29 May 2026 was the deadline for the transposition into Spanish legislation of the new Directive (EU) 2024/1275 on the Energy Performance of Buildings (EPBD), approved by the European Commission in April 2024. It is one of the key pieces of the Fit for 55 package, the set of European measures to cut emissions by 55% by 2030 and achieve climate neutrality by 2050. The new EPBD replaces Directive 2010/31/EU and represents, according to the sector, the most far-reaching technical transformation of the Spanish building stock since the post-war years.
Unlike other regulations, the EPBD does not set only distant targets: it defines a progressive timetable with specific dates that already affect developers, industry, the tertiary sector and public administrations. In Spain, transposition is implemented through the amendment of the Código Técnico de la Edificación (CTE, the Spanish Technical Building Code) and of Royal Decree 390/2021 on energy performance certification. Below we analyse the five key dates that no player in the sector can ignore.
1. 31 December 2026: mandatory solar in new tertiary and public buildings
From that date, all new tertiary-use or public buildings with more than 250 m² of usable floor area will have to include solar photovoltaic installations. The measure directly affects industry (units of more than 250 m²), the logistics sector, large-format retail, hotels and any newly built public facility. For developers with projects at the drafting stage, it is essential to incorporate solar design from the basic engineering stage, not as a final add-on.
2. 29 May 2026: new European energy performance certification
The date has already arrived. Member States were required to have adapted their certification system to the new harmonised European scale, which redefines class “A”: it is now reserved exclusively for zero-emission buildings, and two new categories are added: “A0” (zero emissions) and “A+” (energy demand 20% below the ZEB threshold). For owners of buildings with a current certificate, this means that “their A” is no longer the same European “A”. The practical consequence is immediate for sale, rental and green financing transactions.
3. 2028: new zero-emission public buildings
This is the first major qualitative leap. All new buildings owned by public bodies will have to be zero-emission buildings (ZEB), that is, with very high energy performance, almost zero demand, zero on-site emissions from fossil fuels and very low operational GHG emissions. The date means that public building projects in the 2026-2027 budget planning phase must already incorporate ZEB criteria from the preliminary design stage. Failing to do so may create regulatory incompatibilities when going to tender.
4. 2030: all new buildings at zero emissions + 22% residential renovation
The ZEB obligation is extended to all new buildings, public and private, residential and tertiary. In parallel, 22% of the least efficient existing residential buildings will have to be energy-renovated relative to the 2020 stock. Bearing in mind that, according to sector estimates, between 80% and 90% of Spanish residential buildings are in energy class E or below, the scale of the challenge is clear: we are talking about hundreds of thousands of deep renovation works in less than four years.
5. 2040: complete phase-out of fossil fuel boilers
This is the final date of a transition that has already begun. Since 1 January 2025, public subsidies for the installation of fossil fuel boilers have not been allowed. Each Member State must draw up a national phase-out plan, ensuring that public investment is directed exclusively to clean technologies such as air-source heat pumps, geothermal energy or connection to renewable district heating networks.
What to do now: three actionable recommendations
Experience tells us that regulatory changes of this magnitude reward those who move early. Faced with this timetable, we recommend three immediate actions for industry, developers and administrations:
Energy audit of your own building stock. Identify the current energy class, the gap with respect to the new ZEB thresholds and prioritise actions. A company with several production sites or a town council with ten public facilities needs a regulatory risk map before budgeting anything.
Phased investment plan aligned with the EPBD timetable. Actions must be ordered according to mandatory dates (2028, 2030) and cost-benefit criteria. European funds NextGenerationEU and the state and regional renovation programmes are still accessible, but the access period is closing.
Get ahead of the CTE amendment. The Código Técnico de la Edificación is being revised to incorporate the ZEB requirements. Projects drafted under the current CTE may become technically obsolete within a few months. For developers with a 2026-2028 pipeline, it is critical to design to ZEB criteria now, even if they are not yet mandatory.
At auma auma we support developers, industrial companies and administrations in this type of audit, planning and technical design. The transposition of the EPBD is no longer an abstract European debate: it is the new operating framework for the Spanish building sector for the next fifteen years. Moving early is, right now, the most profitable decision any building owner or manager can make.