All co-ownerships with fewer than 50 units must now carry out their collective DPE
Since 1 January 2026, co-ownerships of 50 units or fewer whose planning permission was submitted before 1 January 2013 must in turn have a collective energy performance certificate (DPE) carried out. This deadline closes a timetable begun in 2024 and in practice concerns most small older buildings in France. Vote at the general meeting, choice of provider, drawing up of a multi-year works plan: co-owners must organise themselves quickly, failing which the town hall or the prefecture may take their place — at the expense of the co-owners' association (source: Kohen Avocats, September 2026).
For owners and future buyers of a property in co-ownership, this certificate is no longer a simple administrative document: it now weighs on the value of the property, on future service charges and, ultimately, on the very possibility of letting the dwelling.
A timetable rolled out gradually since 2024
The obligation to have a collective DPE stems from the French Energy Code and applies to any collective residential building whose planning permission was submitted before 1 January 2013. It has been rolled out in stages, according to the size of the co-ownership:
- 2024 : single-owner buildings and co-ownerships of more than 200 units;
- 2025 : co-ownerships of 50 to 200 units;
- 2026 : co-ownerships of at most 50 units, i.e. the vast majority of small structures.
The certificate must then be renewed every ten years, except for buildings already rated A, B or C, which are exempt (source: Kohen Avocats).
What co-owners must vote on at the general meeting
The managing agent is obliged to place the matter on the agenda. Several votes then follow, with distinct majority rules:
- the principle of the collective certificate, voted by simple majority of the votes cast;
- the choice of provider, also by simple majority;
- the draft multi-year works plan (PPT), mandatory since 2025 for any building completed more than fifteen years ago, presented by simple majority and then adopted in whole or in part;
- each phase of works, according to its nature (simple, absolute or double majority).
Once the report has been delivered by the diagnostician, who must have the technical data of the building provided by the managing agent, it is presented at the following meeting. If the multi-year plan is not adopted or if its implementation remains uncertain, the managing agent is required to re-enter it on the agenda of every meeting approving the accounts — so the matter cannot be buried for good.
What does a co-ownership that fails to act risk?
The scheme provides for a gradation of consequences in the event of inaction:
- Takeover by the authorities : if the multi-year works plan is not submitted within the month following a request by the mayor, the prefect or the intermunicipal authority, the latter may draw it up by default, at the expense of the co-owners' association.
- Liability of the co-owners' association engaged : an approximate certificate or culpable inaction may engage collective liability if a co-owner suffers loss — for example the impossibility of selling or letting a unit because of a poor energy rating attributable to the common parts.
- Progressive ban on letting : dwellings rated G can no longer be let since 2025; this ban will extend to F-rated dwellings from 1 January 2028.
- Fines in the event of a non-compliant advertisement : failure to mention the energy label in a property advertisement exposes the advertiser to an administrative fine of up to €3,000 for a natural person and €15,000 for a legal person (source: Kohen Avocats, September 2026).
An issue that is now central to the value and sale of a property
The collective DPE is no longer limited to a technical formality: it directly determines the attractiveness and valuation of a unit. A discerning buyer now examines the rating of the dwelling as much as that of the building as a whole, as well as the visibility offered by the multi-year works plan on future service charges. Conversely, a co-ownership that has anticipated its certificate and embarked on a renovation trajectory reassures and stands out on the market.
Several recent developments nuance the picture. The electricity conversion coefficient used in calculating the DPE has risen from 2.3 to 1.9, which could move around 850,000 electrically heated dwellings out of the category of energy-inefficient homes, without any works (source: Actual Immo, September 2026). In addition, co-ownerships can mobilise several schemes to finance their works (source: Actual Immo):
- MaPrimeRénov' Copropriété, which finances up to 30% of the cost of works for an energy gain of 35%, or up to 45% for a gain of 50% or more, capped at €25,000 per unit;
- an additional 10% bonus where the building, initially rated F or G, reaches at least class D after works;
- CEE, collective éco-PTZ, reduced VAT and local grants, in addition.
What this changes in practice for owners in the mid- and high-end residential sector
Older upmarket buildings — numerous in town centres and sought-after residential areas — are fully concerned as soon as their planning permission predates 2013. For an owner who is considering selling, anticipating the collective DPE and the presentation of the multi-year works plan makes it possible to approach negotiations with clear arguments rather than facing the questions of a buyer worried about future service charges. For a buyer, the existence of a voted and financed multi-year works plan is a signal of good management, just as much as the state of the co-ownership's accounts.
How the co-ownership council can calmly anticipate this deadline
Several good practices make it possible to approach this obligation without haste or improvisation:
- Check the date of the building's planning permission with the managing agent or the municipal archives, to confirm whether the obligation does indeed apply to the co-ownership.
- Place the item on the agenda as early as possible, rather than waiting for a formal notice: the managing agent must provide the diagnostician with the building's technical data, which requires a minimum of preparation ahead of the general meeting.
- Compare several quotes from certified diagnosticians, as the cost and methodology can vary significantly from one provider to another.
- Anticipate the financing of the works from the presentation of the multi-year plan, by simulating the amount of the works fund required and the available grants, rather than discovering the scale of the needs at the time of the vote on the tranches of works.
- Distinguish the collective DPE from the statutory energy audit, required separately for certain highly degraded buildings: the two documents complement each other but respond to distinct obligations.
A conseil syndical that structures this process upstream avoids the most common pitfall: a vote in principle adopted in haste, followed by a multi-year works plan never actually implemented — a situation that exposes the co-ownership association precisely to the takeover by local authorities described above.
Frequently asked questions
What is a collective DPE, as distinct from an individual DPE?
The collective DPE assesses the energy performance of the building as a whole — common areas, collective heating, insulation of the structure — whereas the individual DPE concerns a specific dwelling. The two coexist: the collective DPE does not exempt the owner from carrying out the individual DPE at the time of a sale or a letting.
Must my co-ownership of fewer than 50 lots already have voted on its DPE?
Yes, where the building's planning permission was submitted before 1 January 2013, the obligation came into force on 1 January 2026. The managing agent must place the matter on the agenda of the next general meeting if this has not yet been done.
Can I sell my lot before the co-ownership has carried out its collective DPE?
Yes, the sale remains possible, but the absence of a collective DPE and of a multi-year works plan may concern a buyer about the future level of charges and about the energy rating of the building, an increasingly scrutinised criterion in negotiations.
What grants exist to finance energy renovation works in co-ownership?
MaPrimeRénov' Copropriété, energy saving certificates (CEE), the collective zero-interest eco-loan and the reduced rate of VAT can be combined with local grants, subject to conditions on energy savings.
What does a co-ownership risk if it completely ignores this obligation?
The town hall, the prefect or the intercommunal authority may draw up the multi-year works plan by default at the expense of the co-ownership association, and the collective liability of the co-owners may be engaged in the event of harm linked to a poor energy rating of the common areas.
At Althenor, we support our buyer and seller clients in co-ownership in reading these collective diagnostics and their works plans, a criterion that is now decisive in the valuation of a property in the Annecy and Lake Geneva area.