Implementation of the EPBD in Belgium – Flemish Region

DATEDecember 2016
AUTHORSMarijke De Meulenaer, Kristien Triest, Flemish Energy Agency

1. Introduction

In Belgium, the implementation of the EPBD is the responsibility of the regional governments. The Flemish Energy Agency (VEA) and the Ministry of Environment, Nature and Energy are the responsible public bodies in the Flemish Region. They are also in charge of managing the certification scheme, the accreditation of experts and compliance checking. A central register is used to collect data from all certificates as well as the calculations of new building requirements.

In 2014, an evaluation process of the Flemish legislation concerning the certification of existing buildings was finalised, and in 2015, an evaluation process of the legislation concerning the requirements for new and renovated buildings was also finalised. A new calculation method for new and renovated non-residential buildings was implemented in 2016. The NZEB requirements for these buildings are currently being implemented.

This report presents an overview of the current status of implementation of the EPBD and future developments in the Flemish region. It addresses, among other issues, requirements, certification and inspection systems, including quality control mechanisms, training of qualified experts and information campaigns.

2. Current Status of Implementation of the EPBD

2.I. Energy performance requirements: NEW BUILDINGS

In Belgium, regulations on building energy performance are set at the regional level. However, the three regions cooperate to establish a common methodology for new and refurbished buildings, leaving each region free to define its own requirements. Also, the three regions use a jointly developed single software tool (Figure 1). The Flemish Energy Agency is the public organisation responsible for the energy performance requirements in the Flemish Region.

Figure 1. Software tool for the calculation of the building energy performance of new and refurbished buildings.

2.I.i. Progress and current status of new buildings

The most important requirement concerns the dimensionless E-level1. The E100-level was introduced in 2006 for new houses, offices and schools. Up to 2016, it was subsequently reduced by 50% to E50, based on cost-optimal studies. The introduction of the E-level for all non-residential buildings (hotels, hospitals, retail, etc.) has started in 2017.

Since 2006, existing requirements have been strengthened for all new buildings. A number of new requirements were introduced in the following years (in 2012 for net energy demand, in 2014 for the minimal share of RES). This set of requirements and its cost-optimal levels were thoroughly evaluated in 2015, with three large studies having been conducted (cost-optimal level for residential2, cost-optimal level for non-residential3, energy performance requirements4).

Until 2016, more than 280,000 final declarations (calculations of the energy performance requirements in as-built situations) were collected in the central register (Figure 2).

Figure 2. Total number of final energy performance declarations (cumulative).

The analysis by the Flemish Energy Agency (the most recent report is found at indicates that the average E-level decreases every year (Figure 3). This evolution is most evident for new single-family houses. The number of single-family houses with an E-level higher than E50 drops from nearly 98% for building permits in 2006 and 85% for building permits in 2010 to 34% for building permits in 2014 (Figure 4).

Figure 3. Evolution of the average energy performance level of new residential buildings, per year of the building permit application.

Figure 4. Distribution of E-levels per year (application of building permit).

2.I.ii. Format of national transposition and implementation of existing regulations

Energy performance requirements for new and renovated buildings in the Flemish Region first started in January 2006. The legislation was consolidated in the energy decree of 2009 (het Energiedecreet van 8 mei 20095) and the energy law of 2010 (het Energiebesluit van 19 november 20106). Each new building must fulfil requirements on energy performance (E-level) and insulation (U-values and global insulation ‘K-level’7) as well as on the indoor air quality and thermal comfort (risk of overheating and ventilation).

The energy performance level or E-level sets the maximum allowed primary energy use for a building. The calculation includes, e.g., thermal bridges, shading devices and the infiltration rate. The airtightness measurement has to comply with the requirements of a quality-assurance scheme as part of technical specifications STSP71-3 (annex 6). Two energy performance methodologies are described in the energy law: one for residential buildings, and the other for non-residential buildings (with a new method substituting for the former method for offices and schools and based on CEN methods). The primary energy factor for electricity is 2.5, and for other sources 1.

Every two years, all levels of requirements are evaluated by carrying out cost-optimal studies, and the levels are adjusted when needed.

