Will consumption certificates become the bestseller?
Many owners expect the consumption certificate to become the cheaper standard from 2027: it is finally choosable for pure residential buildings and without the old Wärmeschutzverordnung-1977 special rule. At the same time it disappears for non-residential buildings when a new certificate is issued for sale, letting or renewal. Whether the cheaper option is also possible for you is what this article explains.
Legal status · Article 2 GModG
Promulgated on 28 July 2026 (Federal Law Gazette 2026 I No. 226). The certificate rules in this article apply from 1 January 2027 (Article 2). Overview: GModG promulgated — new energy certificate from 2027.
In diesem Artikel erfahren Sie …
Two worlds from 1 January 2027
First we clarify which buildings may still receive a consumption certificate after the cut-off date. From 1 January 2027, Article 2 of the Building Modernisation Act (GModG) rewrites the energy-certificate rules.
For pure residential buildings — more precisely: buildings used exclusively for residential purposes — the choice between a consumption certificate under Section 82 and a demand certificate under Section 81 is open once a new certificate is needed for sale, letting or renewal and the consumption data are available. The old special rule for small older homes with a building application before 1 November 1977 falls away; details are in the article Consumption certificate: choice for all residential buildings.
For non-residential buildings, sale, letting, leasing or renewal is different: Article 2 Section 80(3) sentence 2 requires a certificate based on an energy balance under Section 81. Section 82(1) allows the consumption certificate only for buildings used exclusively for residential purposes. Mixed use with a commercial share is usually no longer eligible for a consumption certificate either.
| Topic | Until 31 Dec 2026 | From 1 Jan 2027 (Art. 2) |
|---|---|---|
| Pure residential / exclusively residential use | Often demand-only for <5 units + building permit before 1 Nov 1977 (Wärmeschutzverordnung-1977 hurdle) | Choice consumption certificate § 82 or demand certificate § 81, if data are available |
| Non-residential on sale/letting | Consumption certificate under § 82 still possible | Demand balance § 81 only (§ 80(3) sentence 2) |
| Residential consumption data | ≥ 36 months; latest period ≤ 18 months | Annually over two years; latest period ≤ 18 months |
Until the end of 2026 the interim status remains in place: the Wärmeschutzverordnung-1977 hurdle in Section 80(3) GEG/GModG still applies, and a consumption certificate for non-residential buildings is still provided for in Section 82(2).
For pure residential buildings the entry gets easier
Because choice for residential buildings is newly regulated, it is worth looking at which data requirements are eased at the same time. The often-heard claim “everything gets stricter from 2027” does not apply to the final statute for pure residential buildings.
Choice instead of old-build compulsion. As long as Article 2 does not apply, many buildings with fewer than five dwellings and a building application before 1 November 1977 need a demand certificate — unless the 1977 thermal-insulation level is proven. From 1 January 2027 that special rule in Section 80(3) disappears. Then the consumption certificate is legally choosable if Section 82 is met.
Shorter period. Today Section 82(4) requires bills from a continuous 36-month period; the latest period may be no more than 18 months old. From 2027 Section 82 captures final energy consumption annually over two years, still with the 18-month limit for the latest period. Three billing periods become two annual windows — that lowers the entry hurdle for many owners with available heating-cost statements.
The monthly-data draft was dropped from the final Act. During the legislative process the wording “at least monthly over 24 consecutive months” appeared for a while. The promulgated version does not require that. The strict 24-monthly-values rule has thus been dropped. The hub article on promulgation explains the difference.
Energy carriers. Article 2 Section 82(1) expressly requires recording differentiated by energy carriers. Current Section 82(1) does not state that sentence the same way; primary-energy factors and the consumption-value notice already work with carrier rows. For buildings with several carriers, separation remains important; it is not a new hurdle.
| Rule | Today | From 1 Jan 2027 |
|---|---|---|
| Recording period | 36 months / three periods | Annually over two years |
| Currency of latest period | ≤ 18 months | ≤ 18 months (unchanged) |
| Monthly data over 24 months | Not law (draft only) | Not law — draft dropped |
| Energy carriers | PEF/forms already carrier-aware in practice | Explicitly “differentiated by energy carriers” in the statute |
Where the consumption certificate still fails
Despite the easing, data and occupancy limits remain at which consumption certificates still fail.
