Reliability of the DPE: the project of the Government and the DHUP lacks realism and will not be sustainable

All convinced of the need to reinforce the DPE reliability system and the harmonization of practices, the main professional federations in the real estate diagnosis sector, with the federation of certified real estate diagnosis training organizations and the association of ODI certification bodies consider that, as they stand, the provisions envisaged in the decree will only very partially resolve the problems of the DPE, in particular the problems of fraud which, although marginal, considerably alter the image of the profession. They are also economically unsustainable, posing a risk to the profitability and the very existence of property diagnostic companies.

The main federations of the real estate diagnosis sector do not dispute the spirit and the purpose of the provisions provided for in the draft decree of the DHUP. They are unanimously in favor of strengthening initial and continuing professional training, emphasizing “practical” aspects closer to professional practices, restoring virtual classes, tutoring for new entrants. They are in favor of the harmonization of penalty grids, the content of training and examinations thanks to shared tools and databases, and the establishment of suitable continuing education. The federations support the implementation of effective monitoring to control repeated errors but above all fraud, which considerably damages the image of the profession.

The DHUP's proposals lack realism

But the provisions currently envisaged by the DHUP will have an unsustainable and unacceptable economic impact for the self-employed and real estate diagnosis companies. According to an impact study carried out by the federations and presented to the DHUP, the additional cost of the measures envisaged in the draft decree of the DHUP would not be bearable for a certified diagnostician. For example, the economic impact for a diagnostician starting out in the business would be, to obtain his DPE certification with honors, €33.000, to which are added €20.000 for the energy audit. That is €53.000 of total additional cost!

The consequences would be immediate:

• The risk that diagnosticians give up carrying out DPEs, which have become unprofitable, which would penalize owners and social landlords and the entire housing sector;
• The decrease in the number of diagnosticians when there is a shortage, with an entry fee that is economically unsustainable, as is the cost of monitoring certification;
• The increase in the price of the DPE that will inexorably have to bear the owners and lessors, in particular social, very reluctant to any additional cost. The latter are already vigilant and worried.

Instead of making the DPE more reliable, the Government and DHUP project risks penalizing a professional sector, the pivot of energy renovation, which needs to develop, hire, and encourage vocations. At the same time, access to housing will be penalized (even though it is already experiencing an unprecedented crisis) and energy renovation slowed down (even though it needs to be accelerated).

Federations united around a common core of alternative proposals

The sector federations have co-constructed an alternative proposal, in which they demand a future system that is:

• Operationally applicable and effective;
• Fair and not subject to vagaries;
• Economically sustainable by the diversity of real estate diagnosticians, from “solos” and independents to large structures (SMEs, ETIs);
• Designed so that no diagnostician escapes the control of skills and best practices regardless of their current situation in the year following the implementation and respectful of the pace of adaptation of all actors to changes.

The professional federations have worked together on realistic common proposals intended to strengthen initial and continuing training as well as tutoring, but also the control and possible sanction of diagnosticians. They submitted them to the DHUP. They are summarized in the diagram below.

Here are the main directions:

• Initial training adapted with distance learning, virtual classes (with live trainer as pilot) and face-to-face;
• Pre-requisites which allow the access of work-study students;
• Practically achievable exams with a theoretical part and a practical part with use of test cases;
• Organized tutoring;
• Efficient monitoring thanks to a longitudinal control system based on ADEME's DPE database, fed by the diagnosticians at each DPE carried out. This would easily allow a certification body to detect any repeated errors but also any fraud;
• Continuous training mainly oriented towards regulatory changes, assuming that the certified diagnostician is competent. The certifying body may, thanks to the longitudinal control, impose additional training if necessary.

Go further by empowering all ECD actors

Addressing the subject of making the EPD more reliable only from the perspective of strengthening the training and control of diagnosticians will not solve everything. Making the ECD more reliable requires activating other levers, starting with the accountability of owners, landlords and real estate professionals in the production of this diagnosis.

Unanimously, the main federations of the sector demand the implementation of a completeness index which measures the gap between the data transmitted by the owner and the data necessary for the realization of a quality DPE, which would make it possible to raise awareness and to empower all ECD actors and not just the diagnostician.

They also underline that the adjustment of the computer tool used to carry out the calculations of the DPE is also necessary, in particular to fairly manage the problem of small surfaces, which are today too often credited with a penalizing energy label.

Beyond an order relating to the skills of diagnosticians which responds realistically and effectively to the need for reliability of the DPE, the professional federations of the real estate diagnostics sector are asking for the establishment of a real master plan involving the whole real estate chain, the only way to put the DPE back at the heart of energy renovation.