The national building renovation plan (EPBD Art. 3): what it contains and what it means for energy auditors

Energy auditors work with documents at the scale of one building: the certificate, its annexes, the audit report. Directive (EU) 2024/1275 (EPBD) also requires a document at the scale of a whole country: the national building renovation plan. This guide explains what the directive requires, where Romania stands and why the certificates you issue are raw material for the plan. At the end there is an example on a building from the Zephren demonstrations.

What is the national building renovation plan?

Article 3(1) of the directive obliges each Member State to establish a plan that turns its national stock of residential and non-residential, public and private buildings, by 2050, into "a highly energy-efficient and decarbonised building stock", with the aim of transforming existing buildings into zero-emission buildings. It is a public policy instrument, not a direct obligation for owners or auditors.

What must it contain?

Article 3(2) lists eight elements, points (a) to (h). Those most relevant to an auditor's work are:

• An overview of the building stock (point a): building types, shares, construction periods and climate zones, built, where appropriate, on "the national database for energy performance certificates" referred to in Article 22. In other words, EPCs are a data source for the plan.
• The roadmap (point b): national targets and measurable progress indicators, with targets for 2030, 2040 and 2050 on the annual renovation rate, primary and final energy consumption and operational emission reductions.
• Policies, investment needs and financing (points c and d).
• Minimum energy performance standards for non-residential buildings (point f), based on the thresholds in Article 9(1), and the trajectory for renovating the residential stock (point g), with indicative milestones for 2030 and 2035, expressed as average primary energy consumption in kWh/(m²·year).
• Thresholds for zero-emission buildings (point e), under Article 11.
• The estimated energy savings (point h).

What are the deadlines?

• 31 December 2025: the first draft plan, submitted to the Commission (Article 3(3), second subparagraph), after a public consultation (paragraph 4).
• The Commission may issue recommendations within six months of the first draft being submitted (paragraph 5); the Member State takes them into account or publicly gives its reasons for not doing so (paragraph 6).
• 31 December 2026: the first national plan proper (paragraph 7, second subparagraph). It is then submitted every five years, as part of the national energy and climate plan.

Where does Romania stand?

According to the European Commission's BUILD UP page of 20 January 2026, Romania is one of the eight Member States that submitted their draft on time. The plan was prepared by MDLPA with World Bank support and addresses the financial and administrative barriers to renovation. The assessment by the Joint Research Centre (JRC), announced on the Transition Pathways platform on 4 August 2026, analysed 16 drafts, including Romania's; its general conclusion is that the drafts provide "a solid basis" for the final plans, but that areas still to be strengthened include energy poverty alleviation, quantification of policy impacts, minimum standards for non-residential buildings and data on the state of renovation.

What we did not find in the official sources read: the text of the Romanian draft itself and a final version. The deadline for the latter remains 31 December 2026. Separately, on 30 October 2026 MDLPA opened the decision-making transparency procedure for a draft emergency ordinance amending Law 372/2005, with comments accepted for 30 days; it is a separate act from the plan, but it shows that the transposition of the EPBD is continuing, after the deadline of 29 May 2026.

What does it mean for an energy auditor?

You have no new obligation to fulfil under Article 3: the plan is addressed to the State, and the calculation and issuing rules for the certificate remain those of Mc 001-2022. The effects are indirect but practical:

1. The quality of CPE data matters at national scale. If the picture of the building stock is built on the certificate database, a CPE with the wrong climate zone, year of construction or area worsens the statistics on which the targets depend. 2. Minimum standards for non-residential buildings (Article 9(1)) are, according to the directive, verified on the basis of energy performance certificates or, where appropriate, other available means. Non-residential buildings must fall below the threshold that leaves the worst-performing 16 % of the stock above it from 2030, and below the one for 26 % from 2033; each State sets the exact values in kWh/(m²·year), and Romania had not published them in the sources read. 3. The recommendations in Annex 1 to the CPE are, at building level, what the plan describes at country level: which measures bring the building closer to zero emissions.

Example: what the CPE of a 1975 apartment shows

The M1 demonstration in Zephren is a 65 m² apartment in a large-panel block from 1975 in Constanța, without external insulation, energy class G, with a primary energy of around 610 kWh/m²·year, calculated under Mc 001-2022. It is exactly the type of building that a renovation roadmap puts at the top of its priorities: Article 3(5)(e) asks the Commission to check whether plans give priority to renovating the worst-performing buildings. For the auditor, the value of the CPE is not only the class but also the data behind it (geometry, envelope, systems), which feeds both the recommendations to the owner and, in aggregate, the picture of the building stock.

In short

• The national renovation plan is a State document (EPBD Article 3), with a roadmap for 2030, 2040 and 2050.
• Romania's draft was submitted by 31 December 2025; the final version is due by 31 December 2026.
• For auditors the impact is indirect: certificates feed the database on which the plan relies.

How a calculation program helps

The data of a CPE are entered once, and the program calculates primary energy, class and emissions and fills in the certificate model and annexes. Zephren has no official validation from MDLPA and does not replace the site survey or the responsibility of the certified auditor. You can run the flow on a building of your own in the Zephren calculation program, with the free trial. For the legislative context, see also the transposition of the EPBD in Romania.

*Verified on 3 November 2026, against the Romanian text of Directive (EU) 2024/1275 (Article 3 and Article 9(1)), the European Commission pages (BUILD UP, 20.01.2026; Transition Pathways platform, 04.08.2026) and the MDLPA page of 30.10.2026. This is not legal advice.*