ESG & Stewardship
EPBD in Italy: What the Missed Deadline Means
Italy did not transpose the recast Energy Performance of Buildings Directive by 29 May 2026, and on 15 July 2026 the Commission opened procedures against all 27 Member States. For a Lake Como villa under renovation, the directive's dates are fixed and its national numbers are not. This article separates what the text and the Commission have set from what Italy has still to write.
IllustrationKey takeaways
- - On 15 July 2026 the Commission sent letters of formal notice to all 27 Member States for incomplete transposition of Directive (EU) 2024/1275, which was due on 29 May 2026 (European Commission, 15 July 2026).
- - Italy is also in procedure INFR(2026)2024, opened on 11 March 2026 with 18 other states for not submitting the draft national building renovation plan due 31 December 2025, and on 1 October 2026 it received a reasoned opinion in that procedure (European Commission, March and October 2026 packages).
- - The final national building renovation plans are due on 31 December 2026, a date for the State and not for the owner (European Commission, EPBD page).
- - The residential target is a stock-wide average cut in primary energy use of 16% by 2030 and 20-22% by 2035 against 2020, not a per-villa mandate (European Commission EPBD page; Matheson summary).
- - Member States may exempt historical buildings and holiday homes, but no Italian exemption was found in the sources read, so the Lake Como position is undefined (European Commission, EPBD page).
- - Trade press reports no EPBD delegation in Italy's 2025 European delegation law, no transposition decree as of May 2026, and the passport and A to G scale still to be introduced (Ingenio, Infobuildenergia; secondary).
- - ENEA-CTI data as reported by press put 45.3% of residential certificates issued in 2024 in classes F and G, a certificate sample and not the whole stock (ENEA-CTI via MeteoWeb, 2025).
- - No Lake Como energy-class breakdown, price effect or cost figure was found, and this article is a description of the norm, not legal advice.
On this page (12)
What did the Commission do about the EPBD on 15 July 2026?
Italy did not transpose the recast Energy Performance of Buildings Directive by 29 May 2026, and no other Member State did so in full. On 15 July 2026 the European Commission sent letters of formal notice to all 27 Member States for not fully notifying national transposition of Directive (EU) 2024/1275. Italy is one of the 27. For a principal who holds or renovates a villa on Lake Como, the date is a fact about the rulebook, not about the building.
The EPBD is the EU framework that governs how buildings are classified, renovated and built. Energy Performance of Buildings Directive (EPBD) is the shorthand for Directive (EU) 2024/1275, the recast adopted in 2024. A directive binds a Member State to a result. It does not bind an owner directly. Obligations reach a Lake Como villa only through Italian law, written by Italian legislators and applied by Italian authorities.
The Commission's notice starts a short clock. Member States have two months from the letters to respond, complete transposition and notify the Commission. For the July letters that period ended in September 2026. If the answers are unsatisfactory, the Commission may issue a reasoned opinion. A referral to the Court of Justice, and financial penalties, are later steps in the same ladder. None of these steps is a verdict on any building.
One provision ran earlier than the rest. Article 17(15), on financial incentives for new stand-alone fossil-fuel boilers, had to be transposed by 1 January 2025. The Commission lists that date apart from the general 29 May 2026 deadline. Ingenio reports that Italy already faced a procedure on that point before July. The allocator should read the July letter as a second layer, not the first.
What is a national building renovation plan, and where does Italy stand?
A national building renovation plan is the Member State's own roadmap for its whole building stock, and Italy has not yet submitted its draft. In its March 2026 infringement package the Commission calls these plans an essential and strategic tool for turning the national stock into an energy-efficient, decarbonised asset by 2050. The Commission adds that the plans should create predictable renovation pipelines and clear long-term trajectories.
The plan carries two dates. Draft plans were due on 31 December 2025. Final plans are due on 31 December 2026. Both dates sit on the Commission's EPBD page. As of 23 October 2026 the second date is still ahead. It is a deadline for the State, not for the owner of a villa.
