The requirements of the Energy Performance of Buildings Directive (EPBD) must be included in the legislation of every EU member state as of May 29. However, none of the dozen or so changes to laws and regulations announced by the Ministry of the Environment will be completed by the deadline.
Finland is not the only EU member state that is behind schedule, but many countries will probably get everything in order on schedule. Some have been delighted that it is no longer possible to say that Finland is always the EU's model student.
There are several reasons for Finland's delay, not least the Ministry of the Environment's very limited resources to promote a broad legislative package. All the more reason to have utilized construction industry actors in the preparation. We were ready for this, the starting gun just never sounded.
In early summer 2025, the statement contained perhaps the most important regulations from a practical perspective, namely energy efficiency requirements for new and renovated construction and new energy form factors. During last winter, they took shape somewhat and we can be quite satisfied with the end result.
The tightening of energy efficiency is taking place more or less in line with the minimum guidelines of the directive, although in our opinion it is not material and technology neutral. When the tightening was made to the equalization calculation of heat losses, not all building services can be taken into account in the calculation. This particularly affects solid exterior walls.
In terms of renovation construction, the requirements for windows and doors were brought to a relatively reasonable level, although the requirements are stricter than the ten percent minimum requirement required by the directive.
Emission-free heating does not justify a reduction in energy efficiency
In terms of energy form factors, there was a threat right down to the chalk lines that using emission-free and renewable district heating could have resulted in a building with even lower energy efficiency than current regulations. Fortunately, this did not happen. The lower coefficient for district heating can be used to prepare a separate energy certificate, but not to demonstrate compliance with regulations. It is good that buildings must still be energy efficient regardless of the heating method used in the building.
However, the heating method and its emissions play a key role in the revised Energy Performance of Buildings Directive. According to the directive, new buildings are ZEBs (Zero Emission Buildings) and the entire building stock would be largely emission-free by 2050.
By definition, a zero-emission building has very low energy consumption and zero or negative carbon dioxide emissions during operation. Otherwise, it does not take a position on the building's carbon footprint.
The Ministry of the Environment still has a lot of work ahead of it to complete the remaining legislative amendments. It looks like next autumn, the Parliament will be discussing legislation regarding energy certificates, solar energy, electric car charging points, home automation, compulsory repairs and much more.
We have already made a preliminary proposal for the timing of the entry into force of the new legislation in a way that would cause as little confusion as possible. We hope that the renovation regulations, new energy efficiency coefficients and new energy certificates will enter into force at the beginning of 2028.
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Jani Kemppainen
Manager, Technical Regulations and Legislation and Quality
jani.kemppainen@rt.fi +358 40 541 8090Building Construction Industry Association
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