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Energy performance certificate for commercial property: what it costs and why there is no fixed price

Marco Bisch

Energieberater

As of:

You own an office building, a row of shops or a hall and need an energy performance certificate — and find that nobody quotes you a price, but everyone asks questions first. That is not evasion. For a residential building the law prescribes a narrow scope of services, which is why there is a list price there; for a non-residential building it does not, and that is why there you get a quotation.

Four-storey commercial building with shops on the ground floor and ventilation units on the flat roof; on the left a building section with colour-coded zones for shop, office and storage, an efficiency scale and the heading “Energieausweis fürs Gewerbe – Warum kein Festpreis?” (energy certificate for commercial property – why no fixed price?).
There is no list price for commercial property: floor area, use, zoning and building services determine the effort.

This article explains what the effort actually consists of, which four factors drive it, why there are no reliable statistics on prices for commercial properties and what you can use as a reference point instead. After that it covers the change that removes the cheap option from 1 January 2027, the documents that reduce the effort, and the question of who pays for let units.

Why does the energy performance certificate for a commercial property cost more than for a house?

Because it has to contain more. A consumption certificate (Verbrauchsausweis) for a residential building covers two uses: heating and hot water. For a non-residential building (Nichtwohngebäude), § 82 (2) of the Building Modernisation Act (Gebäudemodernisierungsgesetz, GModG) requires the final energy consumption for heating, hot water, cooling, ventilation and built-in lighting — five uses, related to the net floor area instead of the usable floor area.6 What a non-residential building is in the first place, when it needs a certificate and when it has to be displayed is set out in the overview energy performance certificate for non-residential buildings.

The difference in the reference area quickly becomes expensive in the calculation, because it also shapes the data collection.

Net floor area (Nettogrundfläche) NGF

The net floor area is the reference area of a non-residential building in the energy performance certificate: the usable area under DIN V 18599, insofar as it is heated or cooled. Besides the actual usable area it also includes technical function areas and circulation areas, but not the floor areas of walls and columns. For residential buildings the usable floor area (Gebäudenutzfläche) applies instead.

Then there are the mandatory details. For a non-residential building, § 85 (2) GModG requires the building zones with their respective net floor area and their share of the total area, the breakdown of the annual final energy demand across all five uses, and the final energy demand for heat and for electricity separately. A certificate for a residential building has none of this.

The second reason is economic, not technical: there is no fee schedule for the service “energy performance certificate”. The Chamber of Architects Baden-Württemberg states that such services cannot be remunerated under the Fee Structure for Architects and Engineers (HOAI) and recommends a free agreement instead.13 For residential buildings the market bridges this with standardised online procedures and fixed prices — 69.90 € for the consumption certificate, 119.90 € for the demand certificate. What these prices cover is set out in what an energy performance certificate costs. For a non-residential building, standardisation only goes as far as the building itself is standard.

What distinguishes the certificate for a non-residential building from the residential certificate
Criterion Residential building Non-residential building
Uses recorded heating, hot water heating, hot water, cooling, ventilation, built-in lighting
Reference area usable floor area net floor area
Zones in the certificate none every zone with area and share
Energy performance indicator one value heat and electricity separately
Consumption data heat, 36 months heat and electricity, 36 months each
Pricing list price possible freely agreed fee

What does the price depend on — floor area, use, zoning, building services?

Four factors decide, and they do not carry equal weight.

Zoning is the strongest lever. The calculation standard DIN V 18599 provides its own usage profiles for non-residential buildings; each zone gets its own boundary conditions for temperature, hours of use, lighting and air change. A building that breaks down into eight zones is not eight times as much work as a single-zone one — but considerably more. That is precisely why the Act provides a shortcut: § 32 GModG permits a single-zone model if five conditions are met together and the building belongs to one of six types.2 For existing buildings the rule applies accordingly via § 38 (3) GModG.