Italy missed the first date. On 11 March 2026 the Commission sent letters of formal notice to 19 Member States for not submitting the draft plan. Italy is among them, under procedure INFR(2026)2024. On 1 October 2026 the Commission sent a reasoned opinion in the same procedure to Italy and eight other Member States, stating that they had still not submitted their draft plans. Ingenio, writing in May 2026, reported that no plan had been delivered.
The consequence is one of sequencing. The plan is where a Member State sets its residential trajectory and its financing. The sources read for this article report no published Italian draft. Until a plan is published, the national yardstick for the residential stock does not exist.
What does the EPBD ask of a residential building such as a Lake Como villa?
The directive sets a stock-wide trajectory for homes, not a mandate for each villa. Member States must cut average primary energy use of the residential stock by 16% by 2030 and by 20-22% by 2035, against a 2020 baseline. The Commission's EPBD page gives the percentages, and Matheson's summary of the directive gives the 2020 baseline. The target is an average across the national stock. An individual villa is not assigned a number by the directive.
The effort is steered toward the weakest buildings. Matheson summarises that at least 55% of the decrease must come from renovating the 43% worst-performing residential buildings. That is again a stock-level allocation. It shows where national policy is meant to push first. This is Victaura Research's reading, not a rule: a villa in a low energy class sits closer to that push than one already renovated.
The residential obligation is framed as a national trajectory. The Commission's description of the directive speaks of renovation trajectories for residential buildings and of minimum energy performance standards for non-residential ones. How Italy meets the residential trajectory, through standards, incentives or both, is Italy's choice. Until it chooses, any renovation date quoted to the private owner of an existing home is a guess.
Non-residential rules should not be imported by analogy. ESG Today reports national targets to renovate the 16% worst-performing non-residential buildings by 2030 and the 26% worst-performing by 2033. A villa operated commercially may fall into a different category from a private home. Classification is a national and case-specific legal question, and this article does not answer it.
What is a zero-emission building, and does the standard reach a renovation?
*A zero-emission building is a building with very low energy demand, no on-site carbon emissions from fossil fuels and zero or very low operational greenhouse gas emissions.* That is the summary used by Matheson. The binding wording sits in the directive text on EUR-Lex, which the principal's counsel should read directly. This article does not reproduce it.
The standard bites on new buildings first. On the summaries read, new public buildings must be zero-emission by 2028 and all other new buildings by 2030. A renovated existing villa is not a new building. A demolition and rebuild may raise a different question. For who builds new on the lake, see Lake Como Developers: Who Builds New.
The long-run direction is a zero-emission stock by 2050. The Commission frames the directive as a route to a decarbonised building stock by 2050. ESG Today reports a goal of phasing out fossil-fuel boilers by 2040. For a lakeside villa heated by oil or gas, the boiler is where the abstract target meets the property. The incentive ban on new fossil boilers already has a date, 1 January 2025.
A renovation scope can be read in three layers. The split into envelope, heating system and on-site generation is a Victaura Research assumption. The Commission's description of the directive covers renovation of the worst-performing buildings, the phase-out of fossil-fuel boilers and solar installations, the last mainly on new buildings and certain non-residential ones. Italy has not yet spoken to any of them in transposed form. A principal reading a scope should keep the three layers separate.
A directive is a promise between the Union and the State. It reaches a villa only when the State writes it down.
Victaura Research
What is a renovation passport, and is it available in Italy?
*A building renovation passport is a document that sets out a multi-step plan for an owner who renovates in stages.* The Commission's EPBD page describes it in those terms. It is a planning instrument, and trade press reports that Italy has not yet introduced it. It is not a permit, and it does not by itself change an energy class.
Staged renovation is the relevant case for a villa. A lakeside property often cannot be closed for a full works programme in one go. A passport is designed for the owner who sequences the envelope, the heating and the generation over several phases. That fit is Victaura Research's reading of the Commission's description.
