A DPE displayed in 2017 in a public building has no longer been valid since 31 December 2022: every DPE (the French Energy Performance Certificate, or EPC) issued before 1 July 2021 lost its validity on 31 December 2024 at the latest[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓[11][11]RegulationLégifrance, “Decree No. 2020-1610 of 17 December 2020 on the validity period of energy performance certificates (DPE)”See in sources ↓. Renewing a commercial DPE is therefore a matter for now. Yet the label depends on the consumption data handed to the energy assessor, and almost nobody checks it. Here are the obligations, the calculation method and what the label actually measures. We do not carry out DPEs: we look at what lies behind them.
The commercial DPE framework: labels, triggers, validity, assessor and cost
What the energy performance certificate of a commercial building measures
The energy performance certificate of a building used for commercial purposes produces two labels. The first rates primary energy consumption by end use: heating, cooling and hot water production, among others. Electricity generated on site is deducted[2][2]RegulationFrench Ministry of Ecological Transition, “Energy performance certificate (DPE)”, label templates, end uses and method | ecologie.gouv.frSee in sources ↓. In the commercial sector, it also serves as a sustainable real estate indicator across a portfolio.
The second rates greenhouse gas emissions, without amounting to a carbon footprint. The French Construction and Housing Code (Code de la construction et de l'habitation, CCH) requires it for sales, leases and in certain public buildings[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓.
Four label templates depending on the building's main use
In the commercial sector, the DPE does not come in “types”. There are four label templates, chosen according to the building's main use[2][2]RegulationFrench Ministry of Ecological Transition, “Energy performance certificate (DPE)”, label templates, end uses and method | ecologie.gouv.frSee in sources ↓:
• main use as offices, administration or education; • continuous occupancy, for example hospitals or care homes for the elderly (EHPAD); • shopping centers; • other buildings.
It is this first template that carries the energy class of offices.
Which buildings fall under the commercial DPE?
The DPE covers any building or part of a building used for commercial purposes: offices, shops, healthcare or education facilities. In a mixed-use building, housing and commercial premises are assessed separately. This is what the commercial DPE in mixed-use buildings covers.
Article R.126-15 of the CCH excludes several categories, including temporary structures and places of worship[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓.
Sale and lease of offices or retail premises
On a sale, the owner attaches the DPE to the technical diagnostics file. The mandatory office DPE also applies to leases. The CCH requires the DPE to be attached to the lease when it is signed, except for rural leases and seasonal rentals[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓.
The text does not exclude business premises. The retail premises DPE therefore follows the same obligation. Beyond the law, the weight buyers give to the label affects the green value of an asset.
New construction and extension of a commercial building
For a new construction or an extension, the building owner has the DPE carried out on completion. With no billing history, the assessment relies on a standardized calculation based on the design and its heated floor area. The details can be checked in the CCH[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓.
Public buildings: DPE and display obligation
Having a DPE and displaying it are two separate obligations. The display requirement targets public-access buildings (ERP, établissements recevant du public) of categories 1 to 4 and over 250 m². They must be occupied by a local authority or a public body[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. The 500 m² threshold still quoted belonged to an earlier stage of the text.
A DPE issued for the 2017 deadline lost its validity on 31 December 2022[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓[11][11]RegulationLégifrance, “Decree No. 2020-1610 of 17 December 2020 on the validity period of energy performance certificates (DPE)”See in sources ↓. Without renewal, the regulatory display then shows an expired document.
Validity period, renewal and risks of a missing or expired DPE
A DPE remains valid for 10 years[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. In practice, an update is needed as soon as major works or a change of use make the label wrong.
For DPEs issued before the 2021 reform, the validity period was shortened by Decree No. 2020-1610 of 17 December 2020: DPEs issued between 1 January 2013 and 31 December 2017 were only valid until 31 December 2022, and those issued between 1 January 2018 and 30 June 2021 until 31 December 2024[11][11]RegulationLégifrance, “Decree No. 2020-1610 of 17 December 2020 on the validity period of energy performance certificates (DPE)”See in sources ↓. This rule applies to all DPEs, commercial ones included: any certificate issued before 1 July 2021 has now expired. A missing or expired DPE weakens a sale as much as a lease.
Who can carry out a DPE for commercial buildings?
Only a certified assessor can carry out a DPE with the non-residential endorsement, the certification required for buildings other than housing. Check that endorsement in the official directory of energy assessors. Then ask a precise question: which consumption figures will they use, and over what period? The answer determines the entire calculation method.
Did you know? Every DPE carried out is filed in the ADEME database. The agency has been collecting these certificates since 2013 and has published a dataset dedicated to commercial buildings since 2021[3][3]Studies and reportsADEME, “Commercial-building DPE database” | data.ademe.frSee in sources ↓. The readings you provide therefore end up in a public observatory.
