Energy rules for commercial property

The Éco Énergie Tertiaire framework applies to buildings, parts of buildings and property complexes with at least 1,000 m² of tertiary activities. Owners and tenants share responsibility according to their lease. Final energy use must fall by 40% by 2030, 50% by 2040 and 60% by 2050, relative to a 2010–2019 reference year; an absolute target by activity is another route. Annual consumption is reported on ADEME’s OPERAT platform.

ADEME’s report published on 26 May 2026 counted approximately 340,000 reporting entities, with estimated coverage of 50–60% of the relevant stock. Climate-adjusted final consumption was 26% lower in 2024 than in the 2010–2019 reference period. Reliable declarations indicate that 51% of reporting entities had reached their 2030 target. These data help put each asset’s trajectory in context.

Since 1 July 2026, the annual digital certificate showing the Éco Énergie Tertiaire rating must be accessible in the building and attached to new leases and sale deeds. For a disposal or letting, identify whether the asset is in scope, review its reporting history and explain any gaps in the data.

The threshold now depends on the legal entity’s average annual final energy use over the previous three calendar years. At 2.75 GWh per year or above, a regulatory audit is required every four years unless an energy management system is in place; the first audit is due by 11 October 2026. At 23.6 GWh per year or above, a certified energy management system is due by 11 October 2027.

Building automation and control systems are relevant to tertiary buildings with heating or cooling installations above 70 kW, subject to statutory conditions and exemptions. The requirement has applied to existing buildings above 290 kW since 1 January 2025. For 70–290 kW installations, the deadline has moved from 2027 to 1 January 2030.

Energy rules do not cause a uniform discount on less efficient assets. Value depends on location, use, tenancy, works costs, adaptability and market demand. A valuation should set out regulatory position, future expenditure, potential vacancy or liquidity risk and how those factors enter market and rental value.

Review 2025 OPERAT declarations and certificates in 2026, map energy trajectories and capital expenditure in 2026–2027, plan works and monitor actual performance in 2027–2029, then document the 2030 energy target and the BACS position.

ARBITRAGE examines energy data alongside the asset’s market, use, tenants, works and liquidity. A property or portfolio review can help identify which assets to retain, improve, restructure or sell.