Legislation & Regulation / What Ireland’s BER Changes Mean for Energy, Carbon and Value

What Ireland’s BER Changes Mean for Energy, Carbon and Value

Topic: Legislation & Regulation

Ireland’s Building Energy Rating (BER) system changed on 24 May 2026, introducing a a simplified rating scale for both domestic and non-domestic buildings.  The change is more than a new set of letters. It affects how buildings are assessed, how their energy performance is understood and, increasingly, how owners need to think about carbon, investment and future asset decisions. 

For owners and asset managers, the key question is not simply what BER an asset has today, but what that rating means under the new methodology – and what it could mean for the asset commercially. 

What has changed?

The 2026 BER changes form one part of Ireland’s wider implementation of the revised Energy Performance Building Directive (EPBD), with further requirements still to come. Ireland introduced the new BER methodology and rating scale ahead of the 29 May 2026 deadline for EU Member States to notify the European Commission of their transposition measures. The European Commission subsequently opened infringement procedures against all 27 Member States for failing to fully transpose the recast EPBD by the deadline. 

The previous BER system used 15 subcategories, including A1, A2, A3, B1, B2 and B3. These have now been replaced with a simplified eight-level scale:  A0, A, B, C, D, E, F and G. 

 A0 is Ireland’s highest Building Energy Rating and identifies a Zero Emission Building (ZEB). It recognises buildings with exceptionally low energy demand, no on-site fossil fuel use and very low operational carbon emissions. While the rating can be achieved by both new and existing buildings, the most significant change is for new construction: all new public buildings must meet Zero Emission Building standards from 2028, with the requirement extending to all new buildings from 2030. 

The methodology used to calculate the rating has also changed. As a result, historic and new BER ratings may not be directly comparable, particularly for non-domestic buildings. There is also greater visibility of carbon. The new BER certificate includes information on energy use, renewable energy contribution and whole-life carbon emissions, measured through global warming potential (GWP). 

Existing BER certificates, however, do not simply disappear. They remain valid for up to 10 years, subject to the circumstances that require a new assessment.  This creates an important distinction: a BER can remain legally valid while no longer giving an owner a clear picture of where the asset would sit under today’s methodology.  Energy performance and carbon are not the same thing  One of the most important points to understand is that a BER is not simply a carbon rating. 

The BER primarily measures a building’s energy performance using primary energy. Carbon is now more visible within the assessment, but a change in carbon emissions does not automatically translate into the same movement in BER. 

This matters when reviewing existing assets. 

Recent reassessments show a mixed picture across asset types. Some assets have improved or remained broadly stable, while others have moved down under the new methodology. For example, an existing office moved from B3 to B, while a retail asset moved from C2 to D and a PBSA asset from B3 to C. This highlights why BER movement should not be interpreted in isolation. Changes in the rating need to be considered alongside the underlying energy and carbon performance, as the new methodology can produce different outcomes across asset types.

The important point is not that one measure is “right” and the other is “wrong”. The asset is being assessed against a different methodology. The same distinction is relevant when considering renewable energy. Solar PV can reduce operational carbon by displacing grid electricity, but its impact on the BER depends on factors including primary-energy calculations, self-consumption, export and the building’s demand profile. Energy performance and carbon performance therefore need to be considered together, rather than treated as interchangeable measures. 

Why does this matter for asset owners?

The change becomes important when a BER feeds into a wider commercial decision. 

Finance
A historic BER may remain valid but may not reflect how an asset would perform under the new methodology. For assets approaching refinancing, understanding the current and potential position can help identify exposure early. 

Leasing
For multi-let assets, owners may need to consider whole-building performance alongside individual occupier requirements and improvements. The question is not just whether the BER is valid, but whether it provides a useful picture of current performance. 

Valuation and disposal
A historic BER should not automatically be treated as a proxy for current performance. Understanding the asset under the new methodology can provide greater clarity ahead of a sale, refinancing or investment decision. 

Capex planning
Where improvements are already being considered, understanding the asset’s likely position under the new framework can help inform investment priorities and sequencing. 

Which assets need the most attention?

Priority is likely to be higher where assets have: 

  • an older BER and an upcoming lease, refinancing or sale; 
  • recent or planned energy and decarbonisation works; 
  • significant capital expenditure planned; 
  • inconsistent BER data across a portfolio; or 
  • insufficient information to support an upcoming investment decision. 
  •  BER is only one part of the wider EPBD transition. For owners, the implications also extend to renovation requirements, zero-emission building standards, non-residential performance and the treatment of on-site renewables such as solar. Together, these changes point towards a longer-term shift in how building performance is assessed, improved and managed. 

From compliance to asset management

The 2026 BER changes do not make existing certificates irrelevant. They do, however, change the context in which those certificates should be interpreted.  A valid BER is one piece of information. Understanding the methodology behind it, the building’s energy and carbon performance, planned capital expenditure and the asset’s wider commercial context provides a more useful picture. 

For owners and asset managers, the practical questions are therefore: 

  • Where would this asset sit if assessed today?
  • What does that mean for its energy and carbon performance?
  • And could that affect a financing, leasing, valuation or investment decision?

The value of the new BER framework will ultimately depend not just on the rating itself, but on how effectively owners use the information behind it to make decisions about their assets.  

We’re helping clients rescreen live portfolios against the new BER mechanics, understand where legacy ratings and current performance have diverged, and build the evidence base needed to support the next lease, refinance or transaction. If you’re not yet sure where your Irish portfolio stands under the new scale, that’s the place to start. 

Start the conversation now. Get in touch.

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