What the bank fears

A loan for a commercial building is serviced by rental income, and the building is the security. A weak energy rating can weaken both.

Rental income may fall. If the building can no longer be used legally (as has happened for office buildings in the Netherlands with a poor energy rating, see below), in the worst case, income stops while interest and installments are running. Even in a market without such legal requirements, tenants can move to better buildings or demand lower rent. The risk is of course greatest if the lease expires soon and the income is not insured. Particularly more demanding tenants (including the banks themselves), who have their own sustainability goals, probably want energy ratings of A to C. But price still weighs heavily, also for them, and there are other segments where only price counts.

The value may be lower than expected. Since January 2025, DNB Næringsmegling has included the energy rating in the valuation. The reasoning is that a poorer energy rating may cause buyers in the market to expect a higher yield (i.e. annual rental income after costs, divided by the value), and a higher yield results in a lower property value. DNB believes that offices with a weak rating in less attractive areas may end up as "stranded assets".

Refinancing can be difficult. The Norwegian Financial Supervisory Authority pointed out in its thematic inspection on office property in 2023 that the term of the loans is significantly shorter than the financing need, and that many mortgages lack energy labels. Where data is missing, the bank assumes risk. If rental income and value have to be adjusted down just when the loan is due to be renewed, it is bad timing.

A calculation

Let's take an office building worth 200 million kroner. The net rent (simplified to rent minus ownership costs) is 12 million a year (yield 6 percent). The loan is 130 million (loan ratio 65 percent), and with 5.5 percent interest, it costs 7.15 million in interest. The interest coverage is 1.7 (12 divided by 7.15).

Then the market moves. The yield rises to 6.5 percent because the building has a weak energy rating, and the net rent falls 30 percent, to 8.4 million, because the owner loses a tenant for the same reason. The value then becomes around 129 million. The loan of 130 million now exceeds the value (the loan-to-value ratio is over 100 percent), the interest coverage is down to 1.2, and the loan must be refinanced. The point here is to show that this has two effects (yield and loss of tenant) – it will take a while for them to stack up like this in practice.

Several countries have introduced energy requirements for rental space or commercial buildings.

Energy requirements for rental areas – both commercial property and rental housing – exist in several European countries. It is reasonable to assume that more will follow suit, and perhaps also Norway, in light of a new EU directive. At the same time, a requirement for a given energy rating cannot be translated directly to Norway, for many reasons. As of today, the calculation of energy ratings is not coordinated, so the thresholds and calculation basis for a given rating are different. Other countries have a lot of fossil energy use in buildings, unlike Norway.

Country	Regulations	What is required	Status
France	Tertiary decree	Buildings of 1,000 m² or more: energy use down 40% by 2030 (compared to 2010). Annual reporting.	In force
Netherlands	Energy rating C requirement for offices	Offices over 100 m² must have at least energy rating C (since 1.1.2023)	In force
United Kingdom (England/Wales)	MEES for commercial buildings	Today: energy rating E. Proposed: B from 2031 for rented buildings over 1,000 m²	In force
European Union	Energy Performance of Buildings Directive (2024/1275)	Commercial buildings: the 16% worst to be renovated in 2030, the 26% worst in 2033	In force at EU level, in process nationally

The Netherlands has the closest thing you can get to a ban on the use of poor commercial buildings. An office without an energy rating of C does not have to take measures with a payback period of more than ten years, but must implement measures that pay off more quickly. Before you get worried about "Dutch conditions" in Norway: the requirement corresponds to 225 kWh/m² of fossil primary energy . Norwegian buildings have little fossil energy use, and oil heating is prohibited. Primary energy is something different from weighted delivered energy, which is the basis for energy labeling in new regulations in Norway. Fossil power production loses 40-60 percent before the electricity is delivered.

France does not prohibit the renting out of commercial buildings with poor energy performance, but it has a consumption target that could be just as demanding. Final energy consumption is to be reduced by 40 percent by 2030, 50 percent by 2040 and 60 percent by 2050, compared to 2010. Consumption is reported annually, and companies that fail to do so could face publication of their names and a fine of 1,500-7,500 euros (up to approximately 80,000 kroner per violation).

In the United Kingdom (England and Wales) , leased commercial buildings must currently have at least E . In June this year, the government presented a preliminary proposal for B from 2031 for leased buildings over 1,000 square meters. For both the current and proposed rules, upgrading is only required if the measures have a payback period of 7 years or less and do not reduce the market value by more than 5 percent. Owners of buildings that do not meet the requirement risk fines , depending on how long the deadline has been violated and the rental value. The fine is at least 5,000 pounds (about 65,000 NOK) and a maximum of 150,000 per violation (about 2 million NOK), and the owner's name is published.