What budget should you plan for a commercial DPE?
The observed range is €500 to €2,500 depending on floor area, with no published reference year[4][4]Press and announcementsSelectra, “Cost of a commercial DPE”, year not statedSee in sources ↓. This is not a catalogue price: the number of end uses and the availability of meter readings move the quote. No DPE with the non-residential endorsement is free. An offer advertised as such should ring alarm bells.
Calculation method: what data does your label rely on?
Actual consumption or standardized method: what sets commercial buildings apart from housing
For an existing commercial building, the DPE relies on actual consumption: bills and readings per energy, whether electricity, gas or district heating[2][2]RegulationFrench Ministry of Ecological Transition, “Energy performance certificate (DPE)”, label templates, end uses and method | ecologie.gouv.frSee in sources ↓. The reference period is set by ministerial order. For a new building, with no history, the calculation remains standardized.
The residential DPE has followed a different logic since 2021. For a house or a dwelling, the standardized method calculates a theoretical consumption per unit of living area, without looking at the bills[2][2]RegulationFrench Ministry of Ecological Transition, “Energy performance certificate (DPE)”, label templates, end uses and method | ecologie.gouv.frSee in sources ↓. On the commercial side, taking bills into account brings building operation into the label.
DPE, Décret tertiaire, BACS and energy audit: four obligations, four logics
The four schemes compared on six criteria
| Criterion | Décret tertiaire | BACS Decree | Energy audit | Commercial DPE |
|---|---|---|---|---|
| Trigger | Commercial activity on 1,000 m² or more [8] | Installed HVAC power [5] | Company energy consumption: more than 2.75 GWh/year on average over three years [9] | Sale, lease, construction, display in public-access buildings [1] |
| Scope and threshold | 1,000 m² and over [8] | Over 290 kW since 1 January 2025, 70 to 290 kW by 1 January 2030 [5][6] | The company, not a single building [9] | Building or part of a building, exclusions under Article R.126-15 of the CCH [1] |
| Frequency | Annual reporting on OPERAT [8] | Equipment required by the deadlines [5][6] | Every 4 years [9] | Valid for 10 years [1] |
| What the scheme produces | Trajectory of -40% in 2030, -50% in 2040, -60% in 2050 [8] | System with the required functions, no NF EN ISO 52120-1 class imposed [5] | Costed action plan | Energy and climate labels [2] |
| Enforceability | Results-based obligation reported on OPERAT [8] | Equipment obligation [5] | Obligation to carry out the audit [9] | Information document [1] |
| Reference text | Decree No. 2019-771 [8] | Decrees No. 2020-887 and No. 2025-1343 [5][6] | Directive (EU) 2023/1791, transposed into Article L. 233-1 of the French Energy Code (Law No. 2025-391) [9] | Construction and Housing Code (CCH) [1] |
Four texts often target the same asset: the DPE, the Décret tertiaire (France's tertiary decree on energy savings in commercial buildings), the decree on building automation and control systems (BACS) and the energy audit. Yet each has its own purpose, trigger and penalty. The table lines them up on six criteria, with the DPE in the last column.
CEE energy-savings certificates (certificats d'économies d'énergie) follow a fifth logic: standardized operation sheet BAT-TH-116 funds a class A or B BMS[7][7]RegulationFrench Ministry of Ecological Transition, “Standardized operation sheet BAT-TH-116”See in sources ↓. Regulatory compliance and CEE eligibility are therefore two different things.
What the texts say
- Public display, 250 or 500 m²: the threshold is set in the CCH[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. See “Public buildings”.
- DPEs issued before 1 July 2021: all expired by 1 January 2025 at the latest (Decree No. 2020-1610)[11][11]RegulationLégifrance, “Decree No. 2020-1610 of 17 December 2020 on the validity period of energy performance certificates (DPE)”See in sources ↓. See “Validity period”.
- Leases: the obligation is set in the CCH[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. See “Sale and lease”.
Read column by column, the table shows that only the DPE takes a snapshot of a building. The other three texts impose a trajectory, equipment or a company-wide process.
Commercial DPE and Décret tertiaire: a snapshot versus a reduction trajectory
The DPE records a label at a given date. The Décret tertiaire imposes a trajectory from 1,000 m² of commercial activities. Consumption is reported every year on OPERAT (the French observatory platform for energy performance, renovation and actions in the tertiary sector)[8][8]RegulationLégifrance, “Decree No. 2019-771 on obligations to reduce final energy consumption in commercial buildings”See in sources ↓.
The targets are set at -40% in 2030, -50% in 2040 and -60% in 2050[8][8]RegulationLégifrance, “Decree No. 2019-771 on obligations to reduce final energy consumption in commercial buildings”See in sources ↓. The DPE and the Décret tertiaire share only one thing: your consumption. A good label closes no trajectory gap. Only measured energy savings do. To go further, read our articles on the Décret tertiaire, not to be confused with the DPE and on the EPBD directive and 2030 performance thresholds.
