Portugal's EPBD transposition deadline was 29 May 2026. Portugal did not wait for that deadline: Decreto-Lei n.º 11/2025, de 19 de fevereiro, partially transposed the directive more than a year ahead of it, bringing in the Renovation Passport, minimum energy performance standards (MEPS), the zero-emission obligation for new buildings from 2030, and the end of financial incentives for fossil-fuel boilers from 1 January 2025. Full transposition of the remaining articles is still outstanding. For buyers, the energy rating matters today because it tells you what a home will cost to run and where any future efficiency work starts; no Portuguese rule currently restricts selling or renting a home by energy class. Decreto-Lei n.º 10/2024, de 8 de janeiro took the licence off the deed, so checking a property's documents before signing is now up to the buyer.
What is the EPBD and why does the May 2026 deadline matter?
The Energy Performance of Buildings Directive (EPBD/2024/1275) gave EU member states until 29 May 2026 to transpose it into national law. Portugal transposes through the Sistema de Certificação Energética dos Edifícios (SCE) framework overseen by ADENE and DGEG.
The EPBD has existed since 2002 and has been revised three times, most recently through Directive 2024/1275/EU, published in the Official Journal of the EU on 8 May 2024. The deadline for member states to bring national law fully into line was 29 May 2026. The directive requires minimum energy performance standards (MEPS); it is for each member state to set them, and the directive itself does not ban selling or renting a home.
Portugal already has a functioning energy certification system. All residential properties sold or rented since 2013 require a valid EPC rated A+ to F under Decreto-Lei n.º 118/2013, de 20 de agosto, as amended, now integrated with Decreto-Lei n.º 101-D/2020, de 7 de dezembro. ADENE (Agência para a Energia) administers the SCE system, with qualified experts (Peritos Qualificados) registered on ADENE's national registry. Transposition adds minimum performance standards and a renovation passport to that system; the thresholds for homes are not yet set.
The transposition process is led by the GT-EPBD working group, created under Despacho n.º 8023/2024, de 19 de julho. The group is chaired by ADENE with the participation of DGEG, the Agência Portuguesa do Ambiente (APA), the Instituto da Habitação e da Reabilitação Urbana (IHRU), the Laboratório Nacional de Engenharia Civil (LNEC), the Instituto da Mobilidade e dos Transportes (IMT), and the IMPIC. Portugal transposed the directive's first tranche through Decreto-Lei n.º 11/2025, de 19 de fevereiro, ahead of the working group's own consultation timetable. Full transposition of the remaining articles of DL 101-D/2020 was still moving through the legislative circuit and public consultation as of the most recent public communications from DGEG and ADENE leadership (Edifícios e Energia n.º 163, January/February 2026). Confirm the current state of that remaining transposition against the Diário da República before citing a specific article number or a firm completion date.
ADENE's national EPC registry holds approximately 1.6 million residential certificates as of March 2024. Distribution across classes is uneven: around 22% rate A or B, 44% rate C or D, and 23% rate E or F (ADENE data published by Novoperfil). The bottom of the distribution is the part the EPBD targets first.
What does the directive require from Portuguese buildings?
The EPBD requires member states to improve the worst-performing buildings in stages, with fixed thresholds for non-residential stock and an average-energy trajectory for homes, and to move towards zero-emission buildings by 2050.
The directive distinguishes residential from non-residential buildings. For residential stock, the primary obligation is that all properties reaching the market for sale or rental must hold a valid EPC. Portugal already requires this. The directive does not add a sale or rental restriction for homes.
For non-residential buildings (commercial, office, public), the directive introduces stricter audit cycles. Zero-emission building (ZEB) requirements apply to new public buildings from 2028 and to all new construction from 2030.
The full calendar set by Diretiva (UE) 2024/1275 runs across four post-transposition milestones for the Portuguese parque:
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2028. ZEB obligation for new public buildings.
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2030. ZEB obligation extends to all new construction, already Portuguese law under DL 11/2025. For non-residential buildings, the directive's target is that none performs below the worst 16% of the stock. For homes, it sets a trajectory for the national stock's average primary energy use (at least 16% lower than in 2020), not a minimum class for each home and not a sale or rental restriction.
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2033. The non-residential threshold tightens to the worst 26% of the stock. There is no EU minimum class for homes.
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2040. EU target to phase out fossil-fuel boilers. Portugal ended financial incentives for them from 1 January 2025 (DL 11/2025).
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2050. Full ZEB parque, decarbonised, with verified indoor environmental quality.
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Minimum performance standards. DL 11/2025 brought MEPS into Portuguese law; the thresholds and the buildings they apply to are still to be set, and none currently restricts the sale or rental of a home.
