A label is earned at delivery; performance has to be proven every year. The Décret tertiaire (France's tertiary decree on energy savings in commercial buildings) compares each building's actual consumption with its reference year. Its first milestone is set at -40% in 2030[1][1]RegulationLégifrance, “Decree No. 2019-771 of 23 July 2019 on obligations to reduce final energy consumption in commercial buildings” (Décret tertiaire)See in sources ↓. Sustainable real estate is therefore no longer decided at construction or in the renovation project alone. It rests on data that few portfolios can produce: consumption measured building by building. It is the only defensible basis for energy performance in the commercial sector.
What is sustainable real estate, in practice?
A definition built on three pillars: environmental, social and governance
Sustainable real estate refers to a portfolio designed, built and then operated to limit its environmental impact over its whole life cycle. It also ensures occupant comfort and is accountable for how it is managed. The definition applies to commercial real estate as well as to housing.
From this follow the environmental, social and governance criteria. The first pillar measures environmental performance: consumption, emissions, low-carbon materials. The social pillar covers thermal comfort, accessibility and the social impact of a project. Governance looks at who decides and who checks. In France, this definition now has a quantified translation with the Décret tertiaire, a French obligation.
The variants mostly differ in angle. Green real estate targets environmentally friendly buildings; low-carbon real estate targets the footprint of materials and energy. Responsible real estate looks at how the investment treats its environment and its users. All of them talk about responsible buildings, rarely about the same thing.
Which frameworks apply to a French property company?
The French and European obligations that apply to the portfolio
The Décret tertiaire requires sites of 1,000 m² and more to follow an energy performance trajectory checked every year[1][1]RegulationLégifrance, “Decree No. 2019-771 of 23 July 2019 on obligations to reduce final energy consumption in commercial buildings” (Décret tertiaire)See in sources ↓. The DPE for commercial buildings (DPE, the French Energy Performance Certificate, or EPC) completes this framework, but it informs without prohibiting anything, unlike the DPE for housing.
At EU level, the European taxonomy defines aligned assets[2][2]RegulationEUR-Lex, “Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment” (Taxonomy Regulation)See in sources ↓. The SFDR then requires funds to disclose the impacts of their investments[3][3]RegulationEUR-Lex, “Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector” (SFDR)See in sources ↓. The CSRD requires companies to report, with energy covered by ESRS E1, energy in the CSRD[4][4]RegulationEUR-Lex, “Directive (EU) 2022/2464 as regards corporate sustainability reporting” (CSRD)See in sources ↓.
The EPBD directive, as recast, sets minimum performance standards for the non-residential stock[5][5]RegulationEUR-Lex, “Directive (EU) 2024/1275 on the energy performance of buildings (recast)” (EPBD)See in sources ↓. The Omnibus directive known as “stop-the-clock” postponed CSRD waves 2 and 3 by two years[6][6]RegulationEUR-Lex, “Directive (EU) 2025/794”, known as “stop-the-clock”, postponing CSRD waves 2 and 3 by two yearsSee in sources ↓. Check its final status on EUR-Lex before planning a reporting project.
What investors ask for: GRESB, CRREM and in-use certifications
None of these frameworks is mandatory. Yet they determine financing and asset liquidity in the real estate sector. The GRESB score rates funds and property companies every year on their ESG management. The ISR label (France's public socially responsible investment label), awarded to funds, adds its own criteria.
CRREM translates transition risk into a decarbonization pathway for each asset. Cross-checked with actual consumption, it gives the stranding date: the year the asset leaves its pathway. We cover CRREM and the stranding date of your assets separately, as well as in-use certifications, which also take adaptation to climate change into account.
What each text really requires of a commercial asset
Seven criteria for judging an energy case study
Open a criterion to see what to check, then tick the ones you find in the study you are reading.-
A 25% drop in heating alone is not worth 25% on the building's bill. The study must name the end uses covered (HVAC, lighting, whole building) and the meters used for the measurement, so that you can relate the saving to your own consumption.Red flag: “-30% energy” without specifying either the end use or the meter.Specified in the Valeo case: HVAC
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The saving is calculated against a baseline. For a weather-dependent end use, this baseline must cover a full operating cycle, in practice twelve months, otherwise you end up comparing a winter with a spring.Red flag: a “month-on-month” comparison with no annual baseline period.