Italy has not introduced the passport. Ingenio's May 2026 comparison of Italy, Germany, Austria and Spain lists the renovation passport as still to be introduced in Italy. The source is trade press, not the Gazzetta Ufficiale, and the principal should reconfirm it in the Gazzetta Ufficiale before relying on it.
The certificate scale is the second open item. Ingenio reports that the ministerial decree on minimum requirements of 28 October 2025, effective 3 June 2026, updates calculation methods. It does not introduce the EU A to G scale and does not count as EPBD transposition. Any energy class held today comes from the current Italian system. How it maps to a future EU scale is undefined.
Will historic and holiday villas on Lake Como be exempt from the EPBD?
The directive allows exemptions, but Italy has not yet written them. The Commission's EPBD page states that Member States may exempt categories of buildings from renovation requirements, including historical buildings and holiday homes. The word is may. An exemption exists for a villa only if Italy adopts it, and on the terms Italy chooses.
The category definitions are national. What counts as a historical building, and what counts as a holiday home, will be set in Italian law. Which part of the Lake Como stock falls inside those lines is a property-level legal question. This article classifies no villa and gives no legal advice.
An exemption does not switch off the market's reading of an energy class. A building exempt from the trajectory's obligations is still compared with others by buyers and lenders. Whether a low class is discounted on Lake Como is an empirical question. Victaura Research holds no measured data on it and does not assert an effect.
The holiday-home exemption matters because of who owns on the lake. Second homes and foreign ownership shape much of the market. For the shares, see Lake Como Buyers: Reading the Shares. If Italy defines holiday homes narrowly, more of that stock stays inside the regime. If broadly, less does. Neither outcome is written.
What has Italy actually done on the EPBD?
Italy's 2025 European delegation law did not include the EPBD. Infobuildenergia reports that the bill approved by the Council of Ministers on 22 July 2025 enabled transposition of two directives and implementation of ten regulations, with no reference to the EPBD. Ingenio identifies the Chamber bill as AC 2574 and reports that amendments to add the delegation were rejected in both chambers. These are trade-press reports of parliamentary acts.
No transposition decree was reported as of May 2026. Ingenio states that Italy had no formal transposition decree days before the 29 May 2026 deadline. I found no source reporting one since. That is absence of evidence, not proof of absence. The Gazzetta Ufficiale is the place to confirm the current position.
Several Commission steps now touch Italy. On the sources read, Italy faced a procedure on the boiler-incentive provision in late 2025, the March 2026 procedure on the draft plan, which reached a reasoned opinion on 1 October 2026, and the general July 2026 letter. On the same 1 October 2026 the Commission also sent Italy a reasoned opinion on the recast Energy Efficiency Directive, a separate directive. The EPBD file is one of several.
The government has argued for flexibility. Infobuildenergia reports that the government has repeatedly described the targets for existing homes as unattainable at present and has asked for more flexibility. It is a report of a position, not of a text. It tells the allocator that the content of Italian transposition is still being negotiated, and that its scope may differ from what the directive's headline numbers suggest.
| Date | Milestone | Reported position for Italy |
|---|---|---|
| 1 January 2025 | Article 17(15), end of incentives for new stand-alone fossil-fuel boilers | Procedure reported in late 2025 (trade press) |
| 31 December 2025 | Draft national building renovation plan due | Not submitted per Commission letter of 11 March 2026 and reasoned opinion of 1 October 2026 (INFR(2026)2024) |
| 29 May 2026 | General transposition deadline | No transposition decree reported as of May 2026 (trade press) |
| 15 July 2026 | Letters of formal notice to all 27 Member States | Italy included |
| 31 December 2026 | Final national building renovation plan due | Pending |
| 2028 | New public buildings zero-emission (summary of the directive) | No Italian transposition reported |
| 2030 | Residential stock average primary energy use down 16%; other new buildings zero-emission | National trajectory not published |
| 2035 | Residential stock average primary energy use down 20-22% | National trajectory not published |
What remains undefined for a Lake Como villa until Italy transposes?
