EPC Label requirement at portfolio level: A game-changer for strategic real estate management

With the EPC label requirement for individual buildings soon to be applied at the portfolio level, a strategic real estate plan is becoming more important than ever.

On 14 and 18 July 2025, the Flemish Government provisionally approved an amendment decree and an amendment decision. These form the basis for several key adjustments that provide greater flexibility in making property portfolios more sustainable. A strategic real estate plan ensures this greater flexibility is maximised: it helps determine which buildings should be tackled first, how resources are best allocated, and how legal requirements can be met on time and in a cost-effective way.

But what exactly does a portfolio-level label requirement mean? And how do you get started?

Until now, every single building had to comply with a minimum energy performance label. With the new regulations, it will become possible to apply this requirement across the entire portfolio.

In practice, this means that property owners with large building portfolios, such as school networks, real estate portfolio managers, or organizations with multiple sites, will be able to:

• Renovate more strategically, for example by investing first in the largest or worst-performing buildings

• Gain more freedom in the sequencing of renovations, as long as minimum requirements are met

• Align renovation obligations more closely with their long-term strategy

This approach fits seamlessly with a phased strategy, where impact is achieved step by step. By developing a strategic real estate plan, organizations can shape this phased approach effectively and ensure that investments, renovations, and energy performance are fully aligned.

Other important changes

In addition to the option to meet EPC label requirements at portfolio level, the reform package also introduces several other relevant adjustments:

• Choice of designation: For residential buildings located on the same site as non-residential buildings, it will be possible to opt for a single EPC for non-residential buildings (EPC-NR). This simplifies administration, for example in the case of assisted living units next to a care facility, or studios next to a hotel or rehabilitation center.

• EPC-NR by in-house experts: Internal energy experts will still be allowed to issue EPCs for non-residential buildings for their own employer until 31 December 2029.

• BACS obligation: Non-residential buildings with heating and/or cooling systems over 290 kW must be equipped with a building automation and control system (BACS) by the end of 2025. By 2030, this threshold will be lowered to 70 kW. Buildings with only one of the three systems (heating, cooling, or ventilation) are exempt