Commercial DPE or energy audit: a label snapshot or a costed action plan?
The DPE stops at the findings and indicative recommendations. The energy audit breaks down end uses, costs the works and prioritizes a costed action plan. Since 1 October 2025, whether a company is subject to it no longer depends on its size but on its consumption: more than 2.75 GWh of final energy per year on average over three years, with an audit every four years and a certified energy management system above 23.6 GWh (Directive (EU) 2023/1791, transposed by Law No. 2025-391 into Article L. 233-1 of the French Energy Code)[9][9]RegulationEuropean Union, “Directive (EU) 2023/1791 on energy efficiency”, transposed by Law No. 2025-391 of 30 April 2025 (French Energy Code, art. L. 233-1)See in sources ↓. The FAQ comes back to this. The carbon footprint remains a third exercise, separate from both.
Does your label measure your building fabric or your operation?
Self-assessment: the share of operation in your label
Does your label measure your operation?
The result remains a tentative estimate. It replaces neither an audit nor the DPE.- 1. Are manual overrides active in the BMS?
- 2. Have setpoints been changed since handover?
- 3. Are comfort complaints handled case by case?
- 4. Have the meters never been checked?
- 5. Have optimal start times never been reviewed?
On an existing building, the label relies on actual consumption. It therefore also records how the building is run. The five questions below estimate that share, starting with manual overrides forgotten in the BMS. Answer for one specific building, not for the whole portfolio.
If your answers lean towards “yes” or “I don't know”, part of the label probably measures how the building is run rather than its fabric. Taking operation into account then changes how the report should be read. At Valeo, measurement under the International Performance Measurement and Verification Protocol (IPMVP) established -28.6% HVAC consumption, with no works[10][10]Field feedbackFoobot, operational feedback, Valeo case study (HVAC consumption measured under the IPMVP protocol)See in sources ↓. That is a measurement on one site, not a promise for yours.
What we do around your commercial DPE, without carrying it out
Making meters reliable before the label is renewed
Our BMS advisory starts with metering. We check that the sum of the sub-meters matches the main meter, month by month and per energy. We spot disconnections, gaps in the history, duplicates and invisible drifts. You then hand the assessor readings whose reliability you know.
One silent meter, three false reports
→ 3 false reports
Putting operation back in order: manual overrides, setpoints and sequences
Our Operations advisory covers how the building is run. We remove forgotten manual overrides and restore consistent sequences. Alarms are sorted so the operator sees the ones that matter. On a recent building, we also follow handover and the warranty year (GPA, the defects liability period), with functional tests.
The complaint lasts an hour, the override a quarter
→ 1,534 h of needless running
Redoing your commercial DPE on data you have checked
Before renewing a commercial DPE, three checks follow in this order. Meters first: the label is only as good as the readings handed to the assessor. Operation next: manual overrides, setpoints, optimal start times. Works last, costed on a building whose consumption reflects its fabric rather than its settings. Reversing this order means paying to fix an energy problem that nobody has measured. Once your meters are reliable, control becomes the logical next step.
control the building to improve the DPE
Further reading:
Where the figures on your label come from
- 1Main meterEntry point for each energy.Breaking pointMeter disconnected after an intervention
- 2Sub-metersBreakdown by zone, end use or tenant.Breaking pointMeter counted twice
- 3Readings and bills per energyElectricity, gas, district heating.Breaking pointGaps in the history
- 4Consumption usedWhat the assessor enters into the calculation.Breaking pointReference period not checked
- 5Energy and climate labelClass displayed and passed on to the parties.Breaking pointTenant recharges wrongly allocated
- 6ADEME public databaseCollected since 2013, commercial dataset published since 2021.Breaking pointError published and searchable
Three milestones where consumption drifts while the building fabric stays the same
- Milestone 1 · Handover Sequences validated on paper The BMS is accepted point by point. Complete sequences rarely run under real conditions before delivery.
- Milestone 2 · End of the one-year defects warranty (GPA) The VIP complaint settled with a manual override An occupant asks for more heat. The setpoint is forced instead of fixing the sequence, and the manual override stays in place.
- Milestone 3 · Three years later Degraded mode and lost traceability Equipment runs in degraded mode, changes are no longer documented. Consumption creeps up, the envelope stays the same.
FAQ - Commercial DPE
When is a commercial DPE mandatory?
It is required on a sale, when premises are let and on completion of a new building[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. Public-access buildings occupied by a local authority or a public body must also display it[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. Outside these triggers, no periodic renewal is required.
Which buildings are covered by the commercial DPE?