The Flemish Energy Agency checks the compliance with the procedures (submitting, to a central database, a calculation at the start and again at the as-built situation) and with the requirements. In case of non-compliance with the procedures, the builder receives a warning to submit the calculation to the central database. The central database automatically checks that each individual building meets all the requirements. The compliance rate of new buildings with the E-level is very high (> 99% for E-level), as it is for most other requirements as well (Figure 5). For the ventilation requirements, however, the compliance rate is lower, but shows improvement, whereas the systematic tightening of the requirements on E-level has not influenced the high compliance rate. Those responsible for buildings that, after being warned, do not comply with the procedures, or that do not meet the requirements, receive an administrative fine (Table 1).


Figure 5. Compliance rate with the energy performance requirements (new buildings).

Proceduresat start8327

Table 1. Administrative sanctions for infringements of procedures regarding energy performance requirements.

The Flemish Energy Agency also checks a building sample on the quality of the as-built calculations. In 2015, 182 calculations were checked, and in 2016, 45 calculations were checked. In order to further improve the quality of the reports, experts must attend continuing education since 2015. In 2016, 3,453 experts were suspended, most of them non-active experts who did not attend any education courses.

2.I.iii. Action plan for progression to NZEB for new buildings

Since 2012, the Flemish NZEB action plan focuses on informing, educating, facilitating and financially aiding governments and the public, as well as public, professional, financial and commercial organisations with the introduction of NZEB in the different domains of society by involving them in over 30 actions and projects8 9.

An important action consists of clearly defining and communicating NZEB regulations, and supporting them by financial subsidy systems that are in place for the frontrunners. The NZEB-levels are defined by the cost-optimal studies that take into account the methodology framework provided by the European Commission. The cost-optimal studies of 2015 on residential and non-residential buildings resulted in a revision of the energy performance indicator (E-level) for non-residential buildings and buildings of public administrations, defining the following requirements10:

  1. for residential buildings: E50 in 2017, E40 in 2018, E35 in 2020, E30 (= NZEB level) in 2021;

  2. for non-residential buildings: see Table 2 (NZEB levels are mentioned in the last column);

  3. for buildings of public administrations: see Table 3 (NZEB levels are mentioned in the last column).

E-level, function201720182021
Lodging functions807070
Health care with lodging807070
Health care without lodging806565
Health care operating rooms605050
Meeting areas high occupancy806565
Meeting areas low occupancy806565
Meeting areas cafetaria/refectory706060
Sports: sports hall655050
Sports: fitness, dance654040
Sports: sauna, swimming pool655050
Technical plants/control rooms554545
Common areas555550

Table 2. E-level tightening scheme for non-residential buildings.

E-level, function201720182019





Meeting areas high occupancy




Meeting areas cafetaria/refectory








Technical plants/control rooms504545

Common areas




Table 3. E-level tightening scheme for public administration buildings.

Apart from the E-level, the NZEB definition for new buildings includes additional requirements such as a minimal share of RES.

Recent NZEB actions, targeted at local governments, aim to enhance their NZEB knowledge and motivation by a regionwide road show of good examples, well documented by the mayors, members of the city council and the building team (Figures 6 to 9). Furthermore, the local governments can apply for free NZEB assistance and advice for their building projects during a period of 18 months11.

Figure 6. Good example for local governments: a NZEB after school day care center: (source: BEN-guide for local governments).

Figure 7. Good example for local governments: a NZEB after school day care center: energy performance (source: BEN-guide for local governments).

Figure 8. Good example for local governments: a NZEB after school day care center: materials and installations (source: BEN-guide for local governments).

Figure 9. Good example for local governments: a NZEB after school day care center: materials and installations (source: BEN-guide for local governments).

Continuous NZEB actions that aim to educate and motivate local governments, architects and the public consist of introducing the NZEB-label (Figure 10), a NZEB-handbook (Figures 11 to 13), and the website where one can search for existing NZEB projects and training. A catalogue of 141 residential, public, office and commercial buildings provides details on the designer, the energy performance, the applied techniques and insulations (Figures 14 to 16).

