Energy certificate in listings from 2027: old or new certificate

Joost Jansky

Energy consultant, blogger

Issue date on the PDF: old or new path

From 1 January 2027 the law distinguishes two worlds — not by the day you click “Publish”, but by the issue date on the energy certificate. If a valid certificate was issued before 1 January 2027, § 112 (3) GModG governs the mandatory listing disclosures. If it was issued from 1 January 2027, § 87 GModG applies.

So check page 1 of the PDF before you fill fields on ImmobilienScout, classifieds sites or your agent portal. Mix up final and primary energy and the ad is wrong — even when the certificate itself is fine. Fine and warning-letter risks for agents are summarised in GModG for estate agents; here the focus is your checklist at the portal.

What must appear on the certificate is a separate chapter: the minimum catalogue in § 85 (1) applies to newly issued PDFs — not every line belongs in the listing.

Old path: final energy under § 112 (3)

For certificates with an issue date before 1 January 2027, § 112 (3) requires among other things:

1. the type of certificate (demand or consumption),
2. the final energy demand or final energy consumption stated on the certificate,
3. the main heating energy carriers,
4. for homes the year of construction, and
5. for homes the efficiency class.

In short: the listing keeps the figure you know from the certificate — final energy, not primary energy. That also applies when you publish the ad in 2027. A valid 2019 certificate does not automatically move to the new path.

Reissue: The expanded § 85 catalogue alone does not oblige you to reissue a valid old certificate. Details are in new mandatory certificate disclosures from 2027.

New path: primary energy under § 87

If the certificate was issued from 1 January 2027 and is available when you advertise, § 87 requires among other things:

1. whether the certificate was issued under § 81 or § 82,
2. the issue date,
3. annual primary energy demand in kilowatt-hours per square metre of usable area and year,
4. the efficiency class,
5. the year of construction (homes), and
6. the main heating energy carriers.

Absolute megawatt-hour annual amounts appear on the certificate under § 85 — they do not belong in the § 87 listing fields. Copying MWh values into the portal mixes certificate content with listing duties.

Do not show final and primary energy at the same time as mandatory listing figures. The path follows the issue date, not whichever number looks better.

Checklist: which figure goes in the portal field

Scenario: 2019 certificate and a 2027 listing

You sell a terraced house in 2027. The certificate is from 2019 and still valid. The listing follows § 112 (3): final energy demand, certificate type, carriers, year of construction, class — as today. You do not need a new certificate just because § 87 applies to certificates issued from 2027.

Voluntary reissue is still possible. The new issue date then decides:

• Issue in December 2026 → still the old path (final energy in the listing) when you keep using the old certificate; a replacement issued in Dec 2026 still counts as before the cut-off.
• Issue in January 2027 → mandatory disclosures under § 87 with primary energy in the listing.

When a demand certificate is mandatory depends on the building — not on the listing path alone.

Why class and kWh value do not always match

Many portals show the coloured efficiency class next to the kWh figure. For homes § 86 derives the class from final energy — while on the new path the listing shows primary energy. Primary energy factors (briefly explained in the agent guide) can pull the values apart: heat-pump homes often look “worse” in the listing, pellet often “better”, although the class is based on final energy.

That is not a portal bug but the legal split between listing indicator and class logic. Check: does the number match the chosen path (final vs primary)? Does the class roughly fit the certificate? If not, the fault is usually data entry — not a “wrong” certificate.

How to publish your listing in line with the law

When PDF and portal are ready, six steps are enough:

1. Note the issue date on the certificate — not the publication date of the ad.
2. Set the path: before 1 Jan 2027 → § 112 (3) with final energy; from 1 Jan 2027 → § 87 with primary energy kWh/(m²·a).
3. Transfer mandatory fields from the PDF (type, carriers, year of construction, class) — no MWh values.
4. Check plausibility: class and kWh should roughly align; with heat pumps compare final and primary energy on the certificate.
5. Clarify responsibility: whoever publishes must ensure the § 87 disclosures — often you and your agent together.
6. Publish only when all fields fit — or run the certificate check and order a consumption or demand certificate first.

Estate agencies and platform operators

If you maintain CRM or listing modules, the two-path logic is error-prone: the same screen must pre-fill final energy or primary energy depending on issue date. The Energyausweis API returns § 87-relevant figures as structured JSON for listing fields; GModG 2027 updates — mandatory fields, calculation norms such as DIN/TS 18599:2025-10 — arrive via API versioning without you mirroring issuance logic.

• API product page and Try-out
• Energyausweis API guide
• Agencies, property managers and API

Straight talk: The API does not replace listing responsibility under § 87 — whoever publishes remains responsible for complete mandatory disclosures.

Frequently asked questions

Can I still use an old energy certificate in a listing from 2027?

Yes, while it is valid. Certificates issued before 1 January 2027 follow § 112 (3) with final energy — not the primary-energy duty of § 87 for newly issued certificates.

Do I need a new certificate because of the GModG reform?

No — the new § 85 catalogue alone does not force reissue of valid old certificates. If a new certificate is issued from 1 January 2027, the listing must use the mandatory fields under § 87.

Do megawatt-hour values belong in the listing?

No. Absolute MWh annual amounts sit on the certificate (§ 85), not in the § 87 listing list.

Who is liable for wrong energy figures in the listing?

§ 87 names sellers, landlords and agents when one of them is responsible for publication. Details on fines and warnings: GModG for estate agents.

Why do class and kWh sometimes not match?

For homes the class follows final energy while new listings show primary energy — the figures can therefore diverge.

Summary

For your listing the issue date on the PDF matters: old certificate → final energy under § 112 (3), new certificate → primary energy under § 87 — without absolute MWh values from § 85. Valid old certificates remain usable. If a new certificate is issued from 1 January 2027, the listing must use the mandatory fields under § 87.

Legal note. Promulgated GModG (BGBl. 2026 I No. 226); Article 2 from 1 January 2027. Not legal advice.