BACS Decree 2030: Postponement, Timeline and Action Plan

The postponement of the BACS decree deadline (French decree 2020-887 on building automation and control systems) for 70 to 290 kW buildings to 1 January 2030 changes the timeline. It does not change the obligation. Three more years of grace also means three more years of overconsumption for every commercial building without a working building automation and control system. Postponed compliance does not mean optional compliance. Here is the up-to-date framework and a concrete action plan for your commercial portfolio.

BACS decree regulatory framework and up-to-date timeline

Regulatory origin of the BACS decree

The BACS decree transposes into French law Articles 14 and 15 of European Directive 2010/31/EU (EPBD), as amended by Directive (EU) 2018/844. Decree No. 2020-887 of 20 July 2020 requires a building automation and control system - an automation and control system able to regulate and monitor energy use - to be installed in commercial buildings above a threshold of rated heating and cooling output (source: Légifrance). The text was amended by Decree No. 2025-1343 of 26 December 2025, following a public consultation that shifted the timeline for the 70-290 kW band. The obligation remains in full; only the date moves.

Why did the 70-290 kW deadline move from 2027 to 2030?

In late 2025, the government put a draft decree postponing the deadline out for public consultation (13 November to 4 December 2025), citing in particular the capacity of the BMS industry to absorb the volume of buildings concerned and alignment with Article 13 of Directive (EU) 2024/1275 (recast EPBD). The EPBD 2024 and its 290 kW threshold set this European timeline, lowered to 70 kW at the end of 2029. Decree No. 2025-1343 of 26 December 2025, published in the French Official Journal (JORF) on 27 December 2025, made the postponement official: in Article R. 175-2, II, 4° of the French Construction and Housing Code (CCH), the deadline moves from 1 January 2027 to 1 January 2030 (source: Légifrance). The postponement reflects market strain, not a regulatory retreat.

What the postponement changes for new buildings and building permits

The postponement only concerns existing buildings. For new buildings, Article R. 175-2 of the Construction and Housing Code requires a BACS from the building permit stage for permits filed from 21 July 2021 with a rated output above 290 kW, and from 8 April 2024 with an output above 70 kW (source: Légifrance). A building above 290 kW delivered in 2028 with a 2022 permit is already subject to the obligation. No leeway at all on this band.

Existing buildings above 290 kW: compliance required since 1 January 2025

For existing buildings whose rated heating or air-conditioning output exceeds 290 kW, compliance has been required since 1 January 2025 (source: Decree No. 2020-887 as amended). If your portfolio mixes sites above and below the 70 and 290 kW thresholds, the first band gets no postponement. Latecomers in this band are already past the deadline.

Existing buildings from 70 to 290 kW: new deadline on 1 January 2030

The deadline for existing buildings with a rated heating or air-conditioning output of 70 to 290 kW is set at 1 January 2030 (source: Decree No. 2025-1343, Légifrance). Watch out: this is the output of the heating or cooling system, not the subscribed electrical power. Confusing the two regularly leads building owners to believe they are exempt when they are not.

Room thermostats and pipe insulation: the parallel deadlines

The BACS decree does not stand alone. Two parallel obligations apply to the same commercial building stock:

• Automatic temperature control (“thermostats”): heating and cooling systems must be fitted with room-by-room or zone-by-zone control (Article R. 241-6 of the French Energy Code, from Decree No. 2023-444 of 7 June 2023). Deadline: 1 January 2027 for constructions whose permit or prior declaration is filed from that date, and 1 January 2030 for existing buildings, since Decree No. 2025-1343 postponed this obligation together with the BACS one (source: Légifrance).
• Insulation of heating and cooling distribution networks: insulation of heating and cooling distribution pipework located outside heated or cooled spaces (source: Article R. 241-31-1 of the Energy Code, Légifrance). Same deadlines: 1 January 2027 for new constructions (permit filed from that date), 1 January 2030 for existing buildings (Decree No. 2025-1343). Insulation applies to heating distribution networks and cooling networks alike.

Planning one overall program avoids mobilizing teams three times in a row on the same building.

First inspection: when and how?

The decree provides for a periodic inspection of the building automation and control system (automation and control system), at the owner's initiative (source: Art. R. 175-5-1 of the Construction and Housing Code, Légifrance). Its frequency cannot exceed five years; it is reduced to two years after the installation or replacement of the BACS or of a connected technical system (order of 7 April 2023, Art. 5). In practice, the first inspection of a BACS installed for the 2025 deadline had to take place within two years of commissioning; the same will apply to the 70-290 kW band after 2030. Systems already in place on 8 April 2023 had to be inspected before 1 January 2025. The texts set no specific qualification for the inspector, but the report, delivered within one month and kept for ten years, must bear the inspector's name and signature. Better to prepare the system ahead of the mandatory inspection than to discover it on inspection day.

Functional requirements and compliance: what the decree actually requires

What the decree actually requires: setpoint management, energy monitoring and drift detection

The BACS decree does not prescribe a BMS brand or a standard class. It defines four mandatory functions that the building automation and control system must perform (Art. R. 175-3 of the Construction and Housing Code):

1. Energy monitoring: continuously monitor, log and analyze, per functional zone and at hourly intervals, the energy production and consumption data of the technical systems, adjust those systems accordingly and keep the data at monthly granularity for five years
2. Drift detection: benchmark the building's energy efficiency against reference values, detect efficiency losses in the technical systems and inform the operator of improvement opportunities
3. Interoperability with the building's various technical systems
4. Manual shutdown and autonomous management of one or more technical systems (zone setpoint management falls under this automatic adjustment, with no level imposed)

Key point: the decree imposes no class from NF EN ISO 52120-1. Its requirements are functional, not normative; the ministry's application guide (January 2026) even states that a class C BACS is deemed to meet all the regulatory requirements. Setting up structured energy management covers these four functions - provided the data is actually used.

