The property market is continuously moving towards decarbonisation, as evidenced by the latest data. A clear trend is emerging: the bar for energy efficiency is being raised, with EP indicator threshold values falling. As a result, buildings that have so far been considered energy-efficient may soon require additional capital expenditure to maintain their status.
What do the numbers say? The sector’s “speedometer”
The new thresholds, published in December 2025, point to improved energy efficiency across key sectors. Lower threshold values indicate that the average quality of buildings in Poland is rising – this is a positive signal for the environment but also poses challenges for owners of older properties.
Below are key changes for buildings completed before 31 December 2020:Top 15% (the top tier of the most energy-efficient buildings in Poland):
- Public buildings (including offices and retail): threshold tightened by 3% – new value is 106.45 kWh/m²·year.
- Warehouses and logistics: threshold tightened by 5% – new value is 103.96 kWh/m²·year.
- Single-family residential buildings: a record improvement of 13% – new value is 73.20 kWh/m²·year.
Top 30% (a wider group of buildings with meaningful contributions to climate change adaptation but still requiring investment to enter the Top 15%):
- Public buildings: threshold tightened by 3% (to 144.56 kWh/m²·year).
- Warehouses and logistics: threshold tightened by 3% (to 142.77 kWh/m²·year).
It is worth noting that progress is not observed across all segments. Individual recreational buildings have experienced performance decline by approximately 7%, although at this stage it is difficult to determine the underlying reasons for this change.
Why does this matter so much today?
Although EU directives (including the EPBD) are based on a system of energy classes, they are yet to be formally implemented in Poland. While the latest regulation draft has been under consultation since June 2025, the scheduled entry into force on 30 June 2026 appears ambitious, given the scale of changes, including the transition to an hourly method of calculating energy performance.
During this transitional period, the Top 15% and Top 30% thresholds serve as a market compass for buildings completed before the end of 2020. They remain the only reliable benchmark for banks and investors when assessing compliance with the EU Taxonomy.
Impact on business strategies and CAPEX
Tightened requirements have a direct impact on asset value and liquidity. Cushman & Wakefield’s clients are increasingly enquiring about these parameters at two key moments:
- Acquisitions and disposals – energy efficiency is emerging as a decisive factor, providing a negotiation leverage.
- Refinancing – banks assess compliance with the EU Taxonomy, which directly impacts access to cheaper green financing.
Lower thresholds mean higher expectations. Decarbonisation is becoming a more complex and capital-intensive process for owners of older assets. To keep these assets competitive, strategic, long-term capital expenditure (CAPEX) planning is required to integrate improvements in energy performance certificates (EPCs) with decarbonisation goals.
What is driving these changes?
Beyond regulations, the market is also responding to the change in the non-renewable primary energy input factor for electricity (commonly referred to as the Wi coefficient), which was introduced in April 2023 and continues to have a significant impact on EP values. We are also seeing the effects of thermal retrofits, including replacement of heat sources, system upgrades, improved thermal insulation of building envelopes and the use of renewable energy sources. In the residential sector, subsidy programmes and growing awareness of service charges play a significant role.
At Cushman & Wakefield, we have been monitoring asset compliance with the EU Taxonomy for years, supporting our clients in building future-resilient portfolios. The year 2026 will bring further regulatory changes. Our ESG team is well-positioned to help you develop strategies that turn these challenges into tangible business value.
Source of data: Cushman & Wakefield, based on: Taxonomy of Sustainable Investment Financing – Buildings, Ministry of Economic Development and Technology, Gov.pl, updated on 23 December 2025