Building Modernisation Act, GEG 2026, Energy certificate

Will energy certificates be invalid from May 2026? What the EU rules mean

Author photo
Lea Foster
Energieeffizienz-Expertin, Content-Managerin

You are planning a sale, new rental or lease renewal in 2026 – and wondering: Will my energy certificate with the old A+ to H scale still be accepted? This question concerns owners, brokers and managers. There is no binding answer yet: The EU Building Directive must be transposed by the end of May 2026. How Germany regulates the validity of existing certificates is still pending.

Energy certificate from May 2026: Validity of old certificates – EU rules (EPBD) and two scenarios for owners and managers

In this article we summarise what is certain, which two scenarios are plausible and what you should do now regardless – factually and with clear separation of facts and possible scenarios.

The revised EU Building Directive (EPBD) has been in force since May 2024 and must be transposed into national law by all member states by 29 May 2026. In Germany this is to be done via an amendment to the Building Energy Act (GEG), planned as the Building Modernisation Act (GMG). The coalition committee of the federal government confirmed the timeline on 10 December 2025: key points by end of January 2026, cabinet by end of February 2026. A draft law for the GMG is not yet available – so the question of whether existing energy certificates will become invalid from May 2026 is legally still open.

In this article

The starting point: EU deadline May 2026 and open national regulation

What the EPBD requires for energy certificates

The EPBD (Energy Performance of Buildings Directive) requires, among other things, a harmonised energy efficiency scale A to G for all member states: Class A corresponds to zero-emission buildings, Class G to the worst 15 percent of the national building stock. In addition, the presentation duty is extended – in future an energy certificate is also to be required for lease renewal and for major renovations (e.g. more than a quarter of the building envelope or building value). However, the directive does not explicitly require whether certificates already issued with the old scale (A+ to H) become invalid from the deadline.

Germany: GMG draft missing – validity question still open

Whether and how the energy certificate will be affected in detail by national implementation is not foreseeable due to lack of a draft law. Binding statements on the validity of old certificates are not possible at present. The concrete regulation – whether with transition period, whether with continuation or whether with immediate invalidity – will only be decided by the Building Modernisation Act.

Will existing energy certificates become invalid from May 2026?

What is certain: New scale A–G and extended duties

What is certain: From the national implementation of the EPBD, new requirements apply to energy certificates. Newly issued certificates must use the A to G scale and contain the required information. The extended presentation duty (e.g. for lease renewal and major renovation) is added – regardless of how the validity of old certificates is regulated.

What is unclear: Transition for old certificates (scale A+ to H)

Unclear is whether certificates already issued with the A+ to H scale become invalid from a deadline (e.g. May 2026) or whether they may continue to be used until their ten-year validity expires. The EPBD does not specify this; the decision lies with national implementation.

Two plausible scenarios at a glance

In the specialist literature and reporting, essentially two interpretations are represented:

  • Scenario A: Old certificates (A+ to H scale) lose their validity from May 2026 (or after a short transition period). For sale, rental or lease renewal, a new certificate according to the new standards would then have to be presented.
  • Scenario B: Existing certificates remain valid until the end of their 10-year validity. Only newly issued certificates would have to meet the A to G scale and the other new requirements – comparable to previous amendments (EnEV 2009, EnEV 2014, GEG 2021).

Both scenarios are currently not binding; only the GMG draft and the passed law will provide clarity.

In short: Whether old certificates become invalid from May 2026 is legally still open. Two interpretations are plausible – below the respective consequences.

Scenario A: Old certificates lose their validity

What would happen if the legislator declares old certificates invalid from the deadline (or after a short period)?

If the legislator opts for immediate or near-term invalidity of old certificates, this would have practical consequences: For every sale, every new rental and every lease renewal (which becomes certificate-mandatory from 2026 anyway) a new energy certificate with A to G scale would have to be presented. Brokers and managers would have to check whether the existing certificate still meets the requirements. Those who do not present a valid certificate risk fines of up to €10,000.

