GModG draft 2026: The quiet announcement of a major energy certificate reform
The government draft bill published on 5 May 2026 introduces targeted amendments to Germany's building energy framework and sends a clear signal: energy certificate rules are likely to be revisited in a broader reform round.
This article explains what was already concrete in the draft, what was still open then, and how the promulgated Act has since superseded that early stage.
The government draft bill is a historical working basis — since superseded by parliamentary passage, promulgation and the final text (authoritative: BGBl. 2026 I No. 226): Government draft bill from 5 May 2026 (BMWK, original PDF). We also summarised the energy-certificate-relevant points in a structured briefing: Brief summary of key changes (free PDF).
In this article
- What was published on 5 May 2026 – and what it means legally
- The targeted energy certificate changes in the draft
- Practical effects on the official certificate document
- The major gaps on the EU directive: what the draft does not yet deliver
- Timeline 2026: what is known – and what remains uncertain
- The hidden major signal: “fundamental revision at the next opportunity”
- Conclusion: tighten processes now, prepare for bigger structural change
The 5 May reference draft is historical backstory: the Bundestag and Bundesrat passed the GModG on 10 July 2026; the Act was promulgated on 28 July 2026 ( BGBl. 2026 I No. 226 ). Article 1 has applied since 29 July 2026; Article 2 (EPBD energy certificates) from 1 January 2027.
Key draft→law deltas on § 82: instead of “24 months monthly”, the final text requires annual consumption data by energy carrier over two years; latest period ≤ 18 months (not 15). Consumption certificates only for exclusively residential use; mixed use → demand § 81.
Cabinet draft of 13 May 2026 (interim station): Annex 10 (A+–H) unchanged; EU scale A–G only for non-residential (Annex 10a). Fact check
What was published on 5 May 2026 – and what it means legally
The government draft bill published on 5 May 2026 was not final law and not a casual discussion paper either. In legislative practice, a draft at this stage often showed which priorities would shape the framework. That is why it still matters as an archive of the backstory.
A clear legal reading remains essential: between draft and final law sat political coordination, revisions and detail changes — including on § 82 (data rule) and Article 2 timing. Practice today follows the promulgated Act, not the draft; this article keeps the early signals.
In short: this draft indicated direction, not final legal closure — and that closure has since arrived (see the update box and hub article).
The targeted energy certificate changes in the draft
The strongest practical impact comes from how rule logic, issuer eligibility and evidence requirements are increasingly linked. The text may look technical, but its effect is highly operational.
More unified rule architecture via sections 71 ff.
The draft aligns core requirements for renewable-heat-related logic more systematically around sections 71 ff. of the government draft bill framework. This reduces the old split logic between new buildings and existing stock and creates a more consistent base for certificate-related evaluations.
Stronger importance of renewable energy type disclosures
The draft gives broader relevance to stating the type of renewable energy used. In practice, this pushes issuers from simple field-filling towards traceable justification of entries.
Clearer issuer and evidence framework
With changes around section 88 (issuer eligibility) and section 96 (evidence and retention), the documentation standard becomes more formal. This improves legal certainty but also increases operational workload in data intake and evidence handling.
Practical effects on the official certificate document
In day-to-day work, the pressure for verifiable entries increases. Sensitive fields include renewable energy type, compliance logic and documented evidence sources. This moves the certificate further from a simple output sheet toward a reviewable evidence-backed document.
For issuers, owners, managers and brokers, structured records become more important while rough estimates become riskier. Teams should therefore standardise evidence checks early: what is documented, what is plausible, and what is defensible under review.
The major gaps on the EU directive: what the draft does not yet deliver
On central EU implementation questions, the government draft bill is largely silent. Operational details on harmonised comparability, transition logic and methodology are not addressed in the draft bill.
That is not a side topic. For market actors, those details determine how new and old certificate regimes coexist in real workflows and transactions.
If you want deeper context on those open points:
- Will energy certificates become invalid from May 2026?
- Will the new A-to-G scale improve comparability?
- Energy certificate 2026: new A-G scale and extended obligations
Timeline 2026: what is known – and what remains uncertain
At the time of the reference draft, mainly the publication date was secure; political coordination, final wording and operational detail still looked uncertain. The rhythm is now clear: vote 10 July 2026, promulgation 28 July 2026, Article 2 from 1 January 2027. What this section called “open” refers to the draft phase — not today’s legal status.
Historically, a scenario-based approach helped: prepare early, medium and late paths rather than assuming a single fixed timeline. Those scenarios can now be tied to the fixed cut-offs.
The hidden major signal: “fundamental revision at the next opportunity”
One sentence in the reasoning is strategically important: the certificate framework is to be fundamentally revised at the next opportunity. That strongly suggests a second reform stage.
This makes the current package more than a technical patch. It looks like a bridge between today's targeted adjustments and a broader redesign still to come.
Conclusion: tighten processes now, prepare for bigger structural change
The draft introduced targeted changes with immediate practical relevance while leaving key EU harmonisation details and the then-current timeline open. The broader reform stage announced there is now concrete as the promulgated GModG with Article 2 from 1 January 2027 — this text remains the trace of the early signals.
A pragmatic strategy today: align processes with the final text and cut-offs (hub article); do not read historical draft wording as current law.
Preview: Brief summary of key changes
Free PDF
Click to open the complete one-page PDF summary.