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Degree days (heating degree days, HDD, called DJU in France) express how harsh the climate was over a period. Correcting for them makes it possible to compare two heating or cooling seasons under equivalent weather. Without this correction, a mild winter passes for a saving.Red flag: heating savings announced over a winter milder than the baseline, with no mention of degree days.Applied in the Valeo case
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The IPMVP (International Performance Measurement and Verification Protocol, published by the Efficiency Valuation Organization) sets out how to prove a saving. It offers four options: A and B measure an isolated piece of equipment, C measures the whole building at the meter, D relies on a calibrated simulation. A serious study states which one it followed.Red flag: “up to X% savings” or “estimated saving” with no method cited.Followed in the Valeo case
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A vacant floor, widespread remote working or reduced hours lower consumption without changing anything in the controls. The study must list these factors unrelated to the action and explain how it neutralized them.Red flag: no mention of the occupancy rate over the measured period.
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A replaced boiler, new insulation and optimized controls neither cost the same nor deliver the same return on investment. A useful study separates what comes from the equipment from what comes from the way it is operated; otherwise you do not know what to replicate in your own buildings.Red flag: a single overall figure for a deep renovation and a settings change carried out at the same time.
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Settings drift over time: manual overrides never released, setpoints changed after a complaint, schedules forgotten after a change of occupant. A saving measured over three months says nothing about the following year. Look for a measurement over at least one full season and follow-up after the first year.Red flag: a result published right after commissioning, with no measurement end date.
Here, text by text, is what you will be asked to prove. The table compares regulations and investor frameworks, never commercial offers.
| Text | Scope | Type | Deadline | Expected proof |
|---|---|---|---|---|
| RE2020 (French regulation for new buildings) | New construction | Results-based obligation | Building permit application | Energy and carbon calculation, certificate on completion |
| Décret tertiaire[1][1]RegulationLégifrance, “Decree No. 2019-771 of 23 July 2019 on obligations to reduce final energy consumption in commercial buildings” (Décret tertiaire)See in sources ↓ | Commercial buildings of 1,000 m² and more | Results-based obligation | -40% in 2030, -50% in 2040, -60% in 2050 | Annual consumption declared on OPERAT (the French government's consumption reporting platform) |
| BACS decree[7][7]RegulationLégifrance, “Decree No. 2020-887 of 20 July 2020 on building automation and control systems in non-residential buildings” (BACS decree)See in sources ↓[8][8]RegulationLégifrance, “Decree No. 2025-1343 of 26 December 2025”, postponing the BACS deadline for 70 to 290 kW systems to 1 January 2030See in sources ↓ | HVAC over 290 kW, then 70 to 290 kW | Means-based obligation | 1 January 2025, then 1 January 2030 | Building automation and control system in place |
| Taxonomy, activity 7.7[9][9]RegulationEUR-Lex, “Commission Delegated Regulation (EU) 2021/2139” (Taxonomy Climate Delegated Act), Annex I, activity 7.7 “Acquisition and ownership of buildings”See in sources ↓ | Acquisition and ownership of buildings | Investor demand | Annual reporting | DPE A or top 15% of the national building stock |
| EPBD[5][5]RegulationEUR-Lex, “Directive (EU) 2024/1275 on the energy performance of buildings (recast)” (EPBD)See in sources ↓ | Non-residential stock | Results-based obligation, after transposition | Depending on national transposition | Minimum performance standards met |
| CSRD with Omnibus[4][4]RegulationEUR-Lex, “Directive (EU) 2022/2464 as regards corporate sustainability reporting” (CSRD)See in sources ↓[6][6]RegulationEUR-Lex, “Directive (EU) 2025/794”, known as “stop-the-clock”, postponing CSRD waves 2 and 3 by two yearsSee in sources ↓ | Large companies | Means-based obligation | Waves 2 and 3 postponed by two years | ESRS E1 data verified by a third party |
| SFDR[3][3]RegulationEUR-Lex, “Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector” (SFDR)See in sources ↓ | Funds and asset management companies | Means-based obligation | Applicable since 2021 | Principal adverse impact indicators |
| GRESB | Funds and property companies | Investor demand | Annual assessment | Consumption and meter coverage |
| CRREM | Asset by asset | Investor demand | Asset-specific stranding date | Measured energy and carbon intensity |
| Adaptation commitment charter (OID)[10][10]Studies and reportsObservatoire de l'Immobilier Durable (OID), “Charter of commitment to climate change adaptation” and resource centerSee in sources ↓ | Signatories | Voluntary commitment | Set by the charter | Documented adaptation approach |
Read the last column from top to bottom: almost everywhere, you are asked for measured consumption. Yet a class is not a performance. An asset that is compliant on the day it is delivered can overconsume three years later if operations do not keep up.