Finally, other continuous NZEB actions cover quality control, including education (competences and knowledge), execution (study as well as execution on the building site), and defining regulations for good practice (ventilation, airtightness and RES installations). These projects are executed in close collaboration with the Department of Education, educational institutions and the professional federations of architects, contractors and energy experts.

Figure 10. Branding the NZEB-label, available for NZEB frontrunners.

Figure 11. NZEB-handbook: cover.

Figure 12. NZEB-handbook: NZEB requirements.

Figure 13. NZEB-handbook: guidelines for design and execution.

Figure 14. NZEB website with 141 NZEB residential, office, commercial and public buildings, providing energy performance details, information on material, installations, NZEB architects and NZEB training.

Figure 15. Zero-energy office, bank office in Gooik. E-level 1, K-level 25.

Figure 16. Energy performance details on of the office building in image 15: E-level 1, K-level 25.

2.I.iv. Requirements for systems and / or building components for new buildings

There are no specific requirements for technical building systems for new residential and non-residential buildings. The performance of systems is integrated in the calculation methods of the energy performance (E-level). Since the performance of the installations is taken into account in the E-level, there is no need for individual requirements. Individual requirements for new buildings are therefore considered an extra administrative burden that in addition reduces freedom in design without a proportionate benefit.

In 2017, the same requirements on technical building systems that have existed since 2015 for renovations will apply to new industrial buildings, since this type of buildings does not have an E-level.

Since 2006, maximal U-values are in place for new building components. These levels were systematically strengthened during the years and are meeting current cost-optimal levels (Table 4).

Maximum U-value (in W/m².K)
from 2006 to 31/12/2009from 2010 to 31/12/2011from 2012 to 31/12/2013from 2014 to 31/12/2014from 2015 to 31/12/2015from 2016
Roofs, ceilings to attics0.400.300.
Outer walls0.600.400.320.240.240.24
Floors on the ground, or above cellars0.400.400.350.300.300.24
(profile + glazing)
Insulated existing walls (outside)----0.240.24
Insulated existing walls (cavity)----0.550.55
Insulated existing roofs----0.240.24
Insulated existing floors in contact with outdoor environment----0.300.24

Table 4. Overview of maximum U-values since 2006.

2.II. Energy performance requirements: EXISTING BUILDINGS

Energy performance requirements for renovated buildings in the Flemish Region (as for new buildings) first started in January 2006. Each building that undergoes a renovation with a permit12 must fulfil requirements on insulation levels (U-values) and on the indoor air quality (ventilation).

2.II.i. Progress and current status of existing buildings

Since 2006, the U-value requirements have been strengthened systematically. A number of new requirements were introduced in 2015: minimal requirements for technical building systems, maximal U-values for existing, insulated structures and a maximal E-level for deep renovations. A “deep renovation” is defined as a renovation where more than 75% of the surfaces in contact with the outdoor environment are insulated and all technical building systems are replaced. The calculation method of the E-level is the same as for new buildings, but values to calculate the transmission of existing building components are added also. The set of requirements and its cost-optimal levels were thoroughly evaluated in 2015.

2.II.ii. Plans to improve the existing building stock

The Flemish strategy for renovating buildings (EED Article 4) consists of two parts. The basic part of the strategy is the Energy Renovation Programme 2020. The ambition of this programme is that by 2020, every citizen of the Flemish Region lives in an energy-efficient house with roof insulation, no single glazing and an efficient heating installation. If, in an existing house, the roof insulation is missing, single glazing is still present or the heating installation is older than 25 years, then the priorities for the EPC are the insulation of the roof and the replacement of the single glazing and boiler. The Energy Renovation Programme is completed with the strategy “On the road to NZEB”, supporting early adopters.

The Energy Renovation Programme 2020 aimed to set energy upgrades and energy efficient renovations into motion. However, in order to increase the level of ambition from fragmented improvements towards deep renovations of all existing houses, the government decided to establish a multi-stakeholder partnership. Starting in December 2014, working groups of stakeholders together with public authorities prepared recommendations for a “Renovation Pact”, a long-term strategy for residential buildings, to be applied until 2050. The definition of a long-term 2050 target for energy performance of Flemish houses is one of the many subjects of this pact (Figure 17).

