New mandatory disclosures on the energy certificate from 2027: What is new and what stays?

Joost Jansky

Energy consultant, blogger

Cut-off date and demarcation: certificate content is not the listing

From 1 January 2027, two questions must be answered separately: Which mandatory disclosures must appear on the energy certificate — and which in the property listing? § 85(1) governs the minimum catalogue on the certificate. § 87 governs the mandatory disclosures in the listing when a certificate exists and the listing appears in commercial media. Many listing fields come from the certificate — for example certificate type, date of issue, primary energy metric in kilowatt-hours per square metre and year, energy efficiency class, year of construction and main energy carriers. The certificate contains more: absolute annual quantities in megawatt-hours belong on the certificate (§ 85(1) nos. 23 and 24), not on the listing list under § 87. Mixing both lists produces wrongly cited mandatory fields for portals and exposés.

The new version of §§ 85 to 87 is in Article 2 and applies from 1 January 2027 under Article 9(2). Timeline, how that differs from Article 1 (heating) and the cut-off dates are in the GModG article series. The listing duty and transitional rules for older certificates are covered in depth in GModG for estate agents.

The format of the digital file is a separate question. The digital energy certificate from 2027 clarifies issuance and delivery.

Absolute energy metrics explains what sits behind the new MWh figures — still with an eye on the draft status there. Here the focus is the promulgated field catalogue in Article 2: what must appear on every certificate issued from the cut-off date.

What Section 85 Abs. 1 requires from 2027

The new minimum catalogue expands the certificate with absolute metrics, greenhouse gas disclosures and yes/no disclosures. Article 2 fully replaces the previous §§ 85 to 87 and lists numbers 1 to 31 in subsection 1. For reporting, the changes can be grouped into four clusters.

Absolute metrics in megawatt-hours

New are calculated primary energy and calculated annual final energy in megawatt-hours, plus generation from renewable sources in megawatt-hours including the main energy carrier and the type of renewable energy source (§ 85(1) nos. 23 and 24). These are absolute annual quantities. They sit alongside the specific values in kilowatt-hours per square metre and year that the catalogue continues to require. For prospective buyers and financing talks, the absolute values change the reading: from the annual quantity in megawatt-hours an energy-cost question can be derived, without those values therefore migrating into the listing list under § 87.

Operational and life-cycle greenhouse gas emissions

Operational greenhouse gas emissions in kilograms of carbon dioxide equivalent per square metre of useful floor area and year belong to the minimum catalogue from the cut-off (§ 85(1) no. 16). Subsection 2 points to the calculation rules and emission factors in Annex 9 for determination. That is the operations-related disclosure, not the life-cycle assessment over production and dismantling.

Separate from that are the life-cycle greenhouse gas emissions under the report pursuant to § 88b (§ 85(1) no. 17). They are shown as the total sum of phases A to C, but in stages: from 1 January 2028 the disclosure applies to buildings still to be constructed with more than 1,000 square metres of useful floor area. From 1 January 2030 it applies to all buildings still to be constructed. Merging nos. 16 and 17 in one sentence merges operational emissions with the life-cycle balance and sets the wrong cut-off.

Smart readiness and flow temperatures

Two yes/no disclosures complete the catalogue. Number 26 requires a disclosure on smart readiness — whether the building can respond to external signals and adjust energy consumption. Number 27 applies only if a heat distribution system is present in the building: then the certificate must state whether that system can be operated at low or efficient temperatures (§ 85(1) nos. 26 and 27). Both are mandatory disclosures on the certificate. They create neither a duty to install a heat pump nor a duty to fit smart-home equipment.

Further numbers remain part of the minimum catalogue, including the energy efficiency class under § 86, issuer data, registration number and modernisation recommendations under § 84. They are not the focus here because readers already know them from the existing certificate or because cluster articles already cover them.

Official template not yet published

The disclosures are in the statute; the form is still missing. § 85(3) tasks the Federal Ministry for Economic Affairs and Energy together with the Federal Ministry for Housing, Urban Development and Building with creating templates and publishing them in the Federal Gazette. As of October 2026, DIBt and BBSR report no new templates; the GEG 2024 templates still apply. A technical adaptation of the registration system is planned for 1 January 2027 (DIBt, BBSR templates).

What the press and issuers can do now

Anyone covering the cut-off or issuing certificates should keep three things apart: the statutory disclosures, the still-outstanding template and the listing duty under § 87. That also makes clear that older certificates do not become invalid merely because new fields are added. § 112(3) steers listing disclosures when a certificate issued before 1 January 2027 is present. The subsection does not require reissuance solely because of the new Section 85 catalogue (BGBl. 2026 I No. 226). Valid older certificates remain valid; what is new are the listing duties and, on new issuance from the cut-off, the expanded certificate content.

Newsrooms should check the four field groups against the statute, mark template status as open and keep the listing list in § 87 separate. Owners and issuers who plan an issuance occasion before or after the cut-off can use the certificate check or order the matching consumption certificate or demand certificate once the date is set.

How the catalogue can be classified

Frequently asked questions

What does Section 85 change on the energy certificate from 1 January 2027?

From 1 January 2027 the new minimum catalogue in § 85(1) GModG (Article 2) applies. Newly issued energy certificates must include, among other things, absolute metrics in megawatt-hours, operational greenhouse gas emissions and additional yes/no disclosures.

What do the new megawatt-hour disclosures mean?

Absolute annual quantities in megawatt-hours sit alongside the familiar values in kilowatt-hours per square metre and year. They make the building’s total demand readable — for rough energy-cost questions, for example — and belong on the certificate, not on the listing list under § 87.

How do nos. 16 and 17 differ?

Number 16 covers operational greenhouse gas emissions and applies with Article 2 from 1 January 2027. Number 17 covers life-cycle greenhouse gas emissions under § 88b and applies in stages from 2028 or 2030 for buildings still to be constructed.

Is there already a new official certificate template?

As of October 2026, no. § 85(3) requires publication in the Federal Gazette; DIBt and BBSR still report the GEG-2024 templates. Through end-2026 authorities often still cite the template empowerment as subsection 8; from 1 January 2027 the same duty sits in subsection 3 of the new version.

Must existing energy certificates be reissued because of the new mandatory disclosures?

No. The new field catalogue in § 85 alone does not create a duty to reissue certificates issued before 1 January 2027. For listings that use such certificates, § 112(3) applies.

What belongs in the listing, and what only on the certificate?

§ 87 regulates mandatory disclosures in the property listing. The full minimum catalogue is in § 85(1). Absolute megawatt-hour values belong on the certificate, not on the § 87 list.

Summary and outlook

That is the legally reliable minimum catalogue from January 2027: absolute megawatt-hours, operational and later life-cycle greenhouse gas emissions, the yes/no smart-readiness disclosure (adaptability to external signals) and the disclosure on low or efficient temperatures. Added to that is the clear boundary to the property listing: not everything on the certificate must also appear in the ad. For now, only the official template in the Federal Gazette remains open.

The new absolute figures will matter most for how buildings are read. The efficiency class remains a per-square-metre value; the megawatt-hour line shows the annual demand of the whole building. Even a highly efficient house can consume a lot of energy in absolute terms if the floor area is large — and then stand out in the MWh disclosure. Whether that prompts a rethink of living-space consumption in the long run remains to be seen.