Luxembourg Energy Passport: Obligations for Sale and Rental
In Luxembourg, the Energy Performance Certificate (EPC) — also known as the energy passport or Energiepass — is a legal obligation for any sale, rental, construction or major renovation of a building. Valid for 10 years, it rates your property from A+ to I across three criteria: energy performance, thermal insulation and CO₂ emissions. Without a valid EPC, you cannot legally sell or rent your property, nor publish a property listing — with criminal penalties of up to €24,789 (Article 20 of the modified Law of 5 August 1993). The EPC also determines your eligibility for Klimabonus grants.
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What is the energy passport in Luxembourg?
The Energy Performance Certificate (EPC), commonly called the energy passport or Energiepass, is an official five-page document that assesses the energy quality of a residential or non-residential building in Luxembourg. Introduced by the Grand Ducal Regulation of 30 November 2007, it is now governed by the Grand Ducal Regulation of 9 June 2021 on the energy performance of buildings, which came into force on 1 July 2021.
This document provides three distinct assessments of the building:
- Energy performance class: measures the annual primary energy requirement (kWh/m²/year), taking into account the thermal envelope and technical systems (heating, domestic hot water, ventilation).
- Thermal insulation class: measures the annual heating heat requirement (kWh/m²/year), reflecting the quality of the thermal envelope — insulation of walls, roof and windows, air tightness and building orientation.
- Environmental performance class: measures the building’s CO₂ emissions related to energy consumption.
Each class is rated from A+ (best performance) to I (worst performance). Buildings are commonly described by their first two classes, for example « C-D » (C for energy performance, D for thermal insulation). Since 1 January 2017, all new residential buildings in Luxembourg must meet the NZEB (Nearly Zero Energy Building) standard, which typically corresponds to class AAA.
A building is classified as a residential building when at least 90% of its energy reference area is used for residential purposes. All other conditioned buildings are functional buildings. The applicable EPC type (LuxEeB-H for residential, LuxEeB-F for functional) and the experts qualified to issue it differ depending on this classification.
The EPC is valid for 10 years from its date of issue. In case of substantial energy renovation works, it is strongly recommended — and sometimes mandatory — to obtain a new one to reflect the building’s improved performance, particularly to access Klimabonus grants.
Contrary to what one might think, EPC results do not impose a direct obligation to renovate your property. The EPC primarily serves an information and awareness function. The Klima-Agence, a public body, sets out the rules and lists approved experts.
When is the EPC mandatory in Luxembourg?
According to guichet.public.lu and the Grand Ducal Regulation of 9 June 2021, an EPC is mandatory in the following situations:
| Situation | Requirement | Who is affected? |
|---|---|---|
| Sale of a property | Valid EPC mandatory from the moment of listing | Seller / property owner |
| Rental of a property | Valid EPC mandatory from the moment of listing | Landlord |
| New construction | EPC mandatory for any building permit | Developer / future owner |
| Building extension | EPC mandatory if building permit required | Owner / homeowners association |
| Modification with permit | EPC mandatory if modified area exceeds 10% of the element concerned (exterior wall, roof, windows…) | Owner |
| Substantial transformation without permit | EPC mandatory if impact on energy performance AND modified area > 10% | Owner |
| Works on technical systems (heating, ventilation, etc.) | EPC mandatory if cost exceeds: €1,500 (single-family) or €3,000 (multi-family) | Owner |
| Public buildings | EPC mandatory if energy reference area > 250 m² — visible display required | Public entity owner |
If a house facade is 200 m² and you insulate one side measuring 40 m², you exceed the 10% threshold of total area (10% × 200 m² = 20 m²). A new energy passport must therefore be issued. This criterion applies separately to each element of the thermal envelope: exterior walls, roof, windows.
Concrete obligations when selling a property
The sale of a property in Luxembourg is subject to strict EPC requirements. Here are the four main legal obligations:
The EPC must exist and be valid before publication of any sale listing. A seller who publishes a listing without a valid EPC faces immediate criminal prosecution. The EPC must remain valid throughout the sale period until the deed is signed.
The seller must make the EPC available to all potential buyers on request. Communication must be provided without delay in its complete form (all five pages of the official document). It is recommended to attach it systematically to all listings.
At the time of effective ownership transfer, the original EPC must be attached to the sale deed and handed to the new owner, who retains it for its validity period (10 years).
