The EPBD BACS Guide: Article 13 explained

What the EPBD changes

The EPBD is the EU's central instrument for cutting energy use in buildings, which account for roughly 40% of the bloc's energy consumption. The 2024 recast strengthened the rules on technical building systems, and Article 13 is the part that matters most for controls: it requires member states to mandate BACS in non-residential buildings above defined capacity thresholds. The aim is to close the gap between how buildings are designed to perform and how they actually run — a gap that automated monitoring, fault detection, and demand-based control are well suited to close.

Crucially, the directive sets the framework, but each member state transposes it into national law. That means the precise deadline, enforcement mechanism, and any national nuances depend on where the building is. control.haus models BACS readiness as a planning workflow against this framework — it is not a legal determination.

Thresholds: is your building in scope?

Scope is determined by the effective rated outputof the building's technical systems — the combined capacity of heating, ventilation, air-conditioning, and (where relevant) hot-water systems. Two thresholds apply:

• Above 290 kW — already required, with a deadline of 31 December 2024. The largest buildings should be compliant now.
• Above 70 kW — required by 31 December 2029. This much larger group includes most medium and large offices, retail, hotels, schools, and hospitals.

A worked example: a building with a 120 kW heating system and a 60 kW cooling system has an effective rated output of 180 kW, comfortably above the 70 kW threshold and therefore in scope for the 2029 deadline. Residential buildings are excluded, and mixed-use buildings are assessed on their non-residential portion.

What a compliant BACS must do

Article 13 points to performance, not just presence of a control panel. A compliant system must reach at least EN ISO 52120-1 Class C (the standard formerly known as EN 15232), which defines four automation efficiency classes from A (high performance) down to D (non-efficient). Buildings at Class D, or with no automation at all, are the primary upgrade targets. In practice the system must be able to:

• continuously monitor energy use and log consumption;
• benchmark performance against expected efficiency and flag deviations;
• detect faults, losses, and efficiency drift in technical systems;
• give operators clear, actionable information; and
• enable demand-based control of HVAC rather than fixed schedules.

Simple time-clocks and standalone thermostats do not qualify — they switch equipment on and off but cannot monitor, report, or adapt. See the BACS requirements checklist for the full capability and evidence list.

How to use this guide

A sensible sequence for most owners is: confirm scope, identify the capability gap, then build the investment and funding case before committing to engineering.

1. Run the scope checker with your HVAC capacity to confirm which threshold and deadline apply.
2. Use the capability checklist to find missing controls and the evidence you can already show.
3. Model cost, grant, and savings assumptions in the ROI planner, and check national support in the funding navigator.
4. Track per-country status in the regulatory tracker, since deadlines and enforcement vary by member state.