EPBD transposition: the building automation requirements are now live

The recast Energy Performance of Buildings Directive, Directive (EU) 2024/1275, entered into force in 2024 and had to be transposed into national law by Member States by 29 May 2026. The Directive strengthens the role of technical building systems, digitalisation, building automation and indoor environmental quality in improving the performance of Europe’s building stock.

For anyone responsible for a non-residential building, the practically important part is Article 13. It is no longer a question of whether a building automation and control system is a good idea — for many buildings it is now a requirement.

What Article 13 requires

Under Article 13(9), Member States must ensure that, where technically and economically feasible, non-residential buildings are equipped with a BACS:

• By 31 December 2024, where the relevant heating, air-conditioning or combined ventilation systems have an effective rated output over 290 kW.
• By 31 December 2029, where those systems have an effective rated output over 70 kW.

The 290 kW threshold date has already passed, which means the obligation now applies to a large share of Irish commercial stock. The 70 kW threshold brings a much wider group of buildings into scope over the next few years.

What the system must be able to do

Article 13(10) sets out the minimum capabilities a compliant BACS must provide:

• Continuously monitor, log and analyse energy use, and allow it to be adjusted.
• Benchmark the building’s energy efficiency, detect losses in the efficiency of technical building systems, and inform the facilities or technical building manager of opportunities for improvement.
• Communicate with connected technical building systems and other appliances in the building, and be interoperable across different proprietary technologies, devices and manufacturers.
• Monitor indoor environmental quality, from 29 May 2026.

That last requirement is the one most buildings are least prepared for. IEQ monitoring covers the conditions that affect occupant health and wellbeing — temperature, humidity, ventilation rate and the presence of contaminants — and it is now part of what a compliant system has to deliver, not an optional extra.

What it means on an Irish site

Compliance will be judged on whether the required capabilities are present, operational and verifiable — not on the brand of controller on the wall. That is a functional test, and it is one that a BMS alone rarely passes without additional metering, sensing and reporting layers.

The focus should be on whether the required capabilities are present, operational and verifiable — not on product-specific requirements.

In practice that means three things. Proven energy monitoring with a usable audit trail. Interoperability demonstrated across the systems already installed, typically through BACnet or an open API. And IEQ sensing deployed at a density that produces data someone can act on, rather than a single sensor in a lobby.

Where lighting fits in

This is the part of the Directive our own work speaks to most directly. A modern lighting control system is already a distributed sensor network: occupancy, daylight and increasingly temperature, humidity, CO2 and air quality. Where that network is specified with open protocols — DALI, Bluetooth NLC, BACnet gateways — it becomes the cheapest route to the monitoring and interoperability Article 13 asks for, because the sensing is being installed for the lighting anyway.

Systems such as Silvair, Blu2light, Enlighted and entroCIM are the ones we use to join those layers up: sensing at the fixture, an open gateway, and a reporting layer that a facilities team can hand to an assessor.

Practical next steps

eu.bac, the European Building Automation and Controls Association, has published guidance for Member States on transposing the BACS provisions, along with a BACS compliance verification checklist and a self-declaration template that building owners can use to prepare evidence.

If you are unsure whether a building is in scope, the first step is straightforward: establish the effective rated output of the heating and air-conditioning systems, then compare what the installed controls can actually demonstrate against the four capabilities above. We are glad to carry out that review alongside a lighting or controls survey.