Figure 17. Visualisation of the ‘Renovation Pact’ with long term goals towards 2050.

To implement EED Article 5, the Flemish government has chosen the alternative approach. This requires a series of measures to be taken in public buildings with a total of energy savings equivalent to a deep renovation of the central government's building stock. A first calculation based on available data in 2013 has shown that 150 buildings with an estimated total usable floor area of 900,000 m2 fall under this obligation. These 150 buildings represent only those that fall under the implementation of Article 5. As a result, the Flemish government has to realise 2.4 GWh of savings under the default approach. The first calculations with the alternative approach estimate that it is possible to save 28 GWh during the 2014-2020 period. In view of the 4th Flemish Energy Efficiency Action Plan, new calculations will be undertaken, taking into account new data on buildings owned and occupied by the central Flemish government. The goal is that the public buildings that fall under Article 5 in the EED will, after renovation, improve their energy performance to at least the yellow zone of the EPC. Overall, this means an estimated energy saving of 10%.

2.II.iii. Regulation of system performance, distinct from whole building performance

Requirements for technical building systems can be found in the environmental regulation for heating and cooling systems as well as in the energy performance requirements for buildings (Table 5).

Type of installationRequirement on

Heating systems with space heaters
(gaseous and liquid fuels)

Minimum efficiency
Heating systems with electrical heat pumpsMinimum seasonal performance factor (SPF)
Electrical resistance heatingMaximal power

Electrical boilers and water heater
for domestic hot water (DHW)

Maximal power

Pipework insulation
for heating/cooling systems and DHW

Mandatory for forced circulation,
stimulated for other systems

Cooling system with ice-water distribution systemsMinimum efficiency

Ventilation systems with
mechanical supply and extraction

Minimum efficiency of heat recovery
Non-residential lighting systems

Maximal equivalent specific installed power

Use of modulating systems is stimulated

Table 5. Overview of requirements for technical building systems.

The energy performance requirements for technical building systems are created with the purpose of applying them to new, replaced or upgraded systems in existing buildings. The requirements apply to new installations or installations which are altered or expanded in existing buildings with a building permit. The requirements apply from 1 January 2015. Existing technical building systems which remain unchanged during a refurbishment or works that do not require a building permit do not need to comply with these requirements. However, it is expected that the HVAC contractors will adopt the requirements as benchmarks for these works. Requirements for renovations carried out without a building permit are difficult to enforce. The Flemish government chose not to lay down requirements in cases where enforcement is not possible in practice, or where the extra administrative burden to prove compliance would be too high.

The requirements apply to both large and small modifications to installations in residential as well as non-residential buildings. If the impact of the modification is so small that it is not technically feasible to meet the requirements, there is a procedure for requesting an exception.

2.II.iv. Encouragement of intelligent metering

The energy performance regulations for technical building systems contain requirements for energy metering of large installations. Table 6 gives an overview of the requirements. The presence of such metering systems is obligatory, but it has no impact on the energy performance of the building. The meters need to comply with standards and they can transmit data by using a form of electronic communication. Intelligent metering of the whole building is not yet mandatory. The Flemish government decided to introduce digital meters for electricity and gas in households starting from 2019. The introduction will be gradual, starting with the replacement of limited meters and outdated meters.

Type of installationPowerType of meter
Heat-production> 70 kWFuel + meter
Heat-production> 400 kWCalorimeter
Electrical heat pump> 10 kWMeter for electrical consumption
Electrical heat pump> 100 kWMeter for the amount of useful energy
Cooling (ice-water)> 10 kWMeter for electrical consumption
Cooling (ice-water)> 100 kWMeter for the amount of useful energy

Table 6. Overview of legally-required meters.

