Heating and air conditioning: new carbon requirements applicable from 2027

Decree No. 2026-863 of September 12, 2026, establishes an environmental performance threshold for heating, cooling, and domestic hot water production equipment installed in new buildings. Its application will begin on January 1, 2027, for housing and work undertaken on existing buildings, before gradually extending to other types of construction.

Published in the Official Journal on September 13, 2026, decree no. 2026-863 changes the rules governing the installation of heating, cooling and domestic hot water production equipment in buildings.

The text concerns a wide range of professionals: project owners and project managers, builders, developers, architects, thermal and environmental design offices, construction economists, technical controllers, building companies, technical systems manufacturers and energy suppliers.

Taken pursuant to Article L. 171-1 of the French Building and Housing Code, the decree also transposes Articles 7 and 11 of European Directive 2024/1275 of 24 April 2024 on the energy performance of buildings.

The main regulatory benchmarks

79 g CO2 equivalent/kWh in LHV : threshold applicable to each energy used by equipment installed in a new building.

January 1, 2027 : new housing and work undertaken in existing buildings.

January 1, 2028 : new buildings under public project management.

January 1, 2030 : other categories of new buildings.

Extensions : possible exceptions, particularly in the absence of new equipment and below the thresholds of 150 m² or 30% of the existing surface area.

Supporting document : the note establishing eligibility for an exemption must be kept for the entire lifespan of the equipment.

A threshold set at 79 grams of CO2 equivalent in new vehicles

The decree introduces a new article R. 172-14 into the Building and Housing Code. This imposes a minimum environmental performance on heating, cooling or domestic hot water production equipment installed in new buildings.

For each type of energy used by the equipment, the conversion factor must be less than 79 grams of CO2 equivalent per kilowatt-hour of final energy in LHV ( Lower Heating Value). LHV stands for Lower Heating Value.

The applicable coefficients are those determined by the decree mentioned in Article R. 172-6 of the French Building and Housing Code. The decree thus bases its calculations on the carbon impact of each energy source used, rather than on a list of expressly authorized or prohibited technologies.

This requirement will not apply to equipment providing connection to a heating or cooling network, nor to equipment used as a backup.

A phased application depending on the type of building

If the decree comes into force on January 1, 2027, the threshold applicable to new buildings will be rolled out according to a differentiated timetable:

from January 1, 2027 for buildings or parts of buildings used for residential purposes for which the building permit application or prior declaration is filed from this date onwards;
from January 1, 2028 for buildings constructed under the project management of a public body;
from January 1, 2030 for other buildings, in particular private tertiary buildings which do not fall under the first two categories.

For project owners, designers and design offices, these dates must therefore be taken into account from the programming of operations and when choosing energy systems.

Exceptions are planned for certain extensions

The threshold of 79 grams of CO2 equivalent per kilowatt-hour will not systematically apply to building extensions.

An exception is provided in particular when the application of the requirement conflicts with easements or with legislative or regulatory provisions relating to land law or property law.

The threshold will also not apply when the work does not include any new heating, cooling or domestic hot water production equipment and the extension meets one of the following conditions:

its surface area is less than 150 m²;
Its surface area represents less than 30% of that of the existing building.

A receipt to be kept for the entire lifespan of the equipment

When a project owner intends to benefit from one of these exemptions, they must be able to justify it with a note drawn up under the responsibility of a competent professional.

This assessment can be carried out by a heating equipment installation professional or by a professional meeting the requirements for conducting energy audits. The text also applies to holders of a quality label that meets a set of requirements for resources and skills.

The document must be kept for the entire lifespan of the equipment concerned.

The existing threshold expressed according to a new calculation method

The decree also amends article R. 171-13 of the Construction and Housing Code, which deals with installations in existing buildings.

The regulatory threshold remains set at 300 grams of CO2 equivalent per kilowatt-hour in net calorific value. From January 1, 2027, however, compliance will no longer be assessed based on the "level of greenhouse gas emissions of the equipment", but on the conversion factor of each energy source it uses.

The provisions concerning existing structures will apply to work undertaken after January 1, 2027. The decree also updates the references relating to professionals authorized to draw up the notes used to justify exceptional situations.

A text to be integrated into the design of operations

Project owners, architects, engineering firms, and contractors will need to verify the compatibility of the planned equipment with the coefficient associated with each energy source used. For new construction projects, this analysis will cover both heating and domestic hot water production, as well as cooling.

The phased approach allows more time for public buildings and other non-residential construction. However, the first projects affected will be those for which planning applications are submitted on or after January 1, 2027, for residential buildings.