Regional EPBD exposure · Q4 2025 baseline
Where the deadline bites first: Lisbon, Algarve, and Porto
The 29 May 2026 transposition does not affect every Portuguese region equally. Building age, foreign-buyer concentration, and market liquidity produce distinct exposure profiles. The three regions below carry the highest aggregate risk in different ways.
Lisbon
Highest aggregate risk
Dominant building stock
Pre-1960 Pombaline and Estado Novo-era construction across Avenidas Novas, Arroios, Mouraria
Pre-current-code share
~68% of stock predates current seismic codes and modern thermal regulation (CML Programa ReSist)
Typical rating
Class E or F predominant in pre-1960 stock
Driver of exposure
Building age plus absence of thermal regulation at original construction
Algarve
Highest foreign-buyer exposure
Dominant building stock
1970s and 1980s villa construction with single-glazed windows, minimal roof insulation, electric heating
Foreign-buyer share
Over 80% of transactions involve foreign buyers (INE 2025)
Foreign-buyer average price
€406,000 per transaction (INE 2025)
Driver of exposure
Pre-deadline listings transferring renovation cost to remote buyers without EPC verification
Porto
Tightest market leverage
Dominant building stock
Pre-war stone construction in Bonfim, Paranhos, Campanhã · casa burguesa in the historic centre (UNESCO classified)
Median asking price
€3,908/m², up 5.9% year-on-year (Idealista, Nov 2025)
Typical SCE rating
Class E or below in pre-war stock; thermal mass plus wall U-values weigh against the rating
Driver of exposure
Seller-favoured market; buyers discovering issues post-CPCV have limited renegotiation leverage
The common factor
Under DL 10/2024, the buyer carries the verification burden in every region
Lisbon's pre-1960 stock, the Algarve's 1970s villas, and Porto's casa burguesa all share a single transaction-level reality: the notary no longer verifies the EPC at escritura. Whether the property fronts onto Avenida da Liberdade, a Quinta do Lago golf course, or the Douro river, the buyer signs and inherits the energy compliance cost from that moment. Pre-CPCV verification is the only safeguard.