2.II.v. Financial instruments and incentives for existing buildings

In order to stimulate energetic renovation, a package of financial incentives and subsidies for individual measures is available (Figure 18). Some measures fit within the EPBD. The main focus for individual insulation measures are roof insulation, wall (outside, cavity, inside) insulation, floor insulation and high efficiency glazing. Main individual RES measures are subsidies for thermal boilers and heat pumps. In 2015, nearly 100 million € of subsidies were distributed for these measures (EPBD and non-EPBD). The most popular measure is roof insulation, with 54,000 roofs insulated.

Figure 18. Brochure regarding subsidies and fiscal advantages (regarding energy-saving investments in residential buildings).

Since 2017, individual measures are extended with global measures, called the “total renovation bonus” in order to promote deep renovations, mainly EPBD related. As soon as 3 (up to 7) measures are combined, additional incentives are foreseen. Investments can be spread over a period of 5 years.

Since October 2016, a new financial incentive for a period of 5 years has been introduced for “IER-EPBD-renovations”, or deep energetic renovations, achieving an E-level of max. E90. A reduction of 50% (E90 or below) or 100% (E60 or below) is granted on property tax for a period of 5 years.

The total amount of combined subsidies for deep renovations ranges between 10,000 and 20,000 € per house. Information campaigns / complementary policies

The communication about EPBD mainly focusses on the E-level to be achieved by law and the lower level for financial incentives and the path to NZEB (E30) by 2021. In recent years, for new buildings, the communication focused on BEN-bouwen (BEN = Bijna EnergieNeutraal = NZEB) and the levels to be achieved. The Flemish region focuses on the forerunners (companies, administrations, architects, material producers). By the end of 2016, some 854 forerunners were registrered on The slogan is “ik BEN mee” (I get it). By the end of 2015, houses were built on average E43 and 20% of them already achieve the NZEB or BEN-level (E30).

For deep renovations, by the end of 2016 a new campaign started called “BENOveren” (Figure 19). This means “to renovate better” and focuses on the long-term goals towards 2050.

Figure 19. Branding deep renovations with long term goals towards 2050.

2.III. Energy performance certificate requirements

2.III.i. Progress and current status on sale or rental of buildings and EPCs

The Flemish Energy Agency is the responsible organisation for implementing EPCs. In January 2006, the certification of new buildings started with the implementation of the energy performance requirements.

More than 200,000 EPCs for new buildings have been issued in the Flemish Region since 2006.

For existing residential buildings (for sale), certification started on 1 November 2008. In case of the rental of existing houses, certification is compulsory as of January 2009. More than 1.2 million EPCs for existing residential buildings have been issued since then. Non‐residential buildings, in case of sale or rental, do not yet require an EPC. The implementation of the energy certification scheme for the sale and rental of non‐residential existing buildings is still under development and it is expected to start in the course of 2019.

Only a qualified expert can issue an EPC, and the qualified expert has to use a specific certification software, provided by the Flemish government. All EPCs must be reported to a (non‐public) database13, which is property of the Flemish Energy Agency. Qualified experts can only view their own files/EPCs.

The energy score on the EPC is based on a calculation (asset rating). The EPC includes standardised recommendations (depending on the qualified expert’s input).

An EPC has to be available from the moment a building is put up for sale or rent. The buyer receives the EPC, and in case of rental, the tenant receives a copy of the EPC. In case of sale, the notary has to report the absence of the EPC to the Flemish Energy Agency. Since December 2015, the notary might have to pay a fine when he does not report the absence to the Flemish Energy Agency. When an EPC is not available by the time of advertising, the seller might have to pay a fine.

The EPC is valid for a period of 10 years. Currently, there is no obligation that a new EPC should be issued in case of renovation.

2.III.ii. Quality Assessment of EPCs

In addition to the checks on new buildings (45 in 2016), the Flemish Energy Agency executes a quality check on the work of a number of qualified experts, based on possible illogical inputs of data as well as at random. Each month, a sample of EPCs made in the previous month is taken. A part of those EPCs is checked by desk controls, another by site visits. Since 2016, the Flemish Energy Agency has increased the number of site visits (10 in 2015 and 38 in 2016) in order to improve the quality of the EPCs. In addition, the Flemish Energy Agency also handles complaints regarding the quality. In case of a complaint, the quality is investigated on the spot (site visit).

