The decarbonisation of the built environment plays a key role in achieving Europe's climate objectives. To accelerate this transition, the revised Energy Performance of Buildings Directive (EPBD IV) has been adopted. A key component of the directive is the tightening of requirements related to energy labels. So what are the changes introduced by EPBD IV and what do they mean for Dutch property owners and the wider real estate sector?

Legislation: what is changing? 

The first change already came into effect on 29 May 2026, when the design of the Dutch energy label was updated and expanded to include additional information on a building's energy performance.

The further implementation of EPBD IV into Dutch legislation will take place in three phases. The third phase, scheduled for 2030, introduces Minimum Energy Performance Standards (MEPS), with all non-residential buildings expected to require at least an energy label D by 2030.

A further revision is planned for 2030. At that point, the current labels A+ through A++++ will be abolished and replaced by a simplified rating scale ranging from G to A. Following this change, requirements are expected to become more stringent, with a minimum energy label C likely to be required from 2033 onwards.

Retail and hotels face a significant challenge

This aspect of EPBD IV presents a considerable challenge, particularly for the retail and hotel sectors. Our analysis of retail and hotel properties in the Netherlands shows that more than half of the total floor area does not comply with the future EPBD IV requirements, either because no energy label is available or because the current energy label does not meet the forthcoming MEPS standards.

As illustrated in the chart below, 49% of retail floor space in the Netherlands currently has no energy label, despite this being mandatory for all non-residential buildings. Since 29 May 2026, listed buildings are also required to have an energy label, meaning that these properties are already non-compliant with current legislation. The hotel sector faces a similar challenge, with 54% of hotel floor space lacking an energy label.

Source: Savills Data, Intelligence & Strategy (2026) 

There is also the requirement to achieve at least energy label D by 2030 and, most likely, a minimum energy label C by 2033, as presented by the Dutch government on 26 May 2026. Our analysis indicates that 4% of retail floor space currently has an energy label below the anticipated 2033 threshold. In the hotel sector, this share is larger, with almost 10% of total floor space falling below the expected requirements. Measures will therefore be needed to improve the energy performance of these retail and hotel properties. In addition, it is unlikely that all hotels and retail properties currently lacking an energy label will achieve an energy label C or higher once assessed.

It is noteworthy that the Dutch government has now established clear requirements for all non-residential real estate, effectively creating a level playing field across sectors. For retail buildings and hotels, which have historically received less attention in this area, the impact is likely to be more significant. As a result, both asset classes face a relatively substantial challenge.

Valuations under pressure

There is little doubt that improving the energy performance of buildings is an important step towards mitigating climate change. However, how this will ultimately be reflected in the market remains to be seen. When the minimum energy label requirement for the Dutch office sector was introduced in 2023, Savills research showed that occupiers were willing to pay higher rents for buildings with stronger energy performance credentials, while offices with an energy label D or lower were required to reflect a discount in their valuations.

We expect similar valuation impacts across other sectors that become subject to minimum energy performance requirements. According to Kees van Vilsteren, Director Valuations, green assets will increasingly become the market standard, while brown assets will need to account for sustainability-related CAPEX in their valuations. In practice, this is likely to result in a discount for less sustainable properties.

The retail sector differs slightly from other asset classes, as retail properties are often delivered in shell condition. As a result, a significant part of a property's energy label performance, particularly building installations and technical systems, is determined by the tenant. According to Daan Mulders, Director Retail at Savills Netherlands, landlords can start preparing for this now by incorporating sustainability-related provisions into their lease agreements.

From regulatory requirement to long-term strategy

The implementation of EPBD IV means that energy labels will play an increasingly important role in the real estate market. What started as a regulatory requirement is evolving into a factor that directly influences lettability, valuation and investment decisions. For owners of retail, hotel and other non-residential properties, it is therefore essential not to wait until the new requirements come into force. Property owners who gain insight into the performance of their portfolios today and proactively prepare for future requirements will be better positioned to navigate the changes that lie ahead.