Five conditions of the single-zone model — they apply together

  • The main use and circulation areas account for more than two thirds of the net floor area
  • All rooms are heated and supplied with hot water in the same way
  • The building is not cooled
  • No more than ten per cent of the area has incandescent lamps, halogen lamps or indirect lighting
  • Outside the main use, no ventilation system with above-average power consumption is in operation
Building types for which the simplified single-zone method is permitted, with their limits
Building type Limit
Office building, also with a sales outlet, commercial business or restaurant no area limit
Wholesale and retail no more than 1,000 m² net floor area
Commercial business no more than 1,000 m² net floor area
School, gymnasium, nursery, day-care centre no area limit
Accommodation establishment without swimming hall, sauna and wellness area
Library no area limit

The third condition is where most properties fail: air conditioning. § 32 (4) GModG allows an exception if, in an office building, only a sales outlet, a commercial business or a restaurant is cooled and the cooled area does not exceed 450 square metres in each case. A fully air-conditioned office building falls outside — and is calculated with zoning.

Floor area comes next. It drives measuring, recording of building elements and plausibility checks. How strongly can be read from an official figure, even though it relates to a different service: in Module 2 of its federal funding for energy consulting for non-residential buildings, the Federal Office for Economic Affairs and Export Control (BAFA) funds energy consulting to DIN V 18599 at 50 per cent of the eligible fee and staggers the maximum grant by heated or cooled net floor area.10

Maximum grant under BAFA funding Module 2 by net floor area, as of September 2026
Net floor area Maximum grant Fee up to which the grant still grows
under 200 m² €850 up to €1,700
200 to 500 m² €2,500 up to €5,000
more than 500 m² €4,000 up to €8,000

The third column does not appear as such in the guideline; it is the inverse of the 50 per cent funding rate and shows up to which fee the grant still grows at all.

The building services determine how hard the data is to obtain. The German Energy Agency (dena) describes this soberly in its guide: for non-residential buildings the heating energy data is usually available centrally and relatively easy to record. Electricity consumption is considerably more difficult — in a shopping centre the electricity consumption for lighting and air conditioning of the individual retail units must also be available, and without central meters the only option is to ask every single user. That is the item that blows a budget, and it depends not on the building but on its metering structure.

The inspection is the fourth factor. § 84 (1) GModG requires the issuer to inspect an existing building on site or have suitable photographs provided for the assessment, and to give modernisation recommendations. Both are permitted; the on-site appointment costs more and, in dena’s assessment, finds savings potential that rarely stands out remotely — for non-residential buildings especially in cooling, humidification and lighting.

Which price ranges are realistic, and where do the figures come from?

There are no reliable price statistics for energy performance certificates for non-residential buildings — and that is the honest answer to this question. Neither the Federal Statistical Office nor the consumer advice centres (Verbraucherzentralen), co2online, dena or any chamber of engineers or architects collects such data. What you can google are quoted prices from individual providers — each for its own scope of services, without disclosed methodology and without any statement of what that scope covers for your building. Presenting such figures as a market price would be convenient and wrong, which is why they are not here.

What you have instead is better than a range, because you can calculate with it:

  • The BAFA scale above shows the order of magnitude and the increase with floor area — from an official source.
  • A quotation is a specification of services. Because the fee is freely agreed, the only sensible question is not “What does it cost?” but “What service does it include?”. Two quotations are only comparable if both assume the same zoning, the same data collection and the same kind of inspection.
  • The certificate is not funded. Anyone waiting for a grant waits in vain; BAFA expressly excludes mandatory measures.
  • The consumption certificate is the cheap option — for now. At Energieausweis Portal it costs 39.99 € for a non-residential building, as long as it is permitted; how long that applies is clarified in the next section. If the consumption data is complete, it is ordered via the consumption certificate form.

To put the size of this market in context: the Institut Wohnen und Umwelt counted around 21.1 million non-residential buildings in the German stock, of which only about 1.98 million are considered relevant under the GEG — office, administrative and public-authority buildings account for around 307,000 of them, and around 14.8 million buildings of the total stock are not thermally conditioned at all — garages, sheds and similar very small structures. So if you have the impression that there is no standard product for your building type, you are usually right.

Consumption or energy-balance certificate — what applies today, what from 2027?

Today you have the choice. The rule that forces a demand certificate (Bedarfsausweis) on small old houses is in § 80 (3) sentence 2 GModG and expressly applies only to residential buildings with fewer than five flats and a building application before 1 November 1977. For a non-residential building the current version contains no corresponding restriction: consumption and demand certificates stand side by side, regardless of year of construction and size.

