Four questions for every building in the register
The building stock in s. 2(12) is a data definition, not a technical building one. If the register can answer the four questions for every building, you know your building stock. The cut-off date does not move — and it gets harder to reconstruct the longer you wait.
Do you own it?
Only owned buildings are included. Leased buildings above 250 m² have their own rule: at lease negotiations you must require NZEB by 2030 at the latest (s. 7).
Is it heated or cooled?
Unheated buildings — garages, sheds, halls without heating — fall outside the stock.
Is it above 250 m²?
Buildings of 250 m² and below do not count — not even if they have a poor energy label.
Did it have at least B on 1 January 2024?
Buildings that did not correspond to at least energy label B on the cut-off date are in the stock — even if they have been refurbished since.
From designation to NZEB
- 1 January 2024The cut-off date. The energy label on that day decides whether the building is in the building stock.
- 11 October 2025The executive order comes into force. Every year buildings equivalent to 3 % of the building stock must be designated, and public bodies must together save at least 1.9 % a year measured against final consumption in 2021.
- Every yearDesignation. The buildings must be profitable to refurbish up to NZEB. You can choose to designate buildings that are not profitable, and you can prioritise jointly with other public bodies.
- 2030Leased buildings. At lease negotiations for buildings above 250 m² you must require refurbishment to NZEB by 2030 at the latest — and to zero-emission building by 2050.
- 2040The deadline. All designated buildings must have been refurbished to at least NZEB.
How this is calculated
The building stock is the area of owned, heated or cooled buildings above 250 m² minus the area that had at least energy label B on 1 January 2024. The annual designation is 3 % of that area. The number of buildings is calculated from the average size of the building stock — the actual buildings are chosen on profitability, not on size.
1.9 % is the same percentage of your own final consumption in 2021. The requirement in s. 3 applies to public bodies' total consumption — 31.1 PJ in 2021 — and the Danish Energy Agency counts the savings. The figure shows your proportionate share.
The phase 1 price follows the number of buildings in the portfolio: START 5–15 buildings DKK 129,000 · BASIS 16–30 DKK 199,000 · PORTFOLIO 31–60 DKK 289,000. Above that DKK 289,000 plus DKK 3,900 per building from no. 61 to 120, DKK 3,100 from 121 to 250 and DKK 2,600 from no. 251. Phase 0 costs DKK 24,500 and is credited against phase 1, but counts towards the contract value. All amounts excl. VAT. No advance payment — phase 1 is invoiced 40/30/30 at the portfolio register, milestone M1 and the approved strategy.
For comparison the Danish Ministry of Climate, Energy and Utilities, KL and Danske Regioner agreed on 22 May 2025 that approx. 3.9 million m² of public building stock is to be designated up to 2030.
What the executive order says
- s. 2(12). Building stock below energy label B: the total area of public bodies' owned buildings that are heated or cooled, with an area above 250 m², where the building did not correspond to at least energy label B on 1 January 2024.
- s. 3(1). Public bodies must annually achieve total energy savings in their final energy consumption of at least 1.9 per cent compared with the bodies' total final consumption in 2021, put at 31.1 PJ.
- s. 5(1). Within the building stock below energy label B, buildings that are profitable to refurbish up to NZEB must be designated annually, equivalent to 3 per cent of the building stock. Subsections 2–3: You can also designate buildings that are not profitable, and prioritise jointly. Subsection 4: The designated buildings must have been refurbished to at least NZEB by 2040 at the latest. Subsections 5–7: Listed buildings, the armed forces' special buildings and places of worship can be exempted on conditions.
- § 6. A designated building that is demolished and replaced can be counted as refurbished on specified conditions.
- § 7. Leased buildings above 250 m²: at lease negotiations, refurbishment to NZEB by 2030 at the latest and to zero-emission building by 2050 must be required.
- § 8. When refurbishing owned, heated or cooled buildings above 750 m², you must assess whether an energy performance contract should be entered into.
Executive order no. 1193 of 2 October 2025 on energy efficiency in the public sector, in force 11 October 2025.
The register is the first step.
Phase 1 builds the portfolio register, answers the four questions for every building and sets the strategy for the designation — calculated on measured consumption. 30 minutes of scoping, online or at your offices. No charge.
Send the building stock check to us →The button opens your own email program with the figures written in. Nothing is sent until you press send yourselves.
info@synegro.dk · +45 93 60 24 30 · weekdays 9–17