Five things remain open, and each affects how a renovation scope is written. They are the national residential trajectory, the energy class scale, the renovation passport, the exemptions, and the financing that will back the work. The directive fixes EU-level targets and dates. It leaves these five to Italy.
The trajectory is the first gap. With no draft national plan in the sources read, the Italian route to 16% by 2030 and 20-22% by 2035 is not public. The route decides whether pressure falls on standards for individual owners, on incentives, or on both. A principal cannot price a compliance cost that has not been defined.
The class scale and the passport are the second and third gaps. The EU A to G scale and the passport are both reported as not yet introduced. A renovation designed today targets a class under the current Italian system. Whether that class converts cleanly later is unknown. Exemptions are the fourth gap, and they turn on definitions of historic and holiday homes.
Financing is the fifth gap. The Commission's EPBD page says financing under the directive is more targeted, with a focus on vulnerable households. Italy's incentive architecture is a national matter. Ingenio describes the current Italian incentive system as partial. For how Victaura Research treats certification against practice, see ESG in Luxury Real Estate: Philosophy, Not Certificate.
The dates are fixed. The numbers an owner would act on are not.
Victaura Research
How weak is the Italian building stock the EPBD is aimed at?
The ENEA-CTI report on 2024 certificates puts 45.3% of residential certificates in classes F and G. MeteoWeb's coverage of the sixth annual report states that more than 1.2 million certificates issued in 2024 were analysed and that the most efficient classes, A4 to B, reached 20% of the residential total. LavoriPubblici reports that residential buildings were 88.7% of them. The figures are ENEA's, reported through trade and local press. I could not open the PDF.
The direction of the series is improvement. MeteoWeb reported in October 2024 that the F and G share fell below 50% for the first time in the 2023 data. The 2024 figure continues that fall. The series says the Italian stock is moving. It does not say it is moving fast enough for a 2030 target no one has yet written into Italian law.
A certificate sample is not a census of the stock. Certificates are issued when events occur, such as a sale, a lease or works. The sample over-represents buildings in transactions. It does not describe every villa on the lake. The 45.3% is a national residential figure with that caveat attached, and it is an indicator of the starting point, not a forecast of the outcome.
No Lake Como figure was found. I did not locate a Lake Como or Como province breakdown of energy classes from ENEA or another institution. A principal wanting one should ask for the property's own energy performance certificate, the Attestato di Prestazione Energetica (APE). For how official data is read on the lake, see Lake Como Prices: What the Official Data Shows.
What does an EU infringement procedure mean for an owner in practice?
A letter of formal notice is the first step of a ladder, not a ruling. The Commission asks the Member State to respond within two months and to complete notification. If the reply is unsatisfactory, a reasoned opinion may follow. A referral to the Court of Justice may come after that, and for some cases a request for financial penalties.
The procedure acts on the State, not on the owner. An infringement letter creates no duty for a villa owner and removes none. The owner's position changes only when Italian law changes. The procedure raises the political cost of delay for Rome. It does not set a date for the content of the law.
The ladder gives no schedule I can measure. Each step depends on the Member State's reply and the Commission's assessment. I make no estimate of when Italy will transpose. Two markers lie ahead: the two-month reply period on the reasoned opinion of 1 October 2026 on the draft plan, and 31 December 2026, the date for the final national building renovation plan. Both are dates for the State.
The Commission has already taken Italy to the second step on two adjacent files. On 1 October 2026 it sent Italy reasoned opinions for continued failure to submit the draft national building renovation plan and for incomplete transposition of the recast Energy Efficiency Directive, a separate directive. Eunews reported the same decisions. This is context, not a prediction for the EPBD transposition case opened in July.
A letter of formal notice is a first step. It is not a verdict, and it is not a building rule.
Victaura Research
Weak points of this reading, honestly disclosed
I could not open the directive's full text. The EUR-Lex page did not load in the research tool. The directive-level numbers here come from the Commission's own EPBD page and from summaries by Matheson and ESG Today. Article numbers are cited only where the Commission page gives them, namely Article 17(15). Counsel should check every figure against the Official Journal text.