From 1 January 2027 the choice ends. The amending Act of 23 July 2026 replaces §§ 80 to 83; § 80 (3) sentence 2 in the new version reads: “In the cases of sentence 1, an energy performance certificate based on an energy balance calculation under § 81 is to be issued for a non-residential building.” And the new § 82 begins with the words “If, for a building used exclusively for residential purposes” — the consumption certificate is thereafter reserved for purely residential buildings. Article 9 (2) of the Act sets both for 1 January 2027.9

For the costs this means three things. First, the cheap option disappears. Second, the full calculation becomes unavoidable: the new efficiency class of a non-residential building results from the ratio of the calculated primary energy demand to the primary energy demand of the reference building, so both have to be calculated — what else the new A to G scale means is set out in new A to G scale from 2027. Third, the calculation basis changes: throughout Annex 11, the amending Act replaces the references to DIN V 18599 with the version DIN/TS 18599:2025-10.

Two further changes from 2027 affect commercial properties in particular. In future the certificate will also be due when a tenancy, lease or leasing contract is extended — in the current version the extension is not a trigger. And for display, the area thresholds of 250 and 500 square metres are dropped; what then matters is solely whether the building has heavy public traffic. What duties follow from this overall is explained in energy performance certificate for non-residential buildings; the minimum standards added from 2030 are covered in MEPS from 2030.

Which documents reduce the effort, and which missing ones drive it up?

The effort arises where details are missing and have to be replaced. The Act permits substitutes — but they cost time.

What reduces the effort if you look it out beforehand

  • Net floor area, or at least the gross floor area from a schedule of areas
  • Floor plans and sections from which the zones can be read
  • Year of construction of the building and year of construction of the heat generator
  • Heat consumption for 36 consecutive months, most recent bill no more than 18 months old
  • Electricity consumption for the same 36 months, separated by meter where possible
  • Details of cooling, ventilation systems and built-in lighting
  • Vacancy periods in the last three years
  • Data sheets or maintenance records for the building services

If dimensions are missing, they may be determined by simplified measurement under § 38 (4) GModG; if energy parameters for building elements and system components are missing, reliable empirical values from comparable age classes may be used. That saves the project, but replaces research time with time on site — and if both are missing, a certificate turns into a building survey.

Two simplifications are little known and noticeably save money for portfolios. First, a joint consumption certificate may be prepared for several non-residential buildings if only a joint consumption value is available for them — for example for properties with a shared central heating plant; the certificate then carries the addition “Liegenschaft” (property complex) in the address field. Second, the net floor area may be calculated in simplified form from the gross floor area using a factor of 0.85, and for rooms formerly used for residential purposes and converted at 1.1 times the heated living space.

And the cheapest case is the one hardly anyone thinks of: no certificate. § 2 (2) GModG removes operational buildings that are heated to a target room temperature of less than twelve degrees Celsius, or are heated for less than four months and cooled for less than two months a year, entirely from the Act; the same applies to air-supported halls, tents and buildings that have to be kept open over large areas for long periods. Energy used for production processes is not covered by the Act in any case. Before you obtain a quotation for your warehouse, measuring the target temperature may settle the whole question.

Who pays for let commercial units — and is the certificate a business expense?

The owner has to pay first. § 80 (4) and (5) GModG address the duties to present and hand over the certificate to sellers, landlords, lessors, leasing providers and estate agents; the tenant is not the addressee. Anyone who breaches the duty commits an administrative offence — which offences exist and what they cost is set out in energy performance certificate fines.

Whether the costs can be passed on to commercial tenants is decided by the tenancy agreement. The Operating Costs Ordinance (Betriebskostenverordnung) does not list the energy performance certificate, and under its § 1 (2) administrative costs are expressly not operating costs. In commercial leases the courts generally permit administrative costs to be passed on through standard-form clauses, unlike in residential tenancies — but this requires an effective provision in the contract. Without such a clause the bill stays with the owner.

For tax purposes the case is short where the building is used for business: under § 4 (4) of the Income Tax Act (Einkommensteuergesetz), business expenses are expenses incurred by the business, and the energy performance certificate for a building used for business purposes is one of them — immediately deductible, not production costs. That is different from the tax reduction for private households under § 35a of the Income Tax Act, which specifically does not cover the energy performance certificate. Both cases, including input tax deduction, are separated in is an energy performance certificate tax-deductible?.