EU : The Energy Performance of Buildings Directive , adopted in 2024, has minimum energy performance requirements for commercial buildings (i.e. not just rental space). Based on 2020 figures, the 16 percent worst performing buildings must be renovated by 2030 and the 26 percent by 2033. Each country sets its own thresholds (Norway will probably also introduce the directive, see below).

Residential portfolios

For housing, minimum requirements are optional under the Energy Performance of Buildings Directive, but the energy use of the housing stock in each country must be reduced by 16 percent by 2030 and 20-22 percent by 2035. Larger housing landlords in may face strict rules: France introduced energy rating F as the lower limit for renting out homes in 2025, and plans to tighten it to E in 2028 and D in 2034. In England and Wales, the requirement is energy rating E today. It has been decided politically (but not yet legally) that rental housing must have C by 2030. The Netherlands links the maximum permitted rent to the energy label : energy ratings E, F and G give deductions in the points system for maximum rent.

Where does Norway stand?

Norway currently has no minimum energy performance requirements for existing commercial buildings, other than that buildings that are sold or rented out must have a valid energy certificate. However, three things are changing:

Energy mapping requirement: The regulation applies to enterprises with energy use of at least 2.5 GWh per year, and the deadline for the first mapping was 1 October 2026. The requirement applies to enterprises, not individual buildings, and therefore includes energy use for transport and processes, not just buildings. A rule of thumb: If the company has more than 10-15,000 m² of "ordinary" commercial buildings with energy ratings D or E (or half, if the building has high energy use for heating or cooling, or has a worse energy rating), you may be required to report.
Banks: Most major Norwegian banks now require energy performance certificates for commercial buildings when granting new loans or refinancing, and include the rating in the credit assessment. Many require plans for upgrading buildings with poor energy ratings (e.g. E, F and G).
EU rules: The Building Energy Directive, with minimum requirements for commercial buildings and the average for residential buildings, was up for consultation in the fall of 2025. It is not clear when Norway will implement it, and in what form. Major adaptations to the Norwegian context may be made, including in light of the specific features mentioned above.

Minimum requirements for commercial buildings in Norway: what are the pros and cons?

Before

The direction of EU rules: Norway will probably incorporate the directive sooner or later. The pressure on Norway to comply with EU requirements is tougher than before.
Transparency: when a very small proportion of commercial buildings have a certificate, neither the bank, tenant, owner nor authorities know where the building stock is. A minimum requirement can increase compliance.

Courage

Small climate benefit: Norwegian buildings are largely heated with renewable electricity and district heating, and the operation of buildings therefore accounts for only about 1 percent of Norway's emissions, as they are typically calculated.
The incentives for upgrading are often skewed: the building owner pays for the measure, while the tenant saves money, without rental income automatically increasing overnight.
The energy rating typically shows what the building is designed for, not what the actual use is. A minimum requirement based on calculated energy can therefore penalize poor buildings that are used energy efficiently, and reward those that waste energy in buildings that are designed for efficient energy use. There is much evidence that Norwegian buildings use more in practice than the energy certificate shows .
The wrong building gets the bill: a claim can force expensive measures on buildings that should be sold or rebuilt anyway, especially in weak areas.

A Norwegian ban on the use of energy-wasting commercial buildings is unlikely in the short term (and a ban on renting out poor housing even less likely), but more likely after 2030. Investors from countries that implement the Building Energy Directive can use the same standard for their investments in Norway. The banks and the market are also doing some of the work anyway, through changes in yield, credit ratings and tenant preferences. And the banks are listening to Finanstilsynet. In its analysis of banks' lending to commercial property (mentioned above), the authority asked the banks to take into account that "there may be regulations that require upgrading of the least energy-efficient buildings, or that it will not be allowed to rent out office buildings with the worst energy ratings". So far, the authority has not followed up on this.

What you can do now

Check whether your company must report energy use under the energy mapping regulations. Sum up your energy use (buildings, transport, processes) and compare to 2.5 GWh. If you pay for electricity or district heating for many buildings, as well as electricity or fuel for a number of vehicles in addition, you may be over the limit. Use the mapping to think through measures to save energy and money.
Obtain energy certificates for all your buildings, and check that existing certificates are correct and valid.
Put actual energy use next to the certificate. Operational optimization can have a big impact without major investments in the building itself, but you have to explain that to the bank – they won't figure it out themselves.
Talk to the bank early about loans that need to be refinanced and about green loans for upgrades.
Consider whether weak buildings in weak areas should be sold or rebuilt instead of upgraded.

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Could there be energy requirements for rental spaces in Norway too?