The Brussels Region is preparing a major reform of the EPC (Energy Performance Certificate) in co-ownership buildings. From 2033, units rated F or G could generate fines of up to EUR 31,250 per flat — EUR 62,500 for two top-floor flats. Here is what every manager of Brussels co-ownership buildings needs to know and plan for now.
What will the Brussels EPC reform change for co-ownership buildings?
The Brussels EPC reform, expected in late 2026 or 2027, introduces three structural changes for co-ownership buildings: merging the roles of EPC certifier and EPC adviser into a single expert, requiring one certificate per unit, and creating a summary report for the whole building. This report will explicitly identify units that do not comply with the regulatory deadlines.
These measures are based on the ordinance of 7 March 2024 amending the Brussels Air, Climate and Energy Management Code (CoBrACE), as well as the decrees of 3 July 2025 on the EPC expert, indicators, and requirements.
The merger of roles: the single EPC expert
Today, two roles coexist in Brussels: the EPC certifier (who issues certificates) and the EPC adviser (who recommends works). The reform merges these two roles into a single professional: the EPC expert.
Each co-ownership building will need to appoint a single EPC expert for the whole building. This centralisation aims to ensure a coherent view of the energy performance of the entire building and to facilitate the planning of works.
The new documentation requirements
| Document | Requirement | Scope |
|---|---|---|
| EPC certificate | 1 per unit (flat, office, commercial) | Individual |
| EPC summary report | 1 per co-ownership | Entire building |
| List of violations | Included in the summary report | Non-compliant units |
The summary report will be the central management tool for property managers and general meetings. It will allow you to see at a glance which units require priority action before the deadlines.
What are the deadlines and how are fines calculated?
EPC fines in Brussels co-ownership buildings follow a two-stage calendar, with declining energy consumption thresholds. The calculation is based on exceeding the permitted threshold, capped at an overshoot of 125 kWh/m².
The penalty calendar
| Deadline | Target | Energy consumption threshold | Penalty if exceeded |
|---|---|---|---|
| 2033 (indicative) | Elimination of F and G | 275 kWh/m²/year | Fine calculated on the overshoot |
| 2043 (indicative) | Elimination of D and E | 150 kWh/m²/year | Fine calculated on the overshoot |
The calculation formula
Fine = EUR 2.50 x overshoot (capped at 125 kWh/m²) x floor area (m²)
The overshoot is the difference between actual consumption and the permitted threshold. It is capped at 125 kWh/m², meaning even a very energy-inefficient flat cannot generate a fine above the ceiling calculated on this basis.
A concrete example: a 10-unit building
Consider a co-ownership building of 10 flats, where 2 top-floor flats have an EPC rating of 425 kWh/m²/year, each measuring 100 m².
Calculation per flat in 2033:
- Current consumption: 425 kWh/m²/year
- Permitted threshold: 275 kWh/m²/year
- Overshoot: 425 − 275 = 150 kWh/m² (capped at 125 kWh/m²)
- Fine: EUR 2.50 × 125 × 100 m² = EUR 31,250 per flat
Consequence for the co-ownership:
- Total for the 2 non-compliant flats: EUR 62,500
- Apportioned according to ownership shares
- A co-owner holding 100/1,000ths: EUR 6,250 out of pocket
These figures illustrate why EPC fines will cost far more than the insulation works. Roof replacement or under-roof insulation typically costs between EUR 8,000 and EUR 20,000 per flat — two to four times less than the potential fine.
The new climate tables: good news for 2027
Brussels Environment will adopt new climate reference tables by 2027. These tables recalibrate reference values using updated climate data, which should mechanically improve the EPC scores of many buildings.
What this means in practice
A flat currently rated F in 2025 could move to class D in 2027 without any works being carried out. The exact improvement depends on the specific configuration of each building (orientation, compactness, heating type), but available simulations show gains of 1 to 2 classes for buildings where overconsumption is mainly due to climate calculation biases.
Implication for property managers: it may be strategic to wait until 2027 to obtain new EPC certificates for your units, rather than launching works based on certificates issued under the old tables. A flat that moves from F to D with the new tables will no longer face the urgency of the 2033 deadline.
The impact of photovoltaic panels: the rules are changing
The treatment of solar panels in EPC calculations will change significantly after 2027.
Before 2027 (current system)
Solar production is fully deducted from the total consumption of the property. This artificially improves the EPC score, sometimes excessively. A fuel oil-heated flat with 12 solar panels may display a score two classes above what it would show without panels.
After 2027 (new system)
Photovoltaic production will only be deducted from electricity consumption, not from heating consumption (fuel oil, gas). This rule brings the EPC score closer to the building's actual energy reality.
| Property type | EPC gain with panels today | EPC gain with panels after 2027 |
|---|---|---|
| Fuel oil or gas heating | D → B (2 classes) | D → C (1 class) |
| Heat pump | D → B (2 classes) | D → B (unchanged, full gain maintained) |
Favourable exception: properties equipped with a heat pump will retain the full photovoltaic benefit, since their consumption is almost entirely electric. This is an additional argument in favour of switching to heat pumps in Brussels co-ownership buildings.
What property managers must do now
The Brussels EPC reform will not take effect until 2026–2027, but energy renovation works take time to plan and to put to a general meeting vote. Anticipation is the only viable strategy.
1. Assess the exposure of each co-ownership building
Start by identifying units with an EPC rating of F or G in your Brussels buildings. These are the most exposed to the 2033 fine. For units without a certificate, schedule an energy audit.
Questions to ask for each building:
- How many units are rated F or G?
- What is their floor area?
- What would the total fines be in 2033 without action?
- What would the necessary works cost (roof insulation, windows, heating)?
2. Build up the reserve fund
Major insulation and energy renovation works require general meeting votes and adequate funding. The law already requires the creation of a reserve fund in co-ownership buildings, but its level is often insufficient for heavy works.
Calculate the amount needed to bring non-compliant units to the 275 kWh/m²/year threshold by 2033, and propose a multi-year financing plan to the general meeting. It is better to start setting funds aside now than to face an emergency special levy call in 2030.
3. Prioritise works
The roof is the most effective insulation lever for top-floor flats — and these are generally the ones with the worst EPC scores. Under-roof insulation can move a flat from F to D, eliminating the risk of a 2033 fine.
Recommended priority order:
- Roof insulation (maximum impact, 2033 urgency)
- Glazing replacement (double or triple glazing)
- External wall insulation (combined façade renovation)
- Heating system replacement
4. Wait until 2027 for new certificates
If your current certificates were issued under the existing climate tables, wait for the new tables to be adopted before renewing certificates. You will save certification costs and obtain scores that better reflect reality.
Exception: if you need a certificate for a sale or letting before 2027, issue it with the current tables and plan an update after 2027.
With Seido, plan and track energy renovation maintenance requests for each co-ownership building, document EPC certificates by unit, and centralise contractor quotes for transparent decision-making at the general meeting. Discover Seido →
This article is part of Property Essentials #1 — January 2026. Also read: Co-owners: what you are entitled to expect from your building manager.
Sources and references
- Ordinance of 7 March 2024 amending the CoBrACE, Belgian Official Gazette, 22 March 2024
- Decrees of 3 July 2025 — EPC Expert, Indicators and Requirements, Single Certificate, Brussels Environment
- End of the energy-inefficient built environment in the Brussels Region, Brussels Environment, 2024
- Brussels renovation obligation approved by Parliament, Loyens & Loeff, 2024