The "Zero Emission" Building Energy Requirement Arrives by 2028 – What Does It Mean for Building Services Engineers?

Published: Épületgépész 2026/4 – september

According to the provisions of the EU Energy Performance of Buildings Directive (EPBD 2024/1275), starting in 2028 all new public buildings, and starting in 2030 all new buildings must be zero-emission. The directive rules out the use of standalone boilers powered by fossil fuels in new buildings, mandates renewable energy use in some form, and requires energy feed-in, storage, and generation to be technically controllable. Another major change is that requirements will apply not only to operational energy consumption—as is currently the case—but also to whole-life carbon footprint.

Gábor Szarvas, HuGBC’s Zero Carbon and Green Finance Ambassador and Managing Director of Greenbors Consulting (a sustainable real estate consultancy), assisted in writing this article.

The Fight Against Climate Change

The construction industry is a primary battlefield in combating climate change, as building and operating our structures still demands vast amounts of fossil energy. This is why the EPBD (the EU’s Energy Performance of Buildings Directive) was originally created—to curb energy consumption and environmental impact—and why it was further tightened in 2024. The directive is binding for all EU member states; national law harmonization discussions in Hungary are currently underway.

Transposing the EPBD requires amending several existing regulations and drafting new ones. Member states have flexibility in certain areas—such as how embodied carbon is calculated. In other areas, however, national regulations are unlikely to diverge from EU mandates—such as the prohibition of installing fossil fuel equipment in new builds. Let’s look at the specific rules and where negotiations currently stand.

Zero-Emission Building Energy Consumption: Nearly Zero minus 10%

  The current timeline for implementing the "zero emission" standard is as follows:From 2028: All new publicly owned buildings must be "zero-emission."From 2030: All new buildings must be "zero-emission."The current requirement for total primary energy demand in residential buildings is $76\text{ kWh/m}^2/\text{year}$. This includes heating, ventilation, cooling, and domestic hot water (DHW) production along with auxiliary energy on an annual basis, calculated using primary energy factors.For all other building types, calculations rely on the reference building method. Zero-emission buildings will require energy consumption to be at least 10% lower than current baseline requirements.Under current regulations, the maximum annual primary energy consumption for heating, ventilation, cooling, and DHW production in a $150\text{ m}^2$ house is $11,400\text{ kWh}$.Why does it matter that energy standards specify primary energy rather than actual end-use consumption? Because primary energy conversion factors depend on how environmentally friendly the generation of the energy used on-site actually is. If a building relied purely on resistive electric heating and electric water heaters, the primary energy factor would be 2.3, reflecting the fact that grid electricity is still partially generated from fossil fuels (coal, gas) and suffers grid transmission losses.Current performance targets are already quite strict, but architects, MEP engineers, energy assessors, and contractors have adapted to them. Meeting stricter standards through slightly thicker insulation, thermal-bridge-free detailing, optimized surface-to-volume ratios, renewable integration, and more efficient, finely controlled HVAC/DHW systems will not be overly difficult.

No Fossil Fuel Use in Buildings

If Hungarian regulations align with the EU directive, specifying and installing fossil-fuel-burning equipment in new public buildings will be banned by 2028, extending to all new builds by 2030. In the Hungarian market, this effectively means a ban on natural gas boilers. This is not an insurmountable hurdle: fewer gas boilers and more heat pumps are installed in new builds every year. While 2025 data is not yet finalized, in 2024 only 2,949 new apartments installed individual gas boilers, and 1,451 used central building gas heating systems. By contrast, 6,689 apartments were equipped with heat pumps. Heat pumps have dominated new public construction for years; the main change starting in 2028 is that gas-hybrid systems will also be banned from design plans.

On-Site & Clean Renewable Energy Supply

The directive also specifies how gas boilers must be replaced:

• On-site renewable energy systems physically connected to the building (solar, wind, geothermal, biomass),

• Renewable energy communities,

• Efficient and low-carbon district heating/cooling,

Other clean energy sources.

Regarding the last category, member states may define zero-emission sources at the national level—such as off-site renewable energy contracts or grid electricity generated from nuclear power.

Heat Pump + Solar PV: Is It Enough for "Zero Emission"?

An obvious question arises: Will a building comply if designed using the most common current MEP setup—an air-to-water heat pump? Heat pumps draw heavily on renewable thermal energy extracted from the environment, but they still require grid electricity to run. And that electricity is currently still generated in large part from fossil fuels.

Will adding a rooftop solar PV system bridge the gap? Solar panels generate surplus energy during spring, summer, and autumn, but fall short in winter when heat pumps draw peak power. Batteries cannot fully solve this issue because they absorb daily fluctuations, not seasonal imbalances. If an energy community or district heating is unavailable, what is the solution?