In 2016, 202 EPCs were checked using the random sampling method and 108 EPCs by targeted control. After checking the evidence, 286 qualified experts were evaluated as complying or received a warning, 23 experts had to pay a fine, and 1 was suspended.

In addition, there were 9 complaints (14 in 2015) and 8 of the qualified experts had to pay a fine. These high figures are based on a targeted control. Conclusions on the overall quality of all EPCs cannot be derived from this.

Since December 2015, the minimum fine for the incorrect issuing of an EPC is reduced. Experts now risk a fine which ranges between 250 € and 5,000 € if the control shows that the certificates were not correctly issued.

In order to further improve the quality of the EPCs, experts must attend continuing education from January 2017.

2.III.iii. Progress and current status of EPCs on public and large buildings visited by the public

In the Flemish region, the certification of public buildings has been gradually introduced. Initially (since January 2009), only large (> 1,000 m²) public buildings needed to have an EPC on display. Since January 2013, all public buildings larger than 500 m² need to display an EPC. As of January 2015, small public buildings (> 250 m²) are also included.

Since September 2016, it is possible to use the EPC for new buildings, or in the future, the EPC can be used for non-residential buildings, in order to meet the above requirement.

In case of rental or sale, an EPC for non‐residential buildings will be necessary. The EPC for existing non-residential buildings is still under development.

From 2009 until the end of December 2016, almost 10,000 certificates for public buildings were issued. These certificates are issued on the basis of an operational rating (measured energy consumption).

Public buildings are defined as buildings of the federal, regional and local governments, schools and health and welfare institutions. Private buildings visited by the public are not yet included.

2.III.iv. Implementation of mandatory advertising requirement – status

Since January 2012, it is mandatory to publish the energy score and the address or the unique certificate reference number in all commercial advertisements. In 2016, 3,085 controls were executed regarding the advertising requirements. Ninety-one percent (91%) of the controlled advertisements had the correct advertisement requirements (89% in 2015).

Since December 2015, the minimum fine for not publishing the required data was reduced to 250 €. Both private individuals and broker agencies can receive a fine which ranges between 250 € and 5,000 € for not publishing the required data regarding the EPCs.

In the period between the start of 2012 until the end of December 2016, 454 fines were imposed (139 of these in 2016).

2.IV. Inspection requirements – heating systems, air conditioning

Flanders has adopted inspections for both heating and AC systems.

2.IV.i. Progress and current status on heating systems

Boilers must be inspected for safety aspects as well as energy efficiency by a recognised technician before first use. Boilers with a nominal output of 20 kW and above must be maintained and inspected frequently by a recognised technician, who checks the safety and energy efficiency. If not compliant, the boiler must be adjusted or replaced. Finally, the recognised technician periodically checks the energy efficiency of the entire central heating system and suggests possible energy-saving methods (Table 7).

Type of inspectionFuelNominal powerWhen?What?By whom?*
Inspection before first utilisationGaseousAllBefore using a new or modifier boiler (e.g. replaced burner, modified chimney)Thorough inspection of several safety aspects and proper functioning of the boiler as defined by law, including adjustment of the boiler when deemed necessary.RTG
MaintenanceGaseous≥ 20 kWAt least every two yearsRTG
LiquidAt least each yearRTL
Heating auditGaseous

≥ 20 kW

and ≤

100 kW

At least every five yearsInspection of the entire heating system by means of specialised software, provided by the government, in order to determine energy-saving methods. By using this software, the energy efficiency of the entire heating installation is estimated.RTG
>100 kWAt least every four yearsRTH

≥ 20 kW

and ≤

100 kW

At least every five yearsRTL
>100 kWAt least every five yearsRTH
SolidAllAt least every five yearsRTH
* Abbreviations: RTG (recognised technician gaseous fuel), RTL (recognised technician liquid fuel), RTH (recognised technician heating audit), SC (skilled craftsman).

Table 7: Summary of inspection types on central heating systems powered by a boiler on gaseous, liquid or solid fuel.

