Since Jan. 1, 2025, a new requirement applies to owners and holders of property rights, such as leaseholders or superficies, of large non-residential buildings. An EPC non-residential (EPC NR) is required for buildings with a usable floor area of more than 1,000 m².
What exactly does this obligation entail and to whom does it apply? The most important aspects at a glance.
To whom does this obligation apply?
The requirement applies to all owners and business right-holders, regardless of whether the building is rented or sold. Mere ownership of a non-residential building with a usable area greater than 1,000 sq. ft. is sufficient to be required to have a valid EPC NR.
Important: When selling or leasing a non-residential building, an EPC NR is always required, even if the usable floor area is less than 1,000 square meters.
Which buildings does this rule apply to?
The EPC NR is only required for non-residential buildings, meaning:
- The building must not have a residential use, such as a home.
- The building does not fall under the exclusion category, such as industrial buildings (workshops, warehouses or production halls) or buildings on a farm.
Examples of non-residential buildings covered by the requirement:
- Offices
- Stores
- Service Centers
How is usable floor area calculated?
Usable floor area is calculated per functional building unit with its own lockable access. Separate rooms connected by a connecting door and functioning as one unit are considered one building unit.
What in mixed use?
Some buildings combine industrial functions with non-residential or residential uses. In that case, it must be determined whether the industrial space is included or excluded in the calculation of usable floor area.
Industrial space is not counted if:
- The non-residential and/or residential spaces combined exceed 250 sq. m.
- The industrial space is larger than these other spaces.
If industrial space is not excluded, then the main use of the building is considered:
- If the industrial function occupies more than 70 percent of the building, there is no EPC NR requirement.
- If the non-residential use occupies the largest area and the building is larger than 1,000 square meters, an EPC NR is required.
In a mix of residential and non-residential uses, the largest area is considered the principal use.
Practical examples
1. Workshop (800 m²) + office space (300 m²) without connecting door
- The workshop and office space are considered separate entities.
- The workshop is excluded and has no EPC requirement.
- Office space is non-residential, but with an area less than 1,000 sq. ft. Thus, no EPC NR is required, unless for sale or lease.
2. Workshop (800 m²) + office space (300 m²) with connecting door
- Are considered one building unit.
- The workshop is excluded if the office space exceeds 250 sq. m.
- Because the total usable floor area of the non-residential portion is less than 1,000 sq. ft., no EPC NR requirement applies unless when sold or leased.
3. Workshop (900 m²) + office space (200 m²) with connecting door
- Are considered one building unit.
- The workshop is not excluded because the office space is less than 250 sq. m.
- If the workspace occupies 70 percent or more of the total usable floor area, the zoning is considered industrial and no EPC NR requirement applies.
Conclusion
The new EPC NR requirement brings several practical nuances. Owners and business right-holders of non-residential buildings larger than 1,000 sq. ft. must take this into account. For sales or rentals, an EPC NR is always mandatory, regardless of area.
When in doubt, it is recommended to consult an energy expert.