Since 1 July 2012, sale listings must compulsorily state the energy performance class and thermal insulation class of the property, as shown in the EPC — either via the class graphics or in simplified notation (e.g. « C-D »).
The EPC is not required when a property is transferred through a gift or inheritance, sold for demolition purposes, or sold through a public sale, forced sale or public tender.
Obligations when renting out a property
Landlords’ EPC obligations are similar to those of sellers, with some important differences in document handover:
As with a sale, the EPC must exist and be valid before any rental listing. A landlord without a valid EPC cannot legally publish a rental listing or conclude a lease.
Unlike a sale (where the original is transferred), upon a change of tenant, the landlord must provide the new tenant with a certified copy of the EPC. The landlord retains the original. This copy is provided when the lease is concluded.
Rental listings published in commercial media must state the energy performance class and thermal insulation class. This information must clearly appear in the signed lease.
Reform proposals had considered lowering the rent ceiling to 3% of invested capital for properties rated F to I (versus 5% currently) and 3.5% for classes A to E. However, these provisions were removed from the final law of 23 July 2024 (in force since 1 August 2024), following strong opposition. To date, the legal rent ceiling remains fixed at 5% of invested capital for all properties, regardless of energy class.
Penalties for non-compliance with EPC obligations
The Grand Ducal Regulation of 9 June 2021 explicitly refers to the criminal penalties under Article 20 of the modified Law of 5 August 1993 on rational energy use. These penalties apply to any failure to establish, communicate or make available an EPC.
| Type of breach | Applicable penalty |
|---|---|
| No EPC when selling or renting | Imprisonment of 8 days to 2 months and/or fine of €61 to €24,789 |
| Listing without energy class information | Same criminal penalties + risk of listing invalidity |
| Failure to hand over EPC to new owner or tenant | Imprisonment of 8 days to 2 months and/or fine of €61 to €24,789 |
| Failure to issue « as-built » EPC within the deadline | Same criminal penalties (Article 4 §12 of the 2021 Regulation) |
| Failure by architect/engineer to hand over energy performance calculation to owner | Same criminal penalties (Article 4 §14 of the 2021 Regulation) |
The Grand Ducal Regulation of 9 June 2021 expanded the scope of sanctionable offences relating to EPCs, demonstrating the Luxembourg authorities’ determination to enforce energy performance obligations. Do not take risks: have your EPC established before any transaction or listing publication.
Reading and understanding your EPC (classes A+ to I)
The Luxembourg EPC assigns a rating from A+ to I based on annual primary energy consumption thresholds expressed in kWh/m²/year. Here’s how to interpret these classes:
| Class | Building type | Range kWh/m²/year (residential) | Interpretation |
|---|---|---|---|
| A+ | New / Major renovation | ≤ 50 | Very high energy performance — Optimal NZEB standard |
| A | Recent / Well renovated | 51-75 | High performance — Very low consumption |
| B | Good energy condition | 76-100 | Good performance — Acceptable consumption |
| C | Average condition | 101-140 | Average performance — Improvement recommended |
| D | Fair condition | 141-180 | Weak performance — Renovation worth considering |
| E | Poor | 181-250 | Very weak performance — Significant energy works recommended |
| F | Very poor | 251-400 | Critical performance — Energy renovation strongly recommended |
| G | Energy-intensive | 401-600 | Highly energy-intensive — Urgent improvement recommended |
| H | Very energy-intensive | 601-900 | Very energy-intensive — Major negative impact |
| I | Extremely energy-intensive | > 900 | Very poor performance — Significant energy loss |
The EPC assigns three distinct classes: (1) energy performance class (primary energy consumption), (2) thermal insulation class (heating demand), (3) environmental performance class (CO₂ emissions). A building is described by its first two classes, for example « C-D » (performance C, insulation D). The environmental class is mentioned for information.
Who can issue an EPC in Luxembourg? Cost and timelines
Qualified experts
An EPC for a residential building must be established by an approved construction expert. Two categories are automatically qualified:
- Architects who are members of the Luxembourg Order of Architects and Consulting Engineers (OAI)
- Consulting engineers who are members of the OAI
Outside OAI members, experts approved by the Minister of Energy (under the Grand Ducal Regulation of 10 February 1999) are also qualified. The official updated list of approved experts is available on the Ministry of Energy website.
An EPC issued by an unqualified person has no legal value and cannot be used for a property transaction or Klimabonus grant application. Always ensure your expert is on the official list or is an OAI member.