It covers any building used for commercial purposes: offices, shops, hospitals, education or accommodation facilities. A mixed-use building falls under the scheme for its commercial parts. Article R.126-15 of the CCH lists the exclusions, to be checked before ordering anything[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓.
Energy audit: what are the obligations of large companies?
The regulatory energy audit targets the company, not a single building. Since 1 October 2025, the criterion is no longer the company's size but its consumption: more than 2.75 GWh of final energy per year on average over three years, an audit every four years, and a certified energy management system above 23.6 GWh (Law No. 2025-391 transposing Directive (EU) 2023/1791)[9][9]RegulationEuropean Union, “Directive (EU) 2023/1791 on energy efficiency”, transposed by Law No. 2025-391 of 30 April 2025 (French Energy Code, art. L. 233-1)See in sources ↓. The audit leads to a costed action plan.
What is the commercial DPE?
It is the assessment that gives a non-residential building an energy label and a climate label, linked to greenhouse gas emissions[2][2]RegulationFrench Ministry of Ecological Transition, “Energy performance certificate (DPE)”, label templates, end uses and method | ecologie.gouv.frSee in sources ↓. In the commercial sector, the DPE remains a snapshot. It replaces neither the audit nor the carbon footprint.
Why carry out a commercial DPE?
First, because the law requires it for sales, leases and public display[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. Second, because it gives the owner a benchmark shared with buyers and tenants. Provided the DPE is carried out on verified consumption data.
What floor area requires a commercial DPE?
A transaction triggers the DPE, not a floor area. The exclusions are listed in Article R.126-15 of the CCH[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. For display in public-access buildings, the threshold is 250 m²[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. The label's ratios are then expressed per unit of heated floor area.
What are the four types of DPE?
They are four label templates, not four DPEs[2][2]RegulationFrench Ministry of Ecological Transition, “Energy performance certificate (DPE)”, label templates, end uses and method | ecologie.gouv.frSee in sources ↓: main use as offices, administration or education; continuous occupancy, such as hospitals; shopping centers; other buildings. The template depends on the building's dominant use.
Is the commercial DPE mandatory for leases?
Yes. Article L.126-29 of the CCH requires the DPE to be attached to the lease when it is signed, including for retail or office premises[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. Some sources still claim otherwise: rely on the text in force.
How long is a commercial DPE valid?
A commercial DPE remains valid for 10 years[1][1]RegulationLégifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)See in sources ↓. However, DPEs issued before 1 July 2021 lost their validity on 31 December 2024 at the latest (Decree No. 2020-1610)[11][11]RegulationLégifrance, “Decree No. 2020-1610 of 17 December 2020 on the validity period of energy performance certificates (DPE)”See in sources ↓. A new DPE is required if it has expired at the time of a transaction.
What is the calculation method of the commercial DPE?
For an existing building, the label relies on actual metered consumption[2][2]RegulationFrench Ministry of Ecological Transition, “Energy performance certificate (DPE)”, label templates, end uses and method | ecologie.gouv.frSee in sources ↓. A new building, with no history, goes through a calculation. The residential DPE, for its part, is calculated on living area. The assessor must hold the non-residential endorsement.
SourcesSources and references
11 sources.- [1]Légifrance, Construction and Housing Code (Code de la construction et de l'habitation), DPE provisions (validity, sale, lease, display in public-access buildings, R.126-15 exclusions)↑ 1 2 3 4 5 6 7 8 9 11 12 13 14 15 16 17 18 19
- [2]French Ministry of Ecological Transition, “Energy performance certificate (DPE)”, label templates, end uses and method | ecologie.gouv.fr↑ 1 2 3 4 5 6 7
- [5]Légifrance, “Decree No. 2020-887 on building automation and control systems in non-residential buildings”07/2020
- [6]Légifrance, “Decree No. 2025-1343”, postponement of the BACS deadline for 70 to 290 kW buildings26/12/2025
Show the other 4: [7] to [11]
- [7]French Ministry of Ecological Transition, “Standardized operation sheet BAT-TH-116”↑
- [8]Légifrance, “Decree No. 2019-771 on obligations to reduce final energy consumption in commercial buildings”07/2019↑ 1 2
- [9]European Union, “Directive (EU) 2023/1791 on energy efficiency”, transposed by Law No. 2025-391 of 30 April 2025 (French Energy Code, art. L. 233-1)09/2023↑ 1 2
- [11]Légifrance, “Decree No. 2020-1610 of 17 December 2020 on the validity period of energy performance certificates (DPE)”17/12/2020↑ 1 2 3 4 5
- [3]ADEME, “Commercial-building DPE database” | data.ademe.fr↑
- [4]Selectra, “Cost of a commercial DPE”, year not stated↑
- [10]Foobot, operational feedback, Valeo case study (HVAC consumption measured under the IPMVP protocol)↑