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Renovation Passport. DL 11/2025 created the Passaporte de Renovação de Edifícios, a digital document issued by a perito qualificado (Directive Art. 12 and Annex VIII). Under the directive it is voluntary for owners unless a member state makes it mandatory; whether Portugal will do so for any building is not yet set. InspectOS offers a Renovation Passport service, a planning document for staged energy renovation.
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Solar readiness. New buildings and those undergoing major renovation must meet solar-readiness standards under Art. 10(6) of Directive 2024/1275/EU. The Plano Nacional de Renovação de Edifícios (PNRE), due 31 December 2026, will define national renovation targets, financing instruments, and intervention priorities by typology. The PNRE replaces the Estratégia de Longo Prazo para a Renovação de Edifícios (ELPRE) and is the document buyers should track in the second half of 2026 to understand the trajectory for their property class.
How does the May 29 deadline affect property buyers?
29 May 2026 created no new obligation on a buyer of an F-rated home. What it changes is the trajectory: a low rating means higher running costs and a low starting point if national standards for homes are set later.
Under DL 10/2024 (the Simplex Urbanístico reform), the licença de utilização and the Ficha Técnica da Habitação no longer have to be shown at the deed, and there never was a public check of a home's condition at sale. The energy certificate must still be delivered to the buyer before the contract is signed (DL 101-D/2020). Checking all of it is the buyer's job.
Before signing, a buyer should verify:
- Whether a valid EPC exists (legally required under DL 101-D/2020, integrating DL 118/2013, Art. 12)
- The current energy rating and whether it meets the post-May 2026 minimum
- Whether a Renovation Passport exists, and what it says about staged improvements
Inspect before signing a binding reservation or CPCV where possible. Findings can inform repair requests, pricing and contract terms. Your lawyer should advise on your rights and any inspection condition. Signing a contract can affect your options; it does not mean that every defect automatically becomes your sole legal responsibility. The property due diligence checklist for Portugal sets out all four mandatory documents buyers must verify before the CPCV alongside EPC and energy compliance status.
For buyers financing through Portuguese banks, ask the lender how it treats the energy class before signing the CPCV. Lenders set their own terms; some offer better conditions for efficient homes, and the lower value that inefficient homes can attract is often called the brown discount (desconto castanho).
Foreign buyers face additional exposure. Properties in the Algarve, a region with a large share of foreign buyers, include a lot of older villa stock rated E or F, and a buyer who does not check the certificate before signing the CPCV (contrato-promessa de compra e venda) can end up with higher running and improvement costs than expected. The complete guide for foreign buyers in Portugal covers how EPBD exposure compounds the risks of purchasing remotely.
For buyers acquiring new construction, the EPBD interacts with the existing DL 84/2021 consumer warranty regime. New buildings must be zero-emission from 2030 under DL 11/2025; until then a new-build apartment follows the current SCE rules for new construction, on top of the structural and non-structural warranty obligations. The new build snagging inspection guide covers the verification framework for handover, including the energy compliance dimension.
Verify EPC validity and rating before the CPCV, not after.
Buying a property in Portugal? Verify the energy certificate before signing anything.
What are the risks for owners who do not comply?
Advertising or transacting a property without a valid EPC is illegal under DL 101-D/2020 with fines from €250 to €3,740 for residential properties and up to €44,890 for non-residential buildings.
An EPC is valid for 10 years from the date of issue. Owners whose certificate has expired before the May 2026 deadline must renew before listing. ADENE maintains a public registry where any buyer can verify certificate validity, but in practice many buyers and agents do not check until late in the transaction, by which point the closing timeline is at risk.
Beyond fines for missing or expired certificates, owners of low-rated properties face three specific post-deadline risks.
Transaction rules come first. Portugal has set no sale or rental restriction by energy class; any future national standard for homes will come from Portuguese law, and owners should watch the PNRE.
Financing is the second. Lenders set their own terms by energy class. A buyer who learns mid-process that the lender values a low-rated home less may renegotiate the price, or withdraw if the CPCV contains an appropriate condition.
Renovation cost liability is the third. If a sale completes without disclosure of the energy rating, buyers may have legal recourse under Código Civil, Art. 913 (sale of defective goods, defeitos ocultos), but litigation is slow and costly. Pre-CPCV verification is faster and cheaper.
29 May 2026 was the deadline for member states to transpose the directive. The PNRE, due by 31 December 2026, will set Portugal's renovation trajectory.
Which buildings are most exposed?
Buildings constructed before 1990 account for approximately 58% of Portugal's residential stock (INE, Censos 2021) and are most likely to carry E or F ratings, making them the primary target of the EPBD's minimum performance requirements.
