Establishment of a portfolio framework to increase lending towards energy performance renovations

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The Wiener Stadtwerke thank you for the opportunity to comment. We consider measures that strengthen lending for renovations to be helpful and important to make the necessary progress on renovations. We also welcome a special focus on social housing and vulnerable households. In addition, however, we would like to note that all building owners and lenders/financers will be affected by the proposed delegated act.

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The EACB welcomes the opportunity to participate in the Commissions call for evidence on mortgage portfolio standards under the Energy Performance of Buildings Directive. As the voice of the cooperative banking sector in the EU, we actively followed the work of the institutions in shaping the EPBD, arguing in favour of a voluntary framework.

Efficient Buildings Europe (EBE) appreciates the opportunity to participate in the European Commissions first public consultation on a portfolio framework for increasing lending for energy renovations, proposed by the Energy Performance of Buildings Directive (EPBD).

MVM Group as the leading electricity and gas utility of Hungary, providing for more than 10 million consumers in the wider Central and Eastern European region, and also having subsidiaries promoting energy efficiency in the building sector, would like to highlight several aspects to enable increased lending for building renovations: Green mortgages and green loans should be better defined and standardised at EU…

Airbus welcomes this call for evidence to build up a voluntary and structured portfolio framework to clarify the funding of renovation projects. We believe this will facilitate and boost lending to improve the energy efficiency of buildings, supporting the EUs energy and decarbonisation objective, while promoting best practices to encourage lenders to tackle the most inefficient buildings first.

According to the 2022 Global Status Report for Buildings and Construction, the building sector is responsible for over 36% of greenhouse gas emissions in the EU. With the approval of the EPBD and the EED, energy renovations have become a global priority for both decarbonization and improving living standards.

Comments of the National Council of Industrial and Industrial Experts on the delegated act of the European Commission: Energy efficient buildings – overview of the portfolio to increase loans for renovations. In response to a deserving initiative of the European Community to facilitate the increase in funding for the renovation of buildings, there is now a spontaneous consideration that, faced with a fundamental and…

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The Czech Banking Association appreciates the opportunity to respond to the current call for evidence regarding energy efficient buildings: portfolio framework to increase lending for energy renovations. On behalf of our members, we would like to highlight several critical issues and present key recommendations to improve accessibility, align national initiatives, and address social considerations in financing. 1.

Pearle* recognizes the positive potential of this framework, especially its alignment with the EUs energy and decarbonization targets. We commend the Commission for recognizing the importance of energy renovations and the need to make financing accessible to all sectors.

The UIPI welcomes the opportunity to contribute to the European Commissions proposal for a voluntary mortgage portfolio framework under the revised EPBD. Representing Europes private property owners, UIPI emphasises the need for accessible, affordable financing for energy renovations across diverse property types.

ESBG would like to thank the European Commission to allow for feedback ahead of its delegated regulation even though we regret that no more time was provided to provide feedback. To elaborate more, please find attached ESBG full response, some key takeaways are highlighted below.

European Mortgage Federation-European Covered Bond Council (EMF-ECBC) Response. The EMF-ECBC is a pioneer in energy efficiency financing, having launched the Energy Efficiency Mortgages Initiative (EEMI) in 2015.

Energy Efficient Mortgage Label Foundation Response. Since 2015, the EU-funded Energy Efficient Mortgages Initiative (EEMI), led by the EMF-ECBC, has sought to develop a robust and integrated energy efficient mortgage market over an accelerated timeframe.

Euroheat and Power (EHP) highlights the critical role of private lenders in advancing Europes energy efficiency and climate goals. Buildings account for 40% of Europes energy use, with heating, cooling, and hot water making up the majority of demand, often met by fossil fuels.

WWF welcomes the opportunity to contribute to the EU Commissions call for evidence for the EPBD Delegated Act (DA) on the portfolio framework to increase lending for renovations. To ensure the DA effectively supports the EUs decarbonization and energy goals, we recommend focusing on four key areas.

The ENGAGE for ESG initiative welcomes the European Commission call for evidence for the initiative Energy efficient buildings: portfolio framework to increase lending for energy renovations, which is framed in the process for the adoption of a delegated act in development of Article 17(10) of Directive (EU) 2024/1275 (recast) (hereinafter, the EPBD recast) and would like to contribute to its from its standpoint as…

The European Public Real Estate Association represents the listed real estate sector in Europe, and we thank the European Commission (EC) for the opportunity to provide feedback on article 17 EPBD. We represent more than 290 members and over 880 billion EUR of real estate assets and 95% of the market capitalisation of the FTSE EPRA Nareit Europe Index.

France: collective financing of renovation works in co-ownership A decree implementing the Law of 9 April 2024 aimed at speeding up and simplifying the renovation of degraded housing and major development operations is pending.

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In the Netherlands, various financing options support energy-efficient renovations, especially during property transactions. Key frameworks such as the Energy-Saving Budget (EBB), Energy-Saving Measures (EBV), specialised mortgage products, and government subsidies facilitate access to financing aimed at improving Energy Performance Certificate (EPC) ratings, promoting energy efficiency upgrades.