Practical example: A sale or lease renewal that takes place in May 2026 or later could then only be lawful with an energy certificate issued under the new law – even if the old certificate would not formally have expired yet.

Takeaway (Scenario A): If you are planning a transaction in 2026, you should plan for a new energy certificate in good time – this way you are on the safe side in any case.

Scenario B: Continuation until expiry of 10 years

The other possible line: Existing certificates retain their validity.

Several sources assume that existing energy certificates continue to be recognised until their ten-year validity expires. Reasoning: With previous amendments (EnEV 2009, EnEV 2014, GEG 2021), old certificates remained valid each time; only newly issued certificates had to meet the new requirements. A comparable solution would also be conceivable for 2026.

In this case, the old A+ to H scale would remain in circulation for several more years, because energy certificates are valid for ten years. New certificates would be issued exclusively with the A to G scale.

Takeaway (Scenario B): Even with continuation, you will need a (new) certificate in many cases – namely whenever you renew leases or carry out major renovations (see next section).

Extended presentation duty from 2026 – independent of validity

Regardless of which regulation comes for old certificates: One change affects everyone equally.

Regardless of whether old certificates become invalid or not: From the implementation of the EPBD, the extended presentation duty applies. An energy certificate is then also required for

  • Lease renewal and
  • Major renovations (e.g. if more than a quarter of the building envelope is refurbished or the measures affect a quarter of the building value).

What exactly counts as a "major renovation" will be determined by national implementation. For owners and managers this means: In these cases a (possibly new) energy certificate will be needed in future – regardless of whether the existing certificate becomes "invalid" or not.

Example: A landlord with several apartments renews several leases in 2026. From implementation of the EPBD, they must present an energy certificate – in practice usually one issued under the new law. The extended duty therefore applies regardless of the validity question.

A detailed overview of all changes in 2026 – new scale, extended duties, digital database, greenhouse potential – is provided by the article Energy certificate 2026: New A–G scale and extended duties.

What owners, brokers and managers should do now

Even without binding clarity on the validity of old certificates, you can prepare.

For planned transaction: plan new certificate in good time

If you are selling, renting out newly or renewing leases in 2026, you should check in good time whether a new energy certificate is needed. Even if Scenario B (continuation) is implemented: For lease renewal and major renovation, the EPBD requires an energy certificate anyway – in practice this will usually be a certificate issued under the new law. Timely planning avoids bottlenecks with energy experts and keeps you legally safe.

Voluntarily switch to the new scale?

It can make sense to voluntarily have an energy certificate issued according to the new A to G scale – even if the old certificate would still be valid. This allows better comparison of your properties with buildings that already have a certificate under the new standard. You also signal to potential buyers or tenants that you as an owner are up to date; this can have a positive effect on sales and marketing.

Keep costs and deadlines in mind

Energy certificates are valid for ten years. The costs for a new certificate are typically in the range of around €150 to €500 depending on building and certificate type (Cost comparison of various providers). For violations of the certificate duty, fines of up to €10,000 can be imposed. Keep an eye on the development of the GMG: The key points (end of January 2026) and the planned draft law (end of February 2026) will answer many open questions.

Conclusion: Clarity will come with the Building Modernisation Act

Will energy certificates be invalid from May 2026? Three points to note:

  1. Binding answer is still missing. It will only come with the Building Modernisation Act (GMG).
  2. Two scenarios are plausible: Old certificates become invalid from the deadline (or after transition period) – or they remain recognised until their ten-year validity expires.
  3. Regardless: The new A to G scale and the extended presentation duty (e.g. for lease renewal and major renovation) are coming. Those selling, renting or renewing leases in 2026 should inform themselves in good time and plan for a new energy certificate if needed.

Find out more with the article Energy certificate 2026: New A–G scale and extended duties for an overview of all changes.