According to Gábor Szarvas:

“The directive mandates complete operational emission neutrality for the building’s energy supply. The heat pump plus solar PV example illustrates the challenge well. For a single-family home, this combination can likely achieve compliance because the EU permits net-metering schemes. Under net metering, when solar generation exceeds household demand during sunny periods and feeds back into the grid, an energy-efficient house can balance its annual generation against annual grid draw. (I live in such a home, so practical experience proves it is feasible.)

The situation is trickier for multi-family residential buildings where roof—or even façade—space is insufficient for adequate solar capacity and district heating is unavailable. Here, heat pumps must draw more electricity from the grid annually than is generated on-site. Fortunately, grid power is growing increasingly green, and the EPBD classifies nuclear power as a clean source. In Hungary, renewables plus nuclear currently account for around 60% of grid power. The National Energy Strategy aims to raise this to 90% by 2030. That leaves only a small fraction of non-clean grid power. In such cases, the directive allows national regulations to define acceptable solutions. While Hungary has not yet finalized these rules, one approach could be requiring green power purchase certificates (Guarantees of Origin) to offset residual grid draw. Alternatively, regulations might allow minor uncompensated grid power draw below a de minimis threshold.”

As this shows, achieving zero-emission buildings relies heavily on governmental commitment to decarbonize the power grid. This requires replacing coal and gas plants with nuclear, green hydrogen, wind, hydro, solar, and biomass, backed by substantial energy storage infrastructure—investments that are already underway.

Smart Energy Load Management & Storage

Renewable energy provides abundant "free" energy, but generation fluctuates. Anyone monitoring a rooftop PV system knows peak generation rarely matches peak demand. As a result, zero-emission buildings will require building automation to schedule high-power loads during periods of surplus generation—whether power comes from rooftop panels or grid-level renewable supply.

Whole-Life Carbon Footprint

A building’s environmental impact stems not just from its operations, but also from its construction materials and processes. The EPBD aims to curb both. Mandatory Life Cycle Assessment (LCA) takes effect in 2030 for all new buildings, and in 2028 for larger buildings with useful floor areas exceeding $1,000\text{ m}^2$. Initially, no compliance thresholds will be enforced; designers and energy assessors will simply be required to calculate the carbon figure. The goal is transparency—helping designers treat carbon reduction as a core design parameter. When will mandatory limits arrive? Member states must publish roadmaps by January 2027 and introduce limits by 2030, expressed in kg CO2. Thresholds will vary by country based on local manufacturing supply chains and energy mixes. For example, a bag of cement produced using Denmark’s offshore-wind-heavy power mix yields a vastly different carbon score than one produced in a coal-reliant grid. These limits will incentivize material manufacturers to decarbonize production to stay competitive. Currently, regulatory limits in Hungary only apply to operational emissions (Module B6)—whereas a complete building LCA covers the entire lifecycle. How is a building's embodied carbon calculated? Embodied carbon represents a major share of whole-life carbon and depends on the carbon intensity of every installed building material and product. “Every construction product will eventually carry an Environmental Product Declaration (EPD) specifying its embodied carbon footprint in CO2 equivalents. Designers will aggregate these product footprints across the entire building lifecycle—from raw material extraction through construction, operation, and end-of-life demolition,” explains Gábor Szarvas. LCA calculations will require data sheets for all materials and equipment accounting for at least 1% of the total building mass—including HVAC units, chillers, and air handlers. Looking at international precedents, individual items like piping will not need to be itemized manually; specialized software will estimate their mass based on floor area.Simplified calculation methodologies—already used in countries like Germany and Austria—offer a streamlined path forward for MEP engineering. Since the bulk of embodied carbon resides in structural materials (concrete, rebar, structural steel) and insulation, simplified methods require exact material quantities only for these heavy structural elements. Multiplying this core structural carbon figure by a standardized factor (1.4 in German and Austrian practice) yields the total embodied carbon footprint with high accuracy—capturing the remaining 40% across all other building elements, including MEP services.Once embodied carbon is calculated, software models the whole-life footprint over the building's operating lifespan. How are short-lived mechanical assets (like heat pumps) handled over a typical 50-year building lifecycle?“LCA methodologies account for equipment replacement cycles. If a heat pump with a 25-year service life must be replaced once during a 50-year building lifespan, its embodied carbon footprint is factored into the building’s total LCA at twice its single-unit value.”According to Gábor Szarvas, building owners, developers, facility managers, and design teams should prepare early by leveraging specialized consulting expertise to navigate these incoming regulatory shifts.

Sipos Anna

Environmental Engineer

(About the Author: Anna Sipos graduated as an environmental engineer from Pollack Mihály Technical College in Pécs in 2003. After working in environmental engineering, she transitioned to construction journalism in 2009. Her work focuses on building energy performance, passive design, and active energy reduction. She is active in her family's architectural firm, designing low-energy and passive houses and modeling energy performance using PHPP. She is a regular attendee at key industry conferences for designers and contractors, focusing on technical innovation, practical regulatory changes, and emerging technologies.)