The EPBD solar obligation, and why your national deadline looks a year later
Article 10 of the recast EPBD sets seven dated solar deadlines between 2026 and 2030. Germany's schedule runs 2027 to 2031 and is the same obligation counted from the other end. Here is the EU floor, and where national law still decides.
The legal position for your buildings shifted in the spring of 2026 without much being said about it. Directive (EU) 2024/1275, the recast Energy Performance of Buildings Directive, had to be in national law by 29 May 2026. Its Article 10 carries a solar obligation with seven dated steps, and the first of them falls at the end of this year.
The schedule is in the directive, not in a forecast
What separates this from most summaries online is that nothing in it is estimated. Article 10(3) names the dates, and against each one it says which building is covered and above what useful floor area.
- By 31 December 2026: all new public and non-residential buildings with useful floor area larger than 250 m².
- By 31 December 2027: existing public buildings with useful floor area larger than 2 000 m².
- By 31 December 2027: existing non-residential buildings larger than 500 m², where the building undergoes a major renovation or an action that requires an administrative permit for building renovations, works on the roof, or the installation of a technical building system.
- By 31 December 2028: existing public buildings larger than 750 m².
- By 31 December 2029: all new residential buildings.
- By 31 December 2029: all new roofed car parks physically adjacent to buildings.
- By 31 December 2030: existing public buildings larger than 250 m².
Two things in that list get misread. Housing comes near the end, in 2029, so anyone building homes has more time at EU level than the headline suggests. And across the existing stock the order runs from large to small: 2 000, then 750, then 250 square metres, with public buildings going first at every step.
Why your national deadline looks a year later than the EU one
Germany transposed this in paragraph 106 of the Gebäudemodernisierungsgesetz, and its five steps begin on 1 January 2027, 2028, 2029, 2030 and 2031. Set next to Article 10 that reads like a year of slack. It is not. A German step that begins on 1 January 2028 and an EU deadline of 31 December 2027 are the same moment, described from opposite ends. All five line up that way, and the two EU items that share the 2027 deadline sit together in the German step that follows it.
That distinction earns its keep the moment you operate across borders. An overview citing 2031 and one citing 2030 are not contradicting each other, and neither of them is wrong. Before you treat a national date as stricter or looser than the directive, check whether you are reading a deadline or a start date.
The date is the easy part. The trigger is where it is decided
Article 10(3) applies the obligation only where a solar installation is technically suitable and economically and functionally feasible. Article 10(4) then hands Member States the work: they publish national criteria for how that is assessed in practice, and for exemptions by building type. The same paragraph lets a Member State measure ground floor area instead of useful floor area, provided it shows that this produces an equivalent amount of installed capacity.
So the thresholds are fixed at EU level and the test is not. Germany's trigger for existing non-residential buildings, to take the one case I have checked, is tied to specific renovation provisions rather than to the directive's broader wording about roof works and permits. The directive gives you the date and the square metres; your national criteria give you the answer for a particular building.
Two other dates on the same clock
Article 7 requires new buildings owned by public bodies to be zero-emission buildings from 1 January 2028, and all new buildings from 1 January 2030. Article 9(1) adds minimum energy performance standards for non-residential stock: every Member State sets a threshold such that 16 per cent of its national non-residential stock sits above it, and a second threshold at 26 per cent, both measured against the stock as it stood on 1 January 2020. All non-residential buildings must be below the 16 per cent threshold from 2030, and below the 26 per cent threshold from 2033.
What I am not claiming here
This is not legal advice, and one directive read closely is not twenty-seven transpositions checked. I have verified a single Member State's schedule against Article 10, Germany's, because that is the cluster this site already maintains. The exemption criteria under Article 10(4) are national, published separately, and are where most individual buildings are in fact decided. And every date above is a floor: Article 10 does not stop a Member State, or a region inside one, from asking for more.