Cost of an EPC in Luxembourg
The cost of issuing an EPC is borne by the person requesting it. Fees vary depending on the building’s surface area, technical complexity and the expert chosen. As a general guide, for a single-family house, prices typically range between €300 and €600 excluding VAT. It is always recommended to request multiple comparative quotes.
The energy passport is a regulatory obligation. For this reason, no state subsidy is granted for its establishment — neither under Klimabonus nor through other grants. Its cost is entirely borne by the applicant.
Lead times
Obtaining an EPC generally involves two stages: an on-site visit by the expert (usually 1–2 hours for a single-family house) to inventory the building’s characteristics, insulation materials and technical systems, followed by report preparation and delivery, typically 10–15 working days after the visit. Allow a total of 2–4 weeks from first contact with the expert to receipt of your EPC. Do not leave it to the last minute if you have a sale or rental project in progress.
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Request my EPC →The essential link between EPC and Klimabonus
The energy passport plays a central role in accessing Klimabonus Wunnen grants, Luxembourg’s main energy renovation subsidy programme. Here’s why it is essential:
A valid EPC is an absolute prerequisite to access Klimabonus grants. No grant can be awarded without a valid EPC issued by an approved expert and dated within the last 10 years.
The EPC determines which renovation works are eligible for grants. The works must be capable of improving the building’s energy class. The EPC’s energy performance estimates guide investments.
After completion of subsidised renovation works, an « as-built » EPC (revised energy performance certificate) must be issued to demonstrate the improvement and unlock the second tranche of aid.
For more details, see our articles on Klimabonus in Luxembourg and on how to improve your energy class.
Exemption cases: when is the EPC not required?
Luxembourg regulations provide for several EPC exemption cases. An EPC is not required for:
- Gifts and inheritances: transferring a property through inheritance or inter vivos donation does not require an EPC.
- Properties destined for demolition without an active heating system.
- Public sales by forced sale, mortgage enforcement or public tender.
- Modifications with no energy impact: where works modify the thermal envelope but below the 10% threshold and without impact on the building’s energy performance.
- Technical works below threshold: where the cost of technical systems work is below €1,500 (single-family) or €3,000 (multi-family).
The Mayor may grant, on a reasoned request, exemptions from energy performance requirements in three cases: (1) the building is listed or protected and presents a public interest, (2) the works would lead to a violation of other building rules, (3) there is technical impossibility or excessive hardship.
Frequently asked questions about the EPC in Luxembourg
My EPC is over 10 years old. Is it still valid for a sale?
No. The EPC is valid for 10 years from its date of issue. An expired EPC has no legal value for a real estate transaction. If your passport is expired, you must order a new one before listing your property for sale or rent.
For a multi-family building, who should request the EPC?
In a condominium, the EPC is issued for the entire building, not for each apartment separately. All apartments in the same building share the same energy certificate. In the event of a sale or rental, it is the homeowners association that is responsible for requesting the EPC if the building does not have one. Practically, if a condominium owner wants to sell their apartment, they should check with the building manager whether a valid EPC exists for the entire building.
Can the EPC be transferred to the new owner?
Yes. The EPC follows the building, not the owner. The original EPC must be handed to the new owner on sale, as an annex to the notarised deed. If the EPC is still within its 10-year validity period, the new owner can use it without needing a new one, unless works have been carried out since.
Does the EPC require you to renovate your home?
No. As stated by Klima-Agence, EPC results do not impose any direct obligation to carry out energy renovation. Even a class I rating does not legally oblige you to renovate your property. The EPC serves an information and awareness function. Any renovation obligations fall under other regulations (such as the rules for new NZEB buildings).
Can an EPC be obtained without an on-site visit?
No. An EPC cannot be drawn up remotely or on the basis of documents alone. The expert must carry out an on-site visit to the building to inventory its actual characteristics (insulation materials, heating systems, glazed area, orientation, air tightness, etc.). Online tools allow you to obtain an indicative estimate of your energy class, but these estimates have no legal value.
What if I have lost my EPC?
If you lose your EPC, you should contact the expert who issued it to obtain a duplicate. If this is not possible (expert unavailable, EPC too old), you will need to have a new EPC issued by an approved expert. It is recommended to keep a digital copy of your EPC in a secure location.
Is an EPC necessary to benefit from Klimabonus insulation?
Yes. A valid EPC is required to access all Klimabonus schemes. It serves as the basis for assessing your eligibility and estimating potential subsidies. After subsidised works, a second « as-built » EPC must be issued.