Non-residential assets – Minimum EPC label E as from 2030 in Flanders – Considerations for investors and users
As from 1 January 2030, every non-residential building in Flanders with a usable floor area of at least 1,000 m² will be required to have an EPC label of at least E. For investors and users of non-residential real estate, this means that the EPC label will no longer be merely a technical or informational metric but a factor that directly impacts property valuation, as well as its saleability and lettability. This obligation will apply to a wide range of assets, including offices, hotels, retail properties and nursing homes. Industrial real estate, such as warehouses and logistics buildings, will under current proposals be exempt from this minimum requirement.
Looking ahead to 2030, many buildings will need to undergo a thorough assessment, in terms of both their current EPC rating and the feasibility, timing and cost of the measures required to achieve a minimum label E. In practice, this often involves a combination of interventions relating to the building envelope (insulation and glazing) and technical installations (heating, electricity and ventilation), with a direct impact on energy consumption. A delayed approach may result in capital expenditure projects being carried out under time pressure, potentially increasing costs and negatively affecting the operation and marketability of the property.
Investors are therefore advised to structurally integrate the EPC position from the outset, particularly as part of due diligence and price negotiations. Existing lease agreements should be reassessed in light of this obligation, especially with regard to the allocation of responsibility for any required energy-related works between landlord and tenant. For new leases, in order to minimise legal uncertainty, it is advisable to anticipate future interventions and to include clear commitments in this respect.
In this context, tools such as the CRREM (Carbon Risk Real Estate Monitor) Pathways can provide valuable support for investors seeking to integrate these objectives into the management and renovation of their assets.