Did you know? The BACS decree (French decree 2020-887 on building automation and control systems) does not impose any NF EN ISO 52120-1 class: it sets its own functional requirements[7][7]RegulationLégifrance, “Decree No. 2020-887 of 20 July 2020 on building automation and control systems in non-residential buildings” (BACS decree)See in sources ↓. Compliance and eligibility for CEE energy-savings certificates under standardized sheet BAT-TH-116 follow two separate logics[11][11]RegulationFrench Ministry for Energy, “CEE standardized operation sheet BAT-TH-116”, building management system for heating, domestic hot water, cooling/air conditioning, lighting and auxiliariesSee in sources ↓. And a building's class is that of its weakest function[12][12]StandardsAFNOR, “NF EN ISO 52120-1” (formerly EN 15232), performance classes of building automation and control systemsSee in sources ↓.
If you want to see what this proof looks like on real assets, we have before-and-after measurements.
One problem remains: this proof ages badly. The next section shows where it gives way.
Where an asset's sustainability is won and lost
Construction, renovation, operation: where the carbon footprint sits over the life cycle
Over an asset's life cycle, the carbon footprint builds up in two stages. Construction locks in the carbon of the materials. RE2020 therefore steers new construction towards environmentally friendly buildings and low-carbon, eco-friendly materials. Operation then adds greenhouse gases every year, for as long as the building is heated and cooled.
Decarbonizing the real estate portfolio then becomes a project trade-off. A deep renovation addresses the envelope but commits new carbon and construction work. Controlling existing systems better reduces the environmental impact of operation without any works. This debate comes up at every edition of SIBCA, the annual event for low-carbon real estate.
Everything rests on consumption data per building
Where do the figures in a report come from?
Real estate ESG reporting aggregates four families of figures. Invoices give a total, often with a time lag. Meters give the detail, when they are connected. BMS trend logs provide hourly granularity, if someone has archived them. The rest is estimated. It is with this mix that energy consumption gets declared on OPERAT, and that a carbon footprint is then derived from it.
Why are most real estate reports wrong at the source?
Our position: most real estate reports are wrong at the source. Not through fraud, but through accumulation. A disconnected meter leaves a gap that the tool fills with an average. A sub-meter counted twice inflates a floor. A misallocated meter shifts consumption from one site to another. A cold year compared with a mild one without weather correction looks like drift.
Make data reliable, then control: Foobot's role on your commercial assets
BMS advisory: making meters and consumption histories reliable
Our BMS advisory starts with the meters: disconnections, data gaps, duplicates, invisible drift. This work requires no construction and is valuable in its own right. Reliable energy data makes reporting defensible. There is not necessarily an AI phase afterwards.
BMS advisory: testing at handover, then removing manual overrides in operation
A BMS handed over with no snags is not a tested BMS. We step in at handover, during the warranty year (defects liability period, GPA in France) and after commissioning. The action plan comes down to three moves: remove the manual overrides, bring the sequences back into line and keep only useful alarms. (An alarm that goes off every day ends up acknowledged without being read.)
An asset's performance is proven meter by meter
A label describes an asset on the day it is delivered. The Décret tertiaire, the CSRD and investors look at what it consumes every year. The gap between the two can be read in the meters, and nowhere else. Sustainable commercial real estate is therefore built in this order: make data reliable first, optimize second. Reliable meters make reporting defensible in front of an auditor. Sequences put back in order stop the drift. AI only comes afterwards, if the building justifies it. Before your next declaration or your next investment decision, ask yourself which meters in your portfolio tell the truth. That is where we start.
make your consumption data reliable
Further reading:
Four milestones, and consumption that slips without a sound
- Milestone 1 · Design Performance calculated, not yet measured For new buildings, RE2020 assesses an energy and carbon calculation submitted with the building permit application. No meter has run yet.
- Milestone 2 · Handover An asset compliant on paper Commissioning checks that the equipment starts up. A BMS handed over with no snags has not necessarily been tested under real conditions.
