EPBD transposition deadline: time to turn BACS requirements into practice

29 May 2026 marks the general transposition deadline for the recast Energy Performance of Buildings Directive (EPBD). For Building Automation and Control Systems (BACS), this is not only a legal milestone it is a practical implementation moment.

The revised EPBD, Directive (EU) 2024/1275, entered into force in 2024 and must now be transposed into national law by Member States. The Directive strengthens the role of technical building systems, digitalisation, building automation and indoor environmental quality in improving the performance of Europe’s building stock.

For eu.bac, the message is clear: transposition must go beyond copying EU text into national law. It must result in practical, enforceable and understandable requirements that can be applied by building owners, designers, installers, inspectors and public authorities.

Article 13: the key EPBD article for BACS

Article 13 of the recast EPBD sets requirements for technical building systems. Paragraphs 9 and 10 are particularly important for BACS in non-residential buildings.

Under Article 13(9), Member States must lay down requirements to ensure that, where technically and economically feasible, non-residential buildings are equipped with BACS:

• by 31 December 2024, for non-residential buildings with an effective rated output for relevant heating, air-conditioning, combined heating and ventilation, or combined air-conditioning and ventilation systems of over 290 kW;
• by 31 December 2029, for non-residential buildings with an effective rated output for those systems of over 70 kW.

This means Member States must not only set the obligation in law, but also clarify how building owners and authorities determine whether a building is in scope.

What BACS must be capable of

Article 13(10) defines the minimum capabilities required for BACS covered by Article 13(9). These systems must be capable of:

• continuously monitoring, logging, analysing and allowing for adjusting energy use;
• benchmarking the building’s energy efficiency, detecting losses in the efficiency of technical building systems, and informing the person responsible for the facilities or technical building management about opportunities for energy efficiency improvement;
• allowing communication with connected technical building systems and other appliances inside the building, and being interoperable with technical building systems across different types of proprietary technologies, devices and manufacturers;
• by 29 May 2026, monitoring of indoor environmental quality.

The final point, Article 13(10)(d), deserves particular attention. From the transposition deadline, BACS must also support the monitoring of Indoor Environmental Quality (IEQ).

Why capability (d) matters

The addition of IEQ monitoring is an important step forward. It recognises that building performance is not only about energy consumption, but also about the quality of the indoor environment experienced by occupants.

The EPBD defines indoor environmental quality with reference to conditions inside a building that influence the health and wellbeing of occupants, including parameters such as temperature, humidity, ventilation rate and the presence of contaminants.

This matters because smart and well-functioning buildings should deliver both energy efficiency and healthy, comfortable indoor spaces. BACS can help by providing the data and operational visibility needed to understand how buildings actually perform in use.

IEQ monitoring should therefore not be treated as a secondary or optional topic. It is part of the EPBD’s wider shift towards better building operation, digitalisation and measurable performance.

From legal obligation to practical compliance

The challenge for Member States is now implementation.

To be effective, national transposition should provide clear answers to practical questions, including:

• Which buildings are in scope?
• How should the effective rated output threshold be assessed?
• Which BACS capabilities must be demonstrated?
• What evidence should building owners provide?
• How will compliance be verified?
• How should IEQ monitoring be interpreted in practice?

Without clear implementation guidance, there is a risk of fragmented national approaches, uncertainty for building owners and uneven enforcement across Europe.

eu.bac therefore encourages Member States to adopt a practical, functionality-based approach to BACS compliance. The focus should be on whether the required capabilities are present, operational and verifiable, not on creating overly complex or product-specific requirements.

eu.bac tools to support Member States and stakeholders

To support practical implementation of the EPBD, eu.bac has developed guidance and tools for policymakers, authorities and market actors.

These include:

• eu.bac Guidelines for the Transposition of the recast EPBD
  Guidance for Member States on how to transpose and implement the BACS-related provisions of the Directive.
• BACS Compliance Verification Checklist
  A practical tool to help assess whether buildings in scope meet the BACS capabilities required under Article 13(9) and Article 13(10).
• BACS Self-Declaration Template
  A supporting document for building owners or technical experts to prepare the evidence needed for compliance verification.
• IEQ guidance documents 
  Joint documents developed through the Informal Indoor Environmental Quality Gathering, including a call for coherent and coordinated action on IEQ and technical guidance on best practices for enhancing IEQ in energy-efficient buildings.
• EPBD-relevant case studies
  Practical examples showing how BACS can support energy efficiency, better building operation and improved indoor environmental quality.

A constructive moment for implementation

The 29 May 2026 deadline should be seen as a moment to move from ambition to delivery.

BACS are a central part of making the EPBD work in practice. They help buildings monitor performance, detect inefficiencies, enable better control, support interoperability and now also monitor indoor environmental quality.

eu.bac stands ready to support Member States, authorities and stakeholders in ensuring that the BACS provisions of the EPBD are implemented in a clear, practical and effective way.

Other useful links

• Directive (EU) 2024/1275 — Energy Performance of Buildings Directive
  The legal text of the recast EPBD.
• European Commission guidance on technical building systems, indoor environmental quality and inspections
  Commission guidance covering Articles 13, 23 and 24 of the recast EPBD, including provisions relevant to BACS, IEQ and inspections.
• eu.bac and REHVA guide on EN ISO 52120-1
  A practical brochure explaining how EN ISO 52120-1 can support measurable building performance through building automation, controls and technical building management.