Sufficiency in the National Building Renovation Plans: Recommendations for Member States

National Building Renovation Plans (NBRPs) are, in essence, the roadmaps to guide the decarbonisation of national building stocks. Member States were required to submit the first draft NBRPs by 31 December 2025. The European Commission will assess the drafts within six months, with the final versions due by the end of 2026. Both the template in Annex II of the Energy Performance of Buildings Directive (EPBD) as well as the annotated template published by the Commission in June 2025 refer to “sufficiency” without further clarifying the concept. This document aims to provide additional guidance, inspiration and support for Member States in formulating effective sufficiency measures that can contribute to multiple policy objectives simultaneously.

In the template of the NBRPs (Annex II EPBD) and the Commission’s annotated guidelines, Member States need to report what they have implemented or plan to implement in terms of sufficiency measures. This is to be reported under section c) “Policy and measures”.  

Sufficiency, applied to the building sector means, above all making the best use of existing buildings to create a built environment that is attractive, affordable, and aligned with the actual space and accessibility needs of occupants, all while respecting planetary boundaries.  

Integrating sufficiency in broader climate and energy plans has multiple benefits for local, regional and national decision-makers. They all face the challenge of tackling multiple issues at once: meeting climate goals, reducing land-sealing and biodiversity loss, providing affordable housing, strengthening communities and revitalising regions, all while struggling with tight municipal budgets. The concept of sufficiency offers a systemic approach for the built environment that can support these objectives. 

Prioritising existing buildings can not only help to reduce the life-cycle GHG emissions of the built environment, but also to reduce infrastructure costs for local authorities by avoiding urban sprawl and commuting, reduce land-take and resource consumption, while providing affordable, high-quality housing in a cost and time effective manner and revitalising neglected neighbourhoods.   

The following sufficiency-based strategies are listed in this BPIE report, including real-world practical examples on how sufficiency principles can be translated into concrete policies and measures at scale:  

  • Prioritise the existing building stock in public procurement and other strategies 
  • Plan to gather data on vacancies and under-used spaces 
  • Leverage the potential of district level programmes 
  • Integrate sufficiency advice in One-Stop-Shops  
  • Develop strategies that make publicly owned vacant offices available for conversion into social housing  
  • Adapt building regulations to make repurposing and reusing existing buildings easier 
  • Incentivise updating zoning to allow mixed-use and/or fast-track permitting for conversion  
  • Develop/enhance funding programmes to make best use of the existing building stock  
  • Implement tax measures on vacancies and/or reduced VAT for conversion and renovation 
  • Regulate short-term rentals 
  • Introduce absolute metrics in the National WLC Roadmaps (Article 7 EPBD)  
  • Prevent unnecessary demolition by introducing mandatory pre-demolition auditing linked to whole-life carbon assessments 

As the Commission will closely scrutinise the draft NBRPs during the next six months, Member States still have a clear opportunity to reflect on, refine, and integrate the recommendations set out in this document before submitting their final plans. This guidance will also support the Commission in providing targeted feedback and direction to Member States.  

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