Insufficient consumption data. New builds need a demand certificate anyway. Without heating-cost statements, supplier bills or measurements for two annual periods, the demand certificate remains the pragmatic path. In multi-family houses the consumption certificate often fails on aggregation: Section 82 requires data for the whole building, not only one flat.
Mixed-use buildings. Even a shop or office share that excludes pure residential use usually leads to a demand certificate. “Predominantly residential” is no longer enough for Section 82 from 2027.
Vacancy. The law requires longer vacancies to be accounted for. The notice on energy consumption values in the residential stock of 29 March 2021 allows the procedure described there only if the vacancy factor is at most 30% (factor 0.3 under the notice formula). Above that the procedure does not apply — practically the consumption certificate falls away on that basis. The factor is area- and time-weighted and for heating only covers October to March. Whether a new notice from 2027 keeps the same threshold was still open at research time — until then the 2021 notice is the procedural basis.
Currency. If the latest billing period ended more than 18 months ago, current data for a consumption certificate under Section 82 are missing.
Anyone who still wants to issue under today’s rules before the cut-off finds the timeline in Order a consumption certificate now.
Decision guide — consumption certificate, demand certificate or Smart™
From the limits follows the practical mapping to a consumption certificate, a demand certificate or a comparison of both paths.
| Situation | Recommendation | Why |
|---|---|---|
| Exclusively residential + two annual periods per energy carrier + moderate vacancy | Consumption certificate | Choice plus lower-cost path when § 82 is met |
| Non-residential or mixed use | Demand certificate | Art. 2: consumption certificate only for exclusive residential; non-residential on sale/letting → § 81 |
| New build / no bills / vacancy factor > 30% | Demand certificate | Data basis or notice procedure missing |
| Unclear whether consumption certificate or demand certificate delivers the better class | Energyausweis Smart™ or certificate check | Compare both paths from one data set |
The certificate check classifies your case with a few answers. For pure residential buildings with two annual statements per energy carrier and manageable vacancy, the consumption certificate online is often the cheaper path. Missing data or mixed use means the demand certificate is the right path. If you want to compare both variants from one data set, Energyausweis Smart™ usually delivers the best class result for you.
Five steps to check whether the consumption certificate fits
The following checklist enables a quick classification before ordering.
Quick check before ordering
Frequently asked questions
When does the new choice for the consumption certificate apply?
From 1 January 2027 (Article 2 GModG). Until then the interim rules apply, including the Wärmeschutzverordnung-1977 special rule in Section 80(3).
Can non-residential buildings still get a consumption certificate from 2027?
For a new certificate on sale, letting or renewal, Article 2 Section 80(3) sentence 2 requires a demand-based balance under Section 81. Section 82 limits the consumption certificate to buildings used exclusively for residential purposes.
Are two annual statements enough instead of three periods?
Yes — from 2027 Section 82 requires annual consumption data over two years, not 36 months. The latest period may be no more than 18 months ago. Monthly 24-month series are not required by law.
What does a vacancy factor of 30% mean?
Under the 2021 notice the described vacancy procedure applies only if the vacancy factor is at most 30% (factor 0.3 under the area- and time-weighted formula; for heating only October to March).
Is energy-carrier separation new?
Yes — in the wording of Article 2 Section 82(1) the separation is stated expressly. In practice and on certificate forms, carriers and primary-energy factors were already handled separately. Multiple carriers still need clean evidence.
Which certificate is the right choice?
Use the certificate check to see which certificate types you can choose. With fitting residential and consumption data, you can choose between a consumption certificate, a demand certificate or Smart™.
We expect the consumption certificate to become the new bestseller for residential buildings from 2027 — fewer hurdles, and the option becomes more accessible. Many owners will welcome that, yet they should know: the demand certificate still delivers a clearly more objective assessment of the building’s energy performance and better guidance for modernisation. So the choice should not rest on certificate price alone, but above all on what you want to use the certificate for.