All results of inspections are documented in reports. In 2017, a new web application will be launched allowing digital documentation of inspection results and storage of data in a central database as well as the generation of statistics on heating systems.

As of 1 January 2018, energy efficiency requirements of older boilers using gaseous fuels and premix-technology boilers using liquid fuels will be increased. A communication campaign was launched in 201514 (Figure 20).

Figure 20: Communication campaign website

2.IV.ii. Progress and current status on AC systems

AC systems with a cooling capacity above 12 kW require inspection within 12 months of commissioning and regular inspection by a recognised expert. The frequency of inspections is dependent on the nominal cooling capacity (Table 8). Since September 2016, the nominal cooling capacity is determined at the building level (previously at system level). A web application was developed in 2015 and supplied freely by the Flemish government to evaluate energy efficiency and the dimensioning of AC systems. This system generates a report including recommendations for cost-effective energy performance improvements.

Nominal cooling capacityFrequency of inspection
> 12 and < 50 kWevery 5 years
≥ 50 kW and <250 kWevery 3 years
≥ 250 kWevery 2 years

Table 8: Frequency of inspection of air-conditioning systems.

Since January 2015, only recognised experts that meet certain requirements, attend a specific training course and pass a specific exam are allowed to perform the inspections. Additional training every five years is required as well.

A communication campaign was launched in 201615 (Figure 21).

Figure 21: Communication campaign website

2.IV.iv. Enforcement and impact assessment of inspections

Enforcement and penalties

Municipal supervisors and supervisors of the police zones may sanction the owner or user of a heating or AC system when a mandatory inspection has not been carried out. A list of possible sanctions is included in the decree of 5 April 1995 concerning general provisions relating to environmental policy (e.g., a fine that depends on the kind of infraction). There are no statistics available on the use of these sanctions.

Quality control of inspection reports

As of 2017, the number of technicians recognised to inspect liquid or gaseous fuels exceeds 4,000 and 7,000, respectively. Since 2014, annually approximately 600 randomly selected recognised technicians as well as technicians against whom complaints have been made are subjected to quality control by an accredited inspection body, which is appointed by the government. If quality requirements are not met, the technician will be warned, fined or prosecuted and/or the recognition can be suspended or withdrawn (sanctions have been issued to 64 technicians since 2013). Non-recognised technicians performing any of the aforementioned mandatory inspections that are reported to the government are prosecuted (15 non-recognised persons have been prosecuted since 2013).

As of 2017, almost 120 AC-energy experts have been accredited. Recognised AC-energy experts must provide information on all inspections conducted in the last three years to the supervising government upon request. The government can suspend or withdraw the recognition in specific cases. At the beginning of 2017, a statistically significant number of issued reports are subjected to quality control by (an independent accredited inspection body appointed by) the government. No penalties have been levied yet.

Impact assessment

No impact assessment has been performed.

3. A success story in EPBD implementation

The housing stock of nearly 3 million houses is old, with poor average energy performance and a renovation rate of under 1% per year. Thirty-seven per cent (37%), or over 1 million, of the houses are below standard for comfort, health and safety as stated in current housing legislation (Vlaamse Wooncode van 15 juli 199716). On a total of more than 800,000 EPCs for existing residential buildings, 57% of houses built before 1970 show a dramatically low energy performance. The greenhouse gas emissions of residential buildings in the Flemish Region represent 13% of the total GHG emissions for the Flemish Region in 2014. The potential for energy savings and greenhouse gas reduction is enormous. The sector of building, energy and environmental services (25% of the GNP and 13% of employment), is a crucial partner for exploiting this potential and for raising the level of renovation from the actual 1% per year to 2.5 – 3% from 2020 onward.

