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Construction & Real Estate · EU Taxonomy Activity Guide

Buildings: construction and renovation under the EU Taxonomy

Real estate is where the Taxonomy meets the largest asset class in most portfolios. Three activities do the work: new construction (judged against near zero-energy performance), major renovation (judged by energy improvement), and building acquisition (judged by energy performance certificates). The tests are precise, the evidence is standard industry documentation, and the volume of assessable assets is enormous.

Activity ID
CCM 7.1 / 7.2 / 7.7
NACE code
F41 / L68
Objective
Climate change mitigation
Sector
Construction and Real Estate
01

Why this activity matters

Buildings account for roughly forty percent of EU energy consumption, which is why the renovation wave and energy performance regulation sit at the centre of EU climate policy. The Taxonomy translates that into asset-level tests that lenders, funds and developers can apply: mortgage books, green bonds backed by real estate, Article 8 and 9 property funds and development financing all lean on these criteria.

The three activities serve different moments in the asset lifecycle. New construction must beat the national nearly zero-energy building requirement by a margin (with air-tightness testing and life-cycle carbon reporting for larger buildings). Major renovation must either meet the applicable major-renovation standard or deliver a substantial primary energy demand reduction (on the order of thirty percent). Acquisition and ownership qualifies for top-performing stock, evidenced through EPCs (broadly class A, or demonstrably within the top fifteen percent of the national stock for pre-2021 buildings). Because the evidence is standardised, buildings are among the fastest activities to assess at scale.

02

What alignment requires

Each lifecycle stage has its own test, all rooted in measurable energy performance. In summary:

AreaWhat is required (summarised)
New construction (7.1)Primary energy demand must beat the national NZEB requirement by the required margin (on the order of ten percent), with air-tightness and thermal integrity testing, and life-cycle GWP calculation for large buildings.
Major renovation (7.2)The renovation meets the applicable major-renovation energy standard, or delivers a substantial reduction in primary energy demand, on the order of thirty percent, evidenced by before/after assessment.
Acquisition & ownership (7.7)For buildings built before 2021: EPC class A, or evidence the building sits within the top performance band of the national stock. For newer buildings, the new-construction criteria apply.

Summarised for orientation; the assessment itself applies the full criteria text of the Delegated Acts as amended.

03

Where DNSH scrutiny falls

Climate adaptation

CRVA for the asset or portfolio; flood exposure and overheating risk are the standard items for buildings.

Water

Specified water-efficient fittings for sanitary appliances in new builds and renovations.

Circular economy

Construction and demolition waste: high reuse/recycling rates and, for new builds, design-for-adaptability considerations.

Pollution

Restrictions on hazardous substances in construction products, and emissions limits for materials (e.g. formaldehyde, VOCs) in new builds and renovations.

04

Documentation that typically supports the assessment

05

How Censatim assesses it

Buildings assessments are evidence-led and fast: the tests reduce to documented energy figures against known benchmarks, so our questioning targets the EPC or energy calculation, the applicable national NZEB baseline, and the DNSH items above. For portfolios, the same logic applies asset by asset, which is exactly the use case our forthcoming portfolio mode is designed for.

Censatim is an expert-built EU Taxonomy assessment tool: describe the asset or activity in plain language, upload supporting documents, and answer a short set of targeted questions. The result is a criterion-by-criterion view with an In-line / Partial / Not aligned / Undetermined rating and a confidence level for each dimension. See the full methodology.

06

Frequently asked questions

What EPC rating does a building need for EU Taxonomy alignment?

For buildings built before 2021, acquisition and ownership qualifies with an EPC of class A, or alternatively with evidence that the building is within the top band (broadly the top fifteen percent) of the national building stock by primary energy demand. National implementations vary, which is why the comparison evidence matters.

What does NZEB minus 10% mean for new buildings?

New construction qualifies where the building’s primary energy demand is at least the required margin, on the order of ten percent, below the national nearly zero-energy building (NZEB) requirement. It is a relative test against each country’s own NZEB baseline, not one absolute EU-wide number.

How does a renovation qualify under the EU Taxonomy?

Either by meeting the applicable requirements for major renovations under national energy performance rules, or by delivering a substantial reduction in primary energy demand, on the order of thirty percent, demonstrated through a before-and-after energy assessment.

Can a whole real estate portfolio be assessed for Taxonomy alignment?

Yes, and buildings are the classic portfolio case because the tests are standardised around EPCs and energy calculations. Each asset is assessed against the criteria for its situation (new, renovated, or acquired), then results roll up to portfolio-level aligned percentages for reporting or financing.

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