- Milestone 3 · Warranty year The last window to get things fixed During the one-year completion warranty (garantie de parfait achèvement), the contractor that delivered the system still corrects its sequences. The BACS decree already requires a building automation and control system to be in place.
- Milestone 4 · Three years later Performance is finally measured The Décret tertiaire compares the consumption declared on OPERAT with the reference year. The manual overrides that have piled up weigh on the figure.
FAQ - sustainable real estate
What is the minimum/maximum amount to invest in sustainable real estate?
There is no fixed amount. The entry ticket depends on the vehicle chosen: a share in a labeled real estate fund, or a unit-linked fund in a French life insurance policy (assurance vie) or retirement savings plan. It is stated in the key information document of every real estate investment open to the general public.
What criteria define sustainable real estate?
The criteria are environmental, social and governance. The environment is judged on measured energy performance, embodied carbon from construction and eco-friendly materials. The social dimension covers thermal comfort and accessibility. Governance concerns the quality of building control and of the data.
What classification exists for sustainable real estate?
No single classification is authoritative on its own. The European taxonomy defines aligned activities, including the acquisition and ownership of buildings[2][2]RegulationEUR-Lex, “Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment” (Taxonomy Regulation)See in sources ↓[9][9]RegulationEUR-Lex, “Commission Delegated Regulation (EU) 2021/2139” (Taxonomy Climate Delegated Act), Annex I, activity 7.7 “Acquisition and ownership of buildings”See in sources ↓. The ISR label qualifies funds. The DPE for commercial buildings is often based on metered consumption, whereas the DPE for housing is calculated.
How do you invest in sustainable real estate?
For the general public, investing in real estate goes through labeled funds, held in a life insurance policy or a retirement savings plan. For a property company, it means buying assets whose consumption is measured, not just labeled at delivery.
What is the role of real estate professionals?
Awareness is already there in the real estate sector. The challenges of real estate now lie in execution: the asset manager sets the pathway, the property manager tracks service charges and the operator holds the setpoints. All of them need to know how to read consumption data.
How can you get trained in sustainable real estate?
Sustainable real estate training is available at school, through continuing education or from industry organizations. The resource center of the Observatoire de l'immobilier durable (OID, the French sustainable real estate observatory) publishes guides and case studies[10][10]Studies and reportsObservatoire de l'Immobilier Durable (OID), “Charter of commitment to climate change adaptation” and resource centerSee in sources ↓. Supplement this by reading the texts themselves: Décret tertiaire, taxonomy and CSRD.
SourcesSources and references
12 sources. The numbered references in the text correspond to the following documents.- [1]Légifrance, “Decree No. 2019-771 of 23 July 2019 on obligations to reduce final energy consumption in commercial buildings” (Décret tertiaire)23 July 2019↑ 1 2 3
- [2]EUR-Lex, “Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment” (Taxonomy Regulation)18 June 2020↑ 1 2
- [3]EUR-Lex, “Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector” (SFDR)27 November 2019↑ 1 2
- [4]EUR-Lex, “Directive (EU) 2022/2464 as regards corporate sustainability reporting” (CSRD)14 December 2022↑ 1 2
- [5]EUR-Lex, “Directive (EU) 2024/1275 on the energy performance of buildings (recast)” (EPBD)24 April 2024↑ 1 2
- [6]EUR-Lex, “Directive (EU) 2025/794”, known as “stop-the-clock”, postponing CSRD waves 2 and 3 by two years14 April 2025↑ 1 2
- [7]Légifrance, “Decree No. 2020-887 of 20 July 2020 on building automation and control systems in non-residential buildings” (BACS decree)20 July 2020↑ 1 2
- [8]Légifrance, “Decree No. 2025-1343 of 26 December 2025”, postponing the BACS deadline for 70 to 290 kW systems to 1 January 203026 December 2025↑
- [9]EUR-Lex, “Commission Delegated Regulation (EU) 2021/2139” (Taxonomy Climate Delegated Act), Annex I, activity 7.7 “Acquisition and ownership of buildings”4 June 2021↑ 1 2
- [11]French Ministry for Energy, “CEE standardized operation sheet BAT-TH-116”, building management system for heating, domestic hot water, cooling/air conditioning, lighting and auxiliaries↑
- [12]AFNOR, “NF EN ISO 52120-1” (formerly EN 15232), performance classes of building automation and control systems↑