The Energy Renovation Programme 2020, which since 2009 has been stimulating renovations in roof insulation, double glazing and efficient heating for all houses by 2020, is a leading force in energy efficiency and has a vital effect on society. In order to increase the level of ambition from fragmented towards deep renovation of all existing houses, the government decided to set up a multi-stakeholder partnership. Starting in December 2014, working groups of over 30 stakeholders, together with public authorities, prepared recommendations for a Renovation Pact, a long-term renovation strategy for the residential sector in Flanders. The Flemish government adopted this Renovation Pact in July 2015 and commissioned the Ministers of Energy, Environment and Housing to co-create a long-term coherent action plan. The overall strategy of the Renovation Pact is to put forward and implement a feasible, acceptable and ambitious long-term energy performance level that all residential buildings have to meet by 2050 at the latest, and to provide adequate supportive and normative instruments as well as marketing and action plans. Reaching this energy performance requirement would mean an average decrease of the energy performance indicator of between 65 and 85%.

This broad and continuous multi-stakeholder approach shaped the operational plan and roadmap for the Renovation Pact. This resulted in, amongst other things:

  • the definition of a long-term 2050 target for energy performance of Flemish houses;

  • the development of a concept of a Housing Passport that will serve from 2018 onward to monitor and register the evolution of every single home towards the long-term objective. As a unique electronic record, it will contain information about the energy performance (evolution), a renovation advice (also available in 2018) and data on housing quality and energy-saving investments, at the very least;

  • the start of a service design trajectory covering 2016-2017 for full availability in 2019 offering an EPC+ with a renovation advice.

  • the implementation of a Energy Poverty Programme on 4 March 2016 by the Flemish government, which approved a comprehensive action programme fighting energy poverty based on an inclusive approach of vulnerable families in the renovation strategies;

  • the approval by the Flemish government of a revised grant scheme which, since January 2017, focuses more on deep energetic retrofits, neighbourhood renovations and specific measures for vulnerable groups;

  • the development of a scientifically validated follow-up indicator for measuring the evolution towards the long-term goals for the Flemish housing market;

  • the setup of a communication campaign for the broad public.

In the next phase the focus will be on further developing and implementating products and tools, capacity building, demonstration projects and integration of policies (energy, housing, environmental planning and taxation).

4. Conclusions, future plans

Directive 2010/31/EU was a strong driver in getting the EPBD implementation to a higher level and increased ambition has been a driver for the Flanders region progress.

Requirements for new buildings were strengthened multiple times and the path to 2021 was laid out; the average energy performance of new buildings now improves every year. A good functioning enforcement strategy is one of the keys to this success. A close follow-up based on cost-optimality of this path to 2021 is foreseen with bi-annual cost-optimal studies. The roll-out of the NZEB action plan delivered a successful introduction of the NZEB level. Many frontrunner companies support the NZEB message.

At the end of 2016, almost 30% of the existing residential buildings had an EPC. Ninety-seven per cent (97%) of existing buildings have an EPC when rented or sold. Eighty-six per cent (86%) of a sample of controlled advertisements in 2016 complied with the requirements on the EPC. The Flemish Energy Agency puts a continuous effort to ameliorate the quality of the EPCs.

In order to increase the level of ambition from fragmented towards deep renovation of all existing houses, the government decided to set up a multi-stakeholder partnership: the Renovation Pact and new subsidy schemes incentivising multiple improvements and deep renovation.

Tools and accreditation schemes on inspections were improved over the past years to achieve a larger impact.


  1. The E-level is the level of global energy performance. It is the annual primary energy consumption divided by a reference consumption. The reference consumption for residential buildings is a regression formula based on the consumption of a set of buildings with reference measures in 2006.This level was set at E100. For non-residential buildings, the reference consumption is calculated on the same building geometry with a set of reference measures.






  7. The K-level is the level of global insulation of the building (as a whole). It includes thermal transmission through the building shell and through thermal bridges. It is also influenced by the compactness (ratio surface-volume) of the building.




  11. Full report on

  12. A building permit is needed for most new constructions, renovations and demolitions. Some works are exonerated, like the replacement of windows, the replacement of finishing materials with the same materials or the installation of solar panels. In some cases, a simple building permit is enough, and no energy performance requirements apply, e.g., adding a small window in the back façade. In most cases, an extensive permit is needed, with cooperation of an architect, e.g., when volumes change or when a construction problem needs to be fixed. In that case, the energy performance requirements are applied. However, there is no link with the building value or the ratio of the surface as defined in the EPBD.