EPC Certificate for Common Areas in Belgium: Obligations and Regional Timeline

Energy performance is now at the centre of Belgian building regulation. The EU Energy Performance of Buildings Directive (EPBD) requires member states to set minimum energy standards for existing buildings, and Belgium's three regions are implementing this at different speeds. For co-ownerships, the obligation to obtain an Energy Performance Certificate (EPC) for common areas represents both a compliance requirement and a strategic planning exercise.

Flanders: VLEES — Mandatory Since January 2024

Flanders introduced the Vlaams Energielabel voor Gemeenschappelijke Delen (VLEES) framework, effective 1 January 2024. Every apartment building with common heating, cooling, or ventilation installations must obtain an EPC for the common areas, assessed by a VEKA-certified energy assessor.

The Flemish renovation trajectory sets binding targets:

Label D (maximum 200 kWh/m²/year) by 2040
Label C (maximum 150 kWh/m²/year) by 2045

Buildings that fail to reach these targets face potential penalties and reduced property values. The EPC for common areas is distinct from the individual unit EPCs — it evaluates shared installations such as central heating boilers, communal hot water systems, roof and facade insulation of common parts, and common area lighting.

Wallonia: Phased Introduction from 2025

Wallonia is rolling out its EPC obligations for common areas in phases. Buildings with more than 10 units are expected to require a common-area EPC from 2025-2026, with smaller buildings following thereafter. The Walloon target is to reach label D by 2035, a more aggressive timeline than Flanders for the initial milestone.

The Walloon region uses the PEB (Performance Énergétique des Bâtiments) framework, administered by SPW Énergie. The certification process is similar to Flanders but uses region-specific calculation methodologies.

Brussels: PLAGE Framework and Expected Timeline

The Brussels-Capital Region operates the PLAGE (Plan Local d'Action pour la Gestion Énergétique) programme, currently voluntary for buildings exceeding 5,000 m². A mandatory common-area EPC regime is expected around 2027, aligning with the updated EU EPBD transposition deadline.

Brussels already imposes strict individual-unit EPC requirements for rental properties and has among the most ambitious climate targets in Belgium. Co-ownerships in Brussels should anticipate that common-area obligations will be rigorous once introduced.

Syndic Obligations

The syndic bears primary responsibility for compliance with EPC obligations. Specifically, the syndic must:

Commission the certificate from a certified assessor, obtaining at least three competitive quotes for buildings with more than 20 units.
Present the EPC results to the general assembly, including the current label, the renovation trajectory targets, and the estimated cost of reaching each milestone.
Propose a renovation roadmap as an agenda item, allowing the GA to vote on phased improvements aligned with the building's reserve fund capacity.

Failure to initiate the EPC process can expose the syndic to liability under Art. 577-8 Belgian Civil Code, as maintaining the building in compliance with applicable regulations is a core duty.

Financing Energy Renovations

Belgian co-ownerships have several financing options for energy works approved at 2/3 majority under Art. 577-6 §8 Belgian Civil Code:

Renolution (Brussels): grants up to €50/m² for insulation works.
MyRénova (Wallonia): subsidised energy audits and renovation premiums.
Fluvius premiums (Flanders): incentives for roof insulation, high-efficiency boilers, heat pumps, and solar panels.
ACP bank loan: the GA can vote to take a collective building loan at a 2/3 majority, spreading the cost over 10-20 years. Individual owners retain the option to pay their share upfront to avoid interest charges.

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