Does your existing BMS already meet these requirements?

Many commercial buildings have an existing BMS that, on paper, meets the decree requirements. The problem rarely lies in the system itself. It lies in what is done with it. How the four functions are actually implemented deserves an on-site assessment, question by question.

The tool below checks your BMS installation against the regulatory functions. The verdict remains tentative: only an on-site audit can settle the matter.

What the decree requires vs what the NF EN ISO 52120-1 standard classifies

The market confuses three separate logics. Regulatory compliance with the BACS decree, the NF EN ISO 52120-1 classification (classes A, B, C, D) and eligibility for CEE energy-savings certificates via standardized operation sheet BAT-TH-116 meet different criteria.

A building can satisfy the decree without reaching the class B required for CEE. Conversely, a class A BMS goes well beyond the regulatory requirements. The amount of energy-savings certificates (CEE) varies with the climate zone and floor area of the building. Telling these three logics apart avoids over-investing or missing out on funding.

The table below sets each logic against its own automation criteria and financial consequences.

CEE and the BAT-TH-116 sheet: eligibility separate from compliance

The BAT-TH-116 sheet makes access to CEE conditional on installing a class A or class B automation and control system. Compliance with the BACS decree, on the other hand, mentions no class. The two processes do not follow the same logic.

The return on investment of a compliant BMS depends on the CEE coverage rate obtained and on the actual energy savings. Targeting class B from the outset lets you combine regulatory compliance and funding. To estimate the amount available for your portfolio, see how to fund your BMS with CEE before 2030.

Why is your building's class that of its weakest function?

Did you know? NF EN ISO 52120-1 classifies each technical function separately: heating, cooling, ventilation, lighting. The building's overall class is that of its weakest function. Heating rated A and cooling rated D give a building rated D (source: NF EN ISO 52120-1:2022 standard, AFNOR summary).

This rule changes how an audit should be read. Improving the best-automated function does nothing for the rating. The lever is the lagging function - often the least-instrumented heating or air-conditioning system on the site.

What the postponement does not change: the hidden costs of waiting

Annual overconsumption of a building without working automation

Three years gained on the timeline. Three more years of overconsumption on the bill. ADEME estimates the savings from a working BMS at 20 to 30% of a commercial building's HVAC consumption (source: ADEME, BMS guide, 2021). Applied to an average HVAC energy cost of €15 to €25/m²/year in commercial use (source: Observatoire de l'Immobilier Durable, 2023 barometer), every year without automation represents a measurable cost of inaction.

The math is simple. A 5,000 m² site consuming €20/m²/year in HVAC loses between €20,000 and €30,000 a year in uncaptured energy savings. Over three years of postponement, the cumulative bill exceeds the cost of a BMS audit. The payback period of an automation investment mechanically worsens when it is put off.

Expert tip Before pricing a BMS investment, have your existing system audited. ADEME's orders of magnitude are averages: your building's real potential is measured on your own historical data, not on industry ranges.

CEE: a funding window that closes on 1 January 2030

Standardized operation sheet BAT-TH-116 funds the installation of a class A or B BMS. The CEE scheme rewards actions that go beyond the regulations in force (source: ADEME, general principles of the CEE scheme). The current version of the sheet (from the 62nd CEE order of 22 August 2024) applies to operations committed before 1 January 2030, the date on which the obligation becomes general for 70-290 kW buildings. The funding window therefore closes on 1 January 2030.

Acting before the deadline lets you combine CEE funding and regulatory compliance. The return on investment improves markedly when CEE funding covers part of the installation cost.

Expected strain on BMS contractors as the deadline approaches

The public consultation at the end of 2025 (13 November - 4 December 2025) surfaced an unambiguous finding: the BMS industry lacks the qualified resources to absorb demand (source: ecologie.gouv.fr, consultation on the draft decree). The postponement will mechanically create a bottleneck at the end of 2029. Building owners who wait until the last minute will face longer lead times and higher implementation costs.

Planning ahead lets you choose your team and negotiate. The strain on contractors across the commercial building stock will only grow as the deadline approaches.

Getting ahead of compliance: a three-step action plan

Audit the existing BMS before deciding on an investment

Too many systems are declared obsolete when they actually work - poorly configured or underused. Auditing the existing BMS before deciding on a replacement means separating what works from what needs to change. Installing a new BMS only makes sense if the existing one does not meet the decree requirements.

Do you know how many points in your supervision are actually read and used? Without that answer, any implementation quote is a gamble.

Make data and control sequences reliable

A system whose meters drop out or whose histories have gaps allows no reliable monitoring. Making the data reliable means removing manual overrides, checking control sequences zone by zone and straightening out setpoint management.

Without this implementation step, any energy management layer - manual or automated - works on wrong data. The building consumes energy and nobody knows why.

How does Foobot support BACS compliance across your portfolio?

BMS advisory: audit and fix your system before any decision

Our BMS advisory is the entry point. We audit your system, assess how obsolete it really is and get the meters back in order. Making a building reliable before any investment decision is the principle we never compromise on. The advisory is a service in its own right: your team leaves with an action plan, not a replacement quote. It is deployed on your existing commercial portfolio, with no construction work.

AI Control: going beyond compliance with predictive control

When the BMS is reliable and the HVAC complexity justifies it, we train a custom digital twin. Our AI Control adjusts HVAC every 15 minutes, 24/7, through predictive control - taking into account weather, occupancy and building inertia. Energy savings measured at Valeo reach -28.6% of HVAC consumption under the IPMVP protocol (source: Foobot/Valeo case study). The system builds on the existing energy management without replacing any hardware.

FAQ - BACS decree 2030