EED / GBER / Taxonomy — regulatory framework

At the turn of 2025 and 2026 there is no new, comprehensive revision of the EED, the GBER or the taxonomy dedicated to a district heating strategy. Several important changes and clarifications are, however, already in force or under way — and it is these that form the actual regulatory framework for the sector.

EED — implementation of the 2023 revision

The Energy Efficiency Directive (EED) was substantially revised in 2023 — by Directive (EU) 2023/1791. At the turn of 2025 and 2026, implementation of the resulting obligations is under way: higher efficiency targets, audit requirements and a new, progressively tightened definition of an "efficient district heating and cooling system".

This definition changes over time. Until the end of 2025, an efficient system must be based on at least 50% renewable energy, 50% waste heat or 75% cogenerated heat — or an appropriate combination of these sources — and ultimately, from 2050, solely on renewables and waste heat. Operators of existing systems that do not meet this definition are required to draw up plans for reaching compliance with the criteria. Support for new high-efficiency natural-gas cogeneration units in efficient district heating systems will be possible only until 2030.

GBER — state aid for district heating

The General Block Exemption Regulation (GBER), which allows part of state aid to be granted without individual notification to the European Commission, remains in force — in the version expanded in 2023 under the Green Deal. For district heating, its Article 46 is key, governing investment aid for efficient district heating and cooling systems; the maximum aid intensity under it reaches 45% of eligible costs.

A condition for using this route is that the system meets the definition of an efficient district heating system (or is moving towards meeting it), and aid may not cover new fossil-fuel units — beyond a strictly limited use of gas consistent with the 2030 and 2050 climate targets. Discussions at the end of 2025 focus on increasing aid intensity and better aligning the GBER with the needs of the district heating transformation, but a formal new revision has not yet been adopted.

Taxonomy — clarifications, not a revolution

The main climate taxonomy criteria — for the objectives of climate change mitigation and adaptation — apply from the 2021 delegated act, supplemented in 2022 (including natural gas and nuclear energy) and in 2023 with additional environmental criteria. For district heating, the relevant technical screening criteria concern heat generation and distribution activities — among them CO₂ emissions per unit of energy, the share of renewables and waste heat, and the "do no significant harm" principle (DNSH).

In July 2025 a delegated act was adopted simplifying taxonomy reporting and reducing administrative burdens — but it does not fundamentally change the technical thresholds for district heating activities.

Link with the new heating and cooling strategy

The EU heating and cooling strategy announced for 2026 is expected to be a directional document, drawing on the already-revised directives (EED, RED, EPBD) and the existing GBER and taxonomy frameworks, rather than another major revision of those acts. In consultations and position papers, industry institutions are calling for adjustments to the GBER — higher aid intensity and better treatment of heat storage and network modernisation — as well as clarifications in the taxonomy; their implementation is, however, expected rather after the strategy itself is adopted.