Exposure varies by region.
Lisbon has the highest aggregate risk. Pre-1960 Pombaline and Estado Novo-era buildings dominate the Avenidas Novas, Arroios, and Mouraria districts. These buildings were constructed before any thermal regulation existed in Portugal and typically rate E or F. 68% of the building stock in the Lisbon metropolitan area predates the seismic-protection legislation approved in 1958 (Público, February 2023), and those buildings also predate modern insulation and HVAC standards. These buildings require both energy and structural assessment, the structural and seismic inspection Portugal guide covers the Eurocode 8 seismic vulnerability framework for pre-1983 stock. For the full Lisbon defect profile, see the Lisbon apartment inspection guide.
Algarve carries the highest foreign-buyer exposure. Older villa construction from the 1970s and 1980s tends to rate E or below due to single-glazed windows, minimal roof insulation, and electric heating systems with high primary energy consumption. Buyers who skip the certificate check can face substantial renovation costs later.
Porto has significant pre-war stone construction in Bonfim, Paranhos, and Campanhã that rates poorly under SCE methodology due to thermal mass and wall U-values. The casa burguesa stock in the historic centre carries the same exposure with the added UNESCO classification constraints on intervention type. Porto's tight housing market means sellers hold more negotiating power, and buyers who discover energy issues post-CPCV have limited leverage. For the Porto-specific framework, see the Porto property inspection guide.
How does the EPBD interact with DL 10/2024 (Simplex Urbanístico)?
DL 10/2024 took the licence off the deed in January 2024. The EPBD deadline added no new obligation on a buyer; the energy certificate must still reach the buyer before the contract is signed.
DL 10/2024 took the licença de utilização and the Ficha Técnica da Habitação off the deed. The energy certificate must still be delivered to the buyer before the contract is signed (DL 101-D/2020). For the full legislative detail, see the Simplex Urbanístico guide.
In practice a sale can still complete without a valid certificate. The seller is the one exposed to the fine under DL 101-D/2020 (€250 to €3,740 for individuals), and the buyer loses the information the certificate was meant to give.
Buyers using independent due diligence through RealOS can verify EPC validity and rating through the EPBD Compliance Calendar feature, which pulls live data from the ADENE registry and flags expiry dates and financing risk scores. This can be done before any offer is made.
For buyers who want physical verification of thermal performance, moisture penetration, and actual HVAC condition rather than a certificate review alone, the pre-purchase property inspection includes an assessment of installed systems relevant to the EPC rating, not document review only.
What does an Energy Performance Certificate cover?
An EPC issued under Portugal's SCE framework assesses thermal performance, HVAC systems, hot water production, renewable energy sources, and CO2 emissions to produce a rating from A+ (most efficient) to F (least efficient), valid for 10 years from issue date.
The assessment methodology, rating scale, exemptions, validity periods, and how to obtain a certificate are covered in full in the Energy Performance Certificate Portugal guide. Certificate validity is publicly verifiable at sce.pt, to check before making any offer. Properties with gas installations must also verify the mandatory gas inspection Portugal (Boletim de Inspeção under DL 97/2017) separately, as gas compliance is a distinct legal obligation not assessed by the EPC.
The relationship between the EPC and the new Renovation Passport is one of complement rather than substitution. The EPC classifies a building at a point in time. The Renovation Passport defines the staged pathway from the current class to compliance with the relevant minimum at each EPBD milestone. The two documents share the ADENE database and the qualified expert pool. A buyer of an E or F-rated property may find both useful.
What improvement path does InspectOS recommend?
For properties rated E or below, the Renovation Passport produces a staged improvement roadmap, giving a buyer a clearer picture before committing to a low-rated property.
A property rated D is manageable without major works. Window replacement, HVAC upgrade, or solar water heating can often move a D to a B or C, and the cost is proportionate. Lenders set their own terms by energy class.
A property rated E or F requires more detailed analysis before purchase. The Renovation Passport gives a buyer:
- An energy audit identifying which fabric and system interventions produce the best cost-per-rating-class improvement
- A BIM model of the building as-found
- A staged improvement schedule
- A note of any structural or moisture issues seen on site, since older buildings rated E or F can also have them; the moisture inspection guide covers concealed moisture damage commonly uncovered during energy renovation For buyers at the offer stage who want a fast initial read before committing to a full Renovation Passport, the EPC provides the current rating and remaining certificate validity. For complete pre-purchase coverage including physical condition assessment, book the Pre-Purchase Inspection together with the Simplex Safe and an EPC at inspectos.pt.