Frequently asked questions about costs for commercial property

Four questions from practice

Why does nobody quote me a fixed price for my office building?

Because the law prescribes no fixed scope of services for non-residential buildings and the Fee Structure for Architects and Engineers does not cover the service “energy performance certificate”. The fee is freely agreed and depends on zoning, floor area, building services and the data available. Quotations only become comparable through the specification of services.

Is it worth ordering the consumption certificate in 2026?

If heat and electricity data for 36 consecutive months are available, yes. From 1 January 2027, § 80 (3) GModG in its new version requires a certificate based on an energy balance calculation for every non-residential building. A certificate issued in 2026 remains valid for ten years.

Does my unheated warehouse need an energy performance certificate?

Probably not. § 2 (2) no. 9 GModG exempts from the Act operational buildings that are heated to less than twelve degrees Celsius, or are heated for less than four months and cooled for less than two months a year. What matters is the intended purpose, not the chance of a mild winter.

Is the energy performance certificate for non-residential buildings funded?

No. In Module 2 of its federal funding, BAFA funds energy consulting to DIN V 18599 at 50 per cent of the fee, but expressly excludes the issuing of an energy performance certificate — it is a statutory duty, and mandatory measures are generally not eligible for funding.

Conclusion: no fixed price, but a predictable cost logic

There is no list price for a commercial property, because the law prescribes no fixed scope of services there and the fee structure does not recognise the service. It nevertheless remains predictable: zoning, floor area, building services and data availability determine the effort, and you can clarify three of them before the first quotation. The date that structurally changes the bill is 1 January 2027 — after that, the energy balance calculation is mandatory for every non-residential building. Anyone who still gets a consumption certificate in 2026 has ten years’ peace.

Sources

  1. Building Modernisation Act (GModG), § 2 — Scope (version of 8 September 2026) gesetze-im-internet.de ↩
  2. Building Modernisation Act (GModG), § 32 — Simplified calculation method for a non-residential building to be constructed (version of 8 September 2026) gesetze-im-internet.de ↩1 ↩2
  3. Building Modernisation Act (GModG), § 38 — Energy assessment of an existing building (version of 8 September 2026) gesetze-im-internet.de
  4. Building Modernisation Act (GModG), § 79 — Principles of the energy performance certificate (version of 8 September 2026) gesetze-im-internet.de
  5. Building Modernisation Act (GModG), § 80 — Issuing and use of energy performance certificates (version of 8 September 2026) gesetze-im-internet.de
  6. Building Modernisation Act (GModG), § 82 — Energy consumption certificate (version of 8 September 2026) gesetze-im-internet.de ↩1 ↩2
  7. Building Modernisation Act (GModG), § 84 — Recommendations for improving energy efficiency (version of 8 September 2026) gesetze-im-internet.de
  8. Building Modernisation Act (GModG), § 85 — Details in the energy performance certificate (version of 8 September 2026) gesetze-im-internet.de
  9. Act amending the Building Energy Act and further provisions in the heating sector of 23 July 2026, Federal Law Gazette 2026 I No. 226 — Article 2 enters into force on 1 January 2027 recht.bund.de ↩1 ↩2
  10. Federal Office for Economic Affairs and Export Control (BAFA), Module 2: energy consulting to DIN V 18599 — funding amount and subject of funding (retrieved 8 September 2026) bafa.de ↩1 ↩2
  11. German Energy Agency (dena), energy performance certificate guide part 3 — energy consumption certificates for residential and non-residential buildings (as of May 2022) dena.de
  12. Institut Wohnen und Umwelt, ENOB:dataNWG — overall structure of the German non-residential building stock, Bischof, Hörner and Rodenfels, 28 November 2024 datanwg.de
  13. Chamber of Architects Baden-Württemberg, remuneration of services under the EnEV (as of 13 May 2022) akbw.de ↩
  14. Operating Costs Ordinance (BetrKV), § 1 — Operating costs (version of 8 September 2026) gesetze-im-internet.de
  15. Income Tax Act (EStG), § 4 — Concept of profit in general, subsection 4: business expenses (version of 8 September 2026) gesetze-im-internet.de

This article reflects the position at the time of publication and does not replace legal or energy advice in an individual case. Binding are the Building Modernisation Act (Gebäudemodernisierungsgesetz, GModG) in its applicable version and the details in the issued energy performance certificate.