Wednesday, 26 November 2025
EPC Ratings in Europe: Inconsistencies Undermine Comparability, Savills Finds The Energy Performance Certificate (EPC) system, used across Europe and the UK to assess building energy efficiency, lacks standardisation, according to research from Savills’ Impacts programme. This fragmentation is creating serious challenges for investors and occupiers, particularly those operating across borders. EPC Ratings Vary Widely Even […]
The Energy Performance Certificate (EPC) system, used across Europe and the UK to assess building energy efficiency, lacks standardisation, according to research from Savills’ Impacts programme. This fragmentation is creating serious challenges for investors and occupiers, particularly those operating across borders.
Savills found that the same building could receive EPC ratings up to four grades apart, depending on the country. Even within individual countries, regional discrepancies distort comparability. For example, in Belgium, a building with a specific energy performance measured in kWh/m²/year could earn a ‘C’ rating in Flanders but just a ‘D’ or even an ‘F’ in Brussels, due to the stricter thresholds applied in the Brussels-Capital Region.
Likewise, the standards for what qualifies as an ‘A’-rated office building vary across Europe. A building that receives an ‘A’ rating in one country might be classified as a ‘D’ or ‘E’ elsewhere, even if its energy performance remains unchanged.
Chris Cummings, Director at Savills Earth, stated:
“If even within the same bloc there’s disparities, how can [investors and tenants] compare across wider geographies such as APAC or the US?”
He warned that relying solely on headline EPC grades risks misinterpreting the actual performance of a building. “[Investors and occupiers] run the risk of excluding buildings which have received a lower rating in countries which exert a ‘tougher’ EPC regime, as they do not fulfil their sustainability objectives, only to go on to take a building in another country which has a higher grade, but ultimately is a poorer performer.”
The inconsistency complicates cross-border due diligence and sustainability strategies, making it harder to assess what qualifies as a truly green or efficient asset. This poses particular difficulties for those looking to meet internal sustainability targets or align with international ESG standards.
‘City-level differences in sustainability standards can again present distinct challenges and opportunities for occupiers and investors,’ said Sarah Brooks, Associate Director at Savills World Research. She advised that success increasingly depends on understanding local policies, incentive structures, and climate risks at the city level, not just national averages.
The European Union is working to update its Energy Performance of Buildings Directive (EPBD), which aims to reduce variation among member states. However, Savills notes that discrepancies are likely to persist, given the wide range of political sensitivities, technical constraints, climate conditions, and existing building stock across regions.
While much of the conversation around EPC discrepancies focuses on continental Europe and the UK, Ireland has its own unique challenges. The country uses Building Energy Ratings (BERs), similar in concept to EPCs, for commercial and residential properties. However, variations in enforcement, data transparency, and assessment methodologies have led to growing calls for reform.
According to industry experts, older commercial buildings in Ireland often fall short of energy efficiency targets due to legacy issues in design and insulation. The government’s Climate Action Plan outlines intentions to upgrade energy performance standards, but critics argue that the pace of implementation remains slow, particularly in the private sector.
While EPCs and BERs focus primarily on operational energy use, another critical, but often overlooked, component of building sustainability is embodied carbon: the emissions produced during the manufacture, transport, construction, and end-of-life phases of building materials.
In Ireland, where construction is booming to meet housing and commercial demand, embodied emissions are rising, yet they remain largely unaccounted for in energy performance ratings. Experts suggest that future policy must go beyond EPCs to include whole-life carbon assessments, which are already gaining traction in countries like France and the Netherlands.
To address poor energy performance in existing buildings, the Irish government has launched various retrofit grant schemes, including those operated by the Sustainable Energy Authority of Ireland (SEAI). While these have focused heavily on residential properties, commercial retrofits remain underfunded and underprioritised.
Expanding incentives for deep commercial retrofits could provide a major boost to energy efficiency goals, reduce Ireland’s reliance on imported fossil fuels, and bring aging commercial stock in line with modern sustainability expectations.
For property investors and tenants with multinational portfolios, Savills urges looking beyond the EPC grade and instead analysing the underlying energy consumption data. Only through nuanced, location-specific due diligence can investors ensure they are meeting their sustainability goals and making informed decisions.
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