A new line in credit rating

The EU and Norwegian authorities have, in turn, decided that climate risk is credit risk. Norwegian banks must follow guidelines for lending and monitoring (EBA GL/2025/01), and the capital requirements regulation (CRD6) requires them to assess environmental risk when they grant loans. If the bank's stress tests and scenario analyses show to Finanstilsynet that it is vulnerable to energy transition, it may have to tie up more capital in the "bank vault" per loan: costly, since the money cannot work elsewhere, and it weakens the return on equity that investors care about. In practice, the bank must document the energy condition of what it has as collateral, i.e. your buildings. If it does not do so, it will be in trouble with Finanstilsynet and the investors. If you do not document it for the bank, expect worse loan terms, or a no.

This is how the bank actually calculates risk

Bankers rarely talk about “energy rating” among themselves. They talk about probability of default and loss given default, two numbers that together determine how much capital the bank must set aside for your loan, and thus what loan terms you get. Until now, banks have paid little attention to the energy condition of buildings, but that has changed in the last couple of years, and the trend is likely to continue.

High electricity costs and an urgent need for upgrades can weaken the tenant's or owner's ability to service the loan, thereby increasing the likelihood of default. A weak energy label makes the building more difficult to sell or rent out if the worst happens, which increases the loss the bank is left with. If the bank has many weak buildings in the same, often geographically concentrated, portfolio, the risk is further amplified, especially in the event of sudden new legal requirements or a physical climate event affecting the same buildings.

Translated into plain Norwegian: the bank doesn't actually value your building over time. It values how quickly it becomes difficult to rent out, sell, or insure.

The taxonomy has thresholds, and thresholds have rates.

The EU taxonomy has several paths to a building's "green" classification. All of them can provide better loan terms (even though climate adaptation is still immature terrain in banking Norway), because the bank can count the loan as sustainable in its own portfolio:

Top 15% most energy-efficient buildings in their category, or alternatively energy rating A, for buildings with a building application by the end of 2020.
Top 30%, a more generous threshold related to climate adaptation, or alternatively energy rating C or better: has built significant physical climate risk (floods, landslides, extreme weather), climate adaptation measures may qualify if energy efficiency is also among the top 30%.
Buildings constructed from 2021 must have at least 10% lower energy use than the Norwegian nZEB threshold (nearly zero-energy building).
A number of other measures also qualify under the taxonomy, regardless of the building's overall classification: for example, electric vehicle charging solutions, or equipment for renewable energy, energy efficiency and smart energy management.

A property that can document where it is in this picture negotiates from a much better position than one that has no idea. Details can be found in the threshold values for the top 15% and top 30% from the Ministry of Finance and the Ministry of Energy and guidance on calculating primary energy needs in buildings and energy frameworks for nearly zero-energy buildings.

The floor also comes

In parallel with the bonus for the best comes a floor for what is acceptable at all. The Building Energy Directive, when adopted in Norway, introduces minimum thresholds based on 2020 figures: the weakest 16 out of 100 commercial buildings must be upgraded to at least the level of the 84th worst building by 2030, and the limit is tightened to the weakest 26% by 2033. Buildings below these thresholds risk becoming difficult to finance at all, no matter how nice the location. The directive has been under consultation, may still be delayed, and may receive Norwegian adjustments. If your building needs both financing and upgrading, it is still wise to plan for the changes; banks have had this on their radar for a long time.

The products that actually move the building

Banks have started building loan products directly around this logic, not just around buildings that are already green, but around the journey to get there:

The loans increasingly link loan-to-value ratio, term and covenants to energy class: how much of the building's value the bank lends (loan to value), repayment period, and reporting requirements along the way.

The banks have their own goals, and they are public

This is not just goodwill on the bank's part. It has its own climate goals to answer for, and the real estate portfolio is often a heavy item:

Bank	Goals 2030	Goals 2040/2050
DNB	−29% (from 2019 level)	Net zero 2050
SpareBank 1 Southern Norway	−44% office (from 2020 level)	Net zero 2050
Savings Bank Norway	–	Net zero 2040 (group target)

The figures are taken from the banks' own, public climate targets, and they change; check the current targets with your own bank before you base them on a negotiation. The point here is not the exact percentages, but that your bank has a figure to guide by, and that your portfolio is part of the calculation.

What does this mean in practice for you?

Many property owners first encounter this issue when refinancing or renegotiating, often because they change banks for competing offers. In that case, energy documentation becomes part of the offer basis, and the person who shows up with clear figures (consumption, energy rating, action plan) negotiates from a stronger position.

Therefore, it is good to think through the following: Do you know which taxonomy category your buildings fall into, or if they fall into any at all? Do you have an action plan in place, ready to be presented before anyone asks, instead of writing it in a hurry the day before the meeting? Do you know which climate target your own banker has committed to, and what that might mean for your next loan negotiation?

If you don't have an answer yet, you're in good company: most property owners we speak to discover the requirements when the bank asks, not before. But the earlier you map out, the more choices you have, and the less stress there will be when the deadlines actually arrive. Energihuset helps you with just that: translating the spreadsheets into something the bank understands, and vice versa.

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When the bank checks the energy certificate before checking you