EU taxonomy: updated top 15% benchmarking for German real estate
Claudio Tschätsch
Drees & Sommer SE
08.2025
Since January 2024, stricter requirements for the EU taxonomy have been in force for financial market participants and large companies. This has resulted in additional environmental targets and further reporting obligations. To enable credit institutions to continue to verify and demonstrate the taxonomy compliance of their ‘green’ funding activities in a comprehensible and transparent manner, the Association of German Pfandbrief Banks (vdp) and Drees & Sommer, a consulting firm specialising in construction, real estate and infrastructure, have updated the top 15% benchmarking last published in October 2023. In addition to adapting to the regulation, the analysis has been expanded to include the hotels as an asset class. The benchmarking thus covers all major asset classes in the German property sector.
Banks and credit institutions must keep track of the regulatory jungle in order to demonstrate the sustainability of their business activities. And new requirements are constantly being added. The top 15% benchmarking provides the necessary transparency and serves as a guide for Pfandbrief banks and other financial companies. The top 15% criterion is based on the EU Taxonomy Regulation and economic activities listed therein, ‘Acquisition and ownership of real estate’. According to this, a building constructed by the end of 2020 is considered taxonomy-compliant if, among other things, it ranks among the top 15% of its property class in terms of the national or regional market and its primary energy consumption. Drees & Sommer and the vdp are determining the exact key figures that can be used to verify this in their third annual benchmarking study. The advanced methodology includes, for example, additional CO2 emission indicators and hotel buildings as a further asset class. The updated study thus ensures that credit institutions are up to date when verifying the taxonomy compliance of real estate financings and that they meet the requirements in the best possible way.
In addition to basic recommendations, the study contains detailed and comprehensible criteria for the asset classes residential, office, retail, logistics and, most recently, hotels. It is based on national legislation and also takes into account the preliminary recommendations for the revision of the EU taxonomy and the requirements for zero-emission buildings defined in the EU Directive on the energy performance of buildings.
Decisive criteria: building energy efficiency
To be among the top 15% in its class, a residential building should, for example, have energy efficiency class A+ or A or a calculated final energy consumption of less than 30 or 50 kWh per square metre per year. Building energy efficiency is also a decisive criterion for non-residential buildings. Since regulations such as the Energy Saving Ordinance (EnEV) and the Building Energy Act (GEG) do not specify a uniform upper limit for all applicable building uses, the study recommends assessing the building energy efficiency of non-residential buildings according to individual asset classes. For example, the annual energy consumption for heating and electricity in an office building should be between 140 and 240 kWh per square metre, while the final energy consumption of a hotel in the top 15% can be between 213 and 233 kWh per square metre per year.
Further information on the top 15% benchmarking and a summary of the current study are available on the vdp-Website or at Drees & Sommer.