To the European Commission ASIA: ENERGY EFFICIENCY OF BUILDINGS: — A PORTFOLIO FRAMEWORK TO ADD LENDING TO ENERGY AUTHORITY REFERENCE: The European Commission’s Call for Evidence of 8 October 2024: Owners of affordable rental and right-of-occupancy buildings – Welcomes the opportunity to comment to the European Commission on the initiative to increase lending for energy renovations and, as requested, takes note of…

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The Spanish Banking Association (AEB) acknowledges that the banking sector has an important role to play and remains fully committed to the green and sustainable transition of the economy. In this regard, the banking sector acts as a facilitator of the transition. However, it should not be signalled as the main responsible for the decarbonization of the economy.

Cassa Depositi e Prestiti (CDP) is the Italian National Promotional Institution (NPI) and one of the largest Italian financial institutions, with total assets above 450bn. CDP combines financial and industrial capabilities to foster sustainable development in Italy, with a focus on promoting and enabling the energy transition.

SEFA is the European trade association for the sustainable energy industry in the built environment. We are accelerating the transition to a net zero carbon economy by advancing the development and financing of sustainable energy across Europes built environment.

Under the last mandate, the EU has set itself ambitious renovation goals for the European housing stock. This is very much welcome as energy retrofits are one of the most efficient measures to slash consumers energy bills, increase peoples comfort as well as to reduce the GHG emissions from the buildings sector. However, accelerating the pace of housing renovation is not an easy endeavour.

The Delegated Act to boost energy renovation lending must address Bulgaria's core issue: the absence of suitable loan products. Currently, banks in Bulgaria finance only new construction, leaving renovation projects unsupported. Analyses by institutions like the EIB and World Bank highlight reasons for these failures that must be tackled.

To support the adoption of sustainable financing mechanisms for energy-efficient building renovations across the EU, the EC Delegated Act should establish a flexible and inclusive operational framework for financing.

To address the barriers to effective financing for building renovations, the EC Delegated Act on Energy Efficient Buildings should at first place take critical actions that overcome blocking national policies. In Bulgaria, for example, commercial lending for renovation remains virtually non-existent due to a state-led 100% subsidy model that fails to achieve substantial market reach, but effectively blocks any…

The initiative is essential to aligning financial practices with EU EE and decarbonisation goals. However, while the intent of such a portfolio framework for financial institutions is clear, existing financial institutions are not structured to meet this challenge's complexity fully.

Green Finance Institute Denmark thanks for the opportunity to provide feedback to the Commissions proposal of a portfolio framework. The Danish mortgage banks are actively seeking ways of supporting the implementation of the EPBD and are collaborating on addressing the structural challenges such as data and regulatory barriers that inhibits extending more retrofit loans in Denmark.

To whom it may concern, We are submitting our contribution as consortium members of the European H2020 project SER, which focuses on energy renovation of buildings for third-sector organisations. Please find attached our document with input. Best regards

The green mortgage loans - loans granted for the purchase of high-energy-performance properties or for the energy renovation of buildings - has recorded, in 2023, a significant increase in the Italian market (accounting for: (i) 10% of the total mortgages for the purpose of purchasing; (ii) 16% of those intended for the renovation and/or construction of a residential property).

Subject: Contribution to the Energy Efficient Financing Coalition: Insights and Lessons from the C-REAL Project Onesto supports the establishment of the Energy Efficient Financing Coalition. Through our Horizon2020 project, C-REAL, we piloted 148 deep renovation projects, achieving an average EPC reduction of 51% by collaborating closely with renovation advisors (Dubolimburg).

The quality of the work. Firstly, it is of paramount importance that loans for energy renovations are provided for work carried out by professional companies; in this sense, it is envisaged to set up a register or register that assesses the credibility of these companies on the basis of some selected reliability indices.

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There is no doubt that the efforts of the EU, including the Fit-for-55, the Climate Action Social Facility, the Next Generation EU package, the increased Cohesion Policy budget and the National Recovery plans funded by the Recovery and Resilience Facility, are significant steps toward the alleviation of energy poverty. Now, the way forward is the efficient implementation of the EU Regulation by Member States.

Climate Strategy & Partners (CS) welcomes the opportunity to take part in the European Commission (EC) call for evidence for the initiative Energy efficient buildings: portfolio framework to increase lending for energy renovations.

Due to the complex number of different regulations, we support the development of portfolio standards, as these will definitely offer added value. Unfortunately, these voluntary portfolio standards alone will not completely eliminate the complexity of the issue, unless the regulatory and economic environment enables the necessary investments.

To effectively address the challenge of financing energy-efficient renovations for low-income homeowners, we propose that the EU fosters collaborations between social actors, financial institutions, and public authorities.

The German system of support for building renovations is likely to be very extensive in comparison with Europe and covers a wide range of measures with grants and/or significantly subsidised loans. Nevertheless, demand has been subdued and has fallen further in recent months. In particular, there are reasons for this.

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