The new standard for building improvement: what EPBD IV and GACS mean for real estate
The improvement of the built environment has entered a new phase. Where legislation has long focused on theoretical performance and minimum standards on paper, the emphasis is now shifting to real energy savings in practice. With the tightening of the Energy Performance of Buildings Directive (EPBD) and the introduction of obligations related to GACS, the focus is moving towards insight into actual energy use, continuous monitoring and smart building control. This marks the new standard. In this article, we explore what EPBD and GACS require from property owners and organisations, and which steps are now relevant.
Central to this development is the revision of the Energy Performance of Buildings Directive (EPBD IV). This European directive forms the basis for a range of new obligations in the Netherlands, including stricter requirements for building services, inspections and the use of building automation. One of the most impactful elements is the obligation related to GACS: Building Automation and Control Systems.
From saving energy to managing energy
For a long time, building improvement efforts focused primarily on measures such as insulation, solar panels and replacing installations. These remain important and necessary steps, but they are no longer sufficient on their own. New legislation requires insight into how buildings actually perform. Not just on paper, but in day-to-day operation.
Buildings must be able to measure, analyse and actively control energy use. This applies not only to large real estate portfolios, but also to individual buildings with high energy consumption. As a result, improvement is shifting from a one-off investment to a continuous process.
GACS: smart automation as a legal obligation
For buildings with an installed heating or cooling capacity exceeding 290 kW, GACS is mandatory. This primarily affects property owners, asset managers and organisations with energy-intensive buildings or large technical installations. GACS systems ensure that energy use is structurally monitored and optimised. They provide insight into system performance, detect inefficiencies and enable active control. In addition, they play an important role in safeguarding indoor environmental quality, such as temperature and ventilation.
What makes GACS particularly relevant is that buildings that comply with these requirements may be exempt from certain EPBD inspections. Smart automation is therefore not only a legal obligation, but also a way to reduce administrative burden while maintaining control over energy costs and building performance.
At the same time, this legislation also creates opportunities for financial support. Various subsidy schemes and funding mechanisms align with investments in monitoring, building services and energy efficiency. See here for an overview of the key Dutch subsidies and regulations for real estate improvement in 2026.
EPCs, reporting and transparency
For offices, the requirement to hold at least an EPC C in order to remain in use is already in force. However, this requirement is only the starting point of a broader shift towards transparency and demonstrable improvement.
Organisations are increasingly being held accountable for their actual carbon emissions, both within buildings and beyond. A reporting obligation now applies to carbon emissions from business travel and employee commuting. In addition, the Energy Saving Obligation (EML) remains in force, requiring measures with a payback period of less than five years to be implemented. The associated audit obligation further compels organisations to actively explore additional opportunities for energy and carbon reduction.
Legislation as an accelerator for future-proof real estate
Taken together, these regulations leave little room for doubt. Improvement is no longer a standalone project, but an integral part of property management and organisational policy. Data, monitoring and smart control have become the new standard.
Buildings that act on this now are better prepared for future requirements and benefit at the same time from lower energy costs and increased comfort. GACS plays a key role in this transition: not as an end goal, but as a foundation for future-proof real estate that keeps pace with both regulation and ambition.
CFP as a partner in complex regulation
CFP Green Buildings supports organisations in navigating rapidly changing legislation by connecting strategy, data and real estate. We translate complex regulatory requirements into concrete, achievable actions for both property portfolios and business operations.
From insight into GACS obligations and EPBD requirements to data-driven improvement strategies that go beyond compliance, we help turn regulation into action for your real estate. Get in touch with us for tailored advice.