Frequently Asked Questions
My property has an EPC from 2015. Is it still valid for the May 2026 deadline?
A certificate is valid for 10 years from issue date. A 2015 certificate expired in 2025 and must be renewed before any transaction or rental. Certificates issued from October 2016 onwards are still valid in October 2026. The expiry date is on the document itself and verifiable on the ADENE registry at sce.pt.
Can a buyer use the energy rating to negotiate a lower price?
Yes. A property rated E or F usually has room for improvement. An InspectOS EPC combined with independent contractor quotes for the required works gives a buyer a factual basis for price negotiation before signing the CPCV. Some buyers negotiate a price reduction based on documented improvement scope, then carry out the works after purchase.
What is a Renovation Passport and when is it required?
A Renovation Passport (Passaporte de Renovação) is a formal document that maps a building's path from its current energy rating to compliance with minimum performance standards. The instrument is defined by Diretiva (UE) 2024/1275 Art. 12 and Anexo VIII and was introduced in Portugal by DL 11/2025. Under the directive it is voluntary for owners unless a member state makes it mandatory, and Portugal has not yet set when, or whether, it will be required for any building. The InspectOS Renovation Passport is a planning document for staged energy renovation. Get a quote at inspectos.pt.
Does the EPBD affect commercial property differently from residential?
Yes. For non-residential buildings (offices, retail, hospitality), the EPBD introduces stricter requirements including mandatory smart-readiness indicators, more frequent energy audits, and zero-emission building standards for new public buildings from 2028. Member states must bring non-residential buildings above the worst-performing 16% threshold by 2030 and the worst 26% by 2033. Commercial property buyers should commission a technical due diligence inspection alongside any EPC review. Contact InspectOS for a commercial assessment quote via inspectos.pt/en/schedule.
How long does it take to get an EPC in Portugal?
An InspectOS EPC is issued 3 to 5 business days after the site visit, once the required documents are received, covering the on-site assessment, ADENE submission and certificate delivery. For buyers working to a CPCV deadline, booking early in the due diligence process avoids timeline pressure.
What is the brown discount and how does it affect my mortgage?
The brown discount (desconto castanho) is the lower value or weaker financing terms that energy-inefficient homes can attract. The EBA Guidelines on Loan Origination and Monitoring ask banks to consider environmental risk when they lend, but no Portuguese rule sets a penalty by energy class, and each bank sets its own terms. A buyer expecting standard mortgage terms on a low-rated property should request a pre-approval indication before signing the CPCV.
What happens to my property if I do nothing before 29 May 2026?
Nothing changed for an individual home on 30 May 2026: 29 May was the deadline for member states, and Portugal had already transposed part of the directive through DL 11/2025. The existing rule stands: a valid certificate is needed to sell or rent. Owners planning to sell or rent should check that their certificate is in date. Owners planning to retain the property for the long term have the PNRE timeline (publishing 31 December 2026) to plan against.
Conclusion
29 May 2026 was the EU deadline for transposing Directive 2024/1275. Portugal transposed part of it through DL 11/2025 and the rest is pending. No Portuguese rule today bans selling or renting a home because of its energy class, and renovation passports are not mandatory for owners. The rating still matters to a buyer: it tells you what a home will cost to run and where any future efficiency work starts.
The entry point for any buyer is verifying the current energy rating. The Energy Performance Certificate establishes the current rating, remaining validity, and whether a Renovation Passport would help plan improvements before any further commitment is made.
Originally published 2 April 2026 | Updated October 2026 | InspectOS Portugal
Sources
- Directive 2024/1275/EU (EPBD recast, OJ 8 May 2024)
- Decreto-Lei n.º 101-D/2020, de 7 de dezembro (SCE framework)
- Decreto-Lei n.º 118/2013, de 20 de agosto (SCE prior framework, integrated)
- Decreto-Lei n.º 10/2024, de 8 de janeiro (Simplex Urbanístico)
- Decreto-Lei n.º 84/2021, de 18 de outubro (consumer warranty)
- Despacho n.º 8023/2024, de 19 de julho (GT-EPBD)
- Código Civil Art. 913
- Decreto-Lei n.º 11/2025, de 19 de fevereiro (partial EPBD transposition)
- ADENE national EPC registry
- ADENE data on certificate distribution (March 2024, via Novoperfil)
- Edifícios e Energia n.º 163 (January/February 2026), DGEG and ADENE leadership communications
- INE Censos 2021
- INE property transaction data 2025
- Público, February 2023 (Lisbon metropolitan area building stock)
- EBA Guidelines on Loan Origination and Monitoring (EBA/GL/2020/06, updated 2024)