physical change. Boverket’s estimates show a clear shift towards the top of the scale in all building categories, with the share in classes A–B rising to between roughly a fifth and almost half of buildings, depending on category. At the bottom of the scale the picture is more mixed. For most non-residential categories the share in F–G falls, while for residential buildings it stays roughly the same or rises somewhat. Across all categories, around a fifth of buildings are expected to end up in classes F–G.

Existing certificates remain valid for up to ten years and cannot be converted automatically to the new EPC labels. For a decade, old and new ratings will exist side by side, and a portfolio’s reported energy classes will be partly incomparable.

A0: a new class for zero-emission buildings

Sweden has also introduced A0, a separate class for zero-emission buildings, in addition to the A–G scale. A new building qualifies if it meets the class A EPC level, has no fossil fuel combustion on site and, where technically and economically feasible, can respond to external signals by adjusting its energy use.

For existing buildings, the same last two criteria apply together with an EPC class B level. That level can be adapted where further improvement is not profitable, technically feasible or compatible with the building’s cultural values. As a result, an existing building can in principle qualify for A0 regardless of its underlying energy class. The certificate shows A0 together with the building’s underlying energy performance, so a building may, for example, be rated A0 while performing at the level of EPC class C.

If an existing building qualifies for A0 despite having an underlying energy class below EPC class B, the classification may not be permanent. As technology and cost-effectiveness evolve, the building’s A0 status may need to be reassessed if energy renovation becomes feasible.

Minimum standards for non-residential property

The most direct financial impact falls on owners of non-residential buildings. From 2030, the worst-performing buildings in each category must be improved to at least class F, which in practice phases out class G. From 2033 the threshold rises to class E. Boverket has also proposed extending the standard to phase out class E by 2040 and class D by 2050, which would affect a substantial part of the non-residential stock. Those later steps are not yet decided.

The obligation applies whether or not a building has a valid EPC, and compliance is supervised by the municipality. There are exemptions and room for adaptation where measures are not profitable or technically feasible, or where they would harm cultural heritage values. Residential buildings are not subject to mandatory renovation requirements. For housing, Sweden instead relies on a national trajectory largely based on owners implementing measures voluntarily.

New buildings

From 2028 for new publicly owned buildings, and from 2030 for all new buildings, the energy performance must correspond to EPC class A and qualify as a Zero-Emission Building (A0). In addition, a proposal recently under consultation would require developers to report a building’s climate impact over its whole life cycle, extending beyond today’s climate declaration system, with effect from 2028 for buildings over 1000 m2 and for all buildings from 2030, and introducing limit values for the construction phase from 2030.

What we recommend property owners to consider

  • Re-baseline the portfolio. Old certificates do not tell you where a building stands under the new rules. Identify which buildings are likely to fall in the lower classes under the new scale, starting with non-residential property approaching the 2030 and 2033 thresholds.
     
  • Plan for the full trajectory, not the next deadline. A building upgraded only to class F in 2030 may need further work by 2033 and possibly again later. Coordinating energy measures with planned maintenance and major refurbishments may be more cost-effective than successive minimum upgrades.
     
  • Keep actual energy use in view. Standardised EPCs and real consumption may diverge more than before. Investment cases should rest on both.
     
  • Engage your financiers. Energy classes are widely used in sustainable financing and reporting. Review any sustainable finance engagements to ensure they reflect the new classification framework. 

The bottom line

The new rules require property owners to assess their portfolios using a different performance metric while preparing for tighter requirements over time. This means identifying buildings that may be affected, understanding the implications of parallel EPC systems, and coordinating energy improvements with planned maintenance and investment decisions.

 

Author

Name:
Ebba Ramel
Title:
Head of Sustainability Business Analysis
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