The Italian position rests on trade press. Ingenio, Infobuildenergia and Eunews are not the Gazzetta Ufficiale or the parliamentary record. Their reports agree with each other, but they are secondary. They are dated July 2025 to October 2026, and a decree could have been adopted since. That would change the table above.
Reports differ in small ways. One outlet dates the July notices to 17 July. The Commission's own page is dated 15 July 2026, and this article uses that date. On the draft-plan case, this article relies on the Commission's own pages for both the March 2026 letter and the reasoned opinion of 1 October 2026.
There is no Lake Como evidence on value or on cost. I found no measured data on how energy class affects Lake Como prices, or on renovation cost for lakeside villas. The 45.3% is national. This article describes a norm and its gaps. It is not legal advice, and it does not assess any specific property.
How should the allocator read the missed deadline for Lake Como?
The missed deadline is a fact about Italian legislation, not about a villa's value. The directive's dates are set, and the Commission has acted against all 27 Member States. What Italy writes into law for homes, historic buildings and holiday stock is not yet known. The allocator should hold the two layers apart and avoid pricing the second as if it were the first.
The sensible response is documentation, not prediction. A renovation scope can record the current energy class, the heating source, the envelope condition and the generation on site. These facts will be needed under almost any Italian version of the rules. That is a statement about records, not a recommendation to renovate or to wait.
Three markers deserve a watch. The first is any Italian transposition decree or delegation law. The second is the draft national building renovation plan, and then the final plan due on 31 December 2026. The third is the Italian definition of historic and holiday buildings. Each is checkable in an official source: the Gazzetta Ufficiale for Italian acts, and the Commission's infringement decisions for the plan.
Skin in the game disclosure. Victaura, through its parent Greystone B.V. (Netherlands), develops projects on Lake Como (Italy), in Nungwi, Zanzibar (Tanzania), on Gili Air and in Uluwatu, Bali (Indonesia), and holds an off-plan capital position on Al Marjan Island, Ras Al Khaimah (UAE). Readers should assume commentary may be influenced by, or benefit, these positions. This document is classified as marketing material under MiFID II Article 24(3). It is not investment advice.
References
- European Commission, Commission calls on EU countries to transpose the reinforced rules on energy performance of buildings, 15 July 2026
- European Commission, March infringements package: key decisions in energy, 11 March 2026
- European Commission, Energy Performance of Buildings Directive
- European Union, Directive (EU) 2024/1275 on the energy performance of buildings (recast), Official Journal 2024
- eceee, The Commission calls on EU countries to transpose the reinforced rules on the energy performance of buildings, July 2026
- ESG Today, EU Commission Launches Legal Action Against All 27 Member States for Failing to Implement Zero Emission Building Law, July 2026
- Eunews, Italy still facing EU infringement over energy efficiency and building renovations, 1 October 2026
- Infobuildenergia, Direttiva EPBD, la Commissione mette sotto infrazione tutti i 27 Stati membri, July 2026
- Infobuildenergia, Legge di delegazione europea 2025, le associazioni denunciano l'assenza della direttiva sugli edifici
- LavoriPubblici, Efficienza energetica edifici 2025: presentato il nuovo Rapporto ENEA-CTI, 27 October 2025
- Ingenio, Recepimento direttiva Case Green: facciamo il punto, Italia, Germania, Austria e Spagna a confronto, May 2026
- Matheson, Energy Performance of Buildings Directive (recast) now in force, 17 June 2024
- ENEA e CTI, Rapporto annuale sulla certificazione energetica degli edifici 2025, as reported by MeteoWeb, October 2025
- MeteoWeb, Certificazione edifici 2023, le classi meno efficienti sotto il 50% per la prima volta, 10 October 2024
- European Commission, October infringements package: key decisions in energy, 1 October 2026
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