RE2020 Extension: Concrete Impacts for the Building Sector in 2026

Since January 1st, 2025, the requirements of the RE2020 (Environmental Regulation 2020) have become more stringent. Thresholds for the Ic Construction indicator were tightened by approximately 12% for housing and 17% for offices, pushing current projects (residential, office, and educational buildings) toward more demanding environmental targets.

However, this is not the only major shift for new construction. As anticipated by the industry for several years, new building typologies will soon enter the scope of RE2020.

This extension serves a dual purpose: it provides methodological clarity by ending complex situations where a single project had to navigate RT2012, the E+C- label, and RE2020 requirements simultaneously. Yet, it also raises questions regarding the specific level of requirements for these new categories.

New building categories covered by RE2020 in 2026

The buildings included in this extension are largely those that were previously subject to RT2012. These include:

  • Libraries and media centers;
  • Atypical educational buildings and university research facilities;
  • Hotels;
  • Early childhood childcare facilities;
  • Restaurants and retail stores;
  • Changing rooms and sports facilities;
  • Healthcare facilities (including those with accommodation);
  • Airport terminals;
  • Industrial and artisanal buildings.

The decree regarding thermal and environmental requirements specifies that these categories must comply with RE2020 for any projects with a building permit application submitted on or after January 1st, 2026.

Should We Expect Ambitious Thresholds?

Regarding the regulatory environmental thresholds (Ic Construction and Ic Energy), the requirements for these new categories are expected to be slightly more flexible than those for offices. Estimates place them around 800 kg eq. CO₂/m² for Ic Construction and 200 kg eq. CO₂/m² for Ic Energy.

Threshold modulation based on building location, surface area, and specific works (such as VRD/Roads and Utility Networks, Infrastructure/Foundations, and local electricity production equipment) will be maintained. These modulations rely on “pivot values” specific to the building type:

  • Roads and Utility Networks (VRD): Pivot value of 10 or 20 kg eq. CO₂/m².
  • Foundations and Infrastructure: Pivot value of 40 or 60 kg eq. CO₂/m² (rising to 100 kg for airport terminals).
  • Local Electricity Production: Pivot value of 20 kg eq. CO₂/m².

If a project’s impact exceeds these pivot values, the IcConstruction threshold increases proportionally.

Will default “flat rates” for technical lots be maintained?

While awaiting the official modified decree, the specific flat-rate values for technical lots have not yet been announced. Early indications suggest they will likely mirror those used for offices.

As a reminder, a flat-rate lot in RE2020 is a generic, penalizing environmental data point used by default when it is impossible to detail every piece of equipment in a lot. These values typically cover HVAC, high-voltage, and low-voltage electrical systems.

What about renovation?

A major question remains: how to approach renovation projects from an environmental impact perspective? Currently, only energy performance is regulated for renovations.

The Low Carbon Prescribers Hub (a collaborative platform led by the IFPEB) is advocating for an experimental label similar to the E+C- label that prefigured RE2020 to establish a calculation method and specific carbon reduction targets for renovated buildings.

The European Context

Many European countries are beginning to follow suit, gradually deploying environmental regulations, certifications, and country-specific databases. This trend is driven by EU Directive 2024/1275, which requires member states to calculate the environmental impact of their building stock. A key milestone is set for 2028, by which time all new public buildings must be zero-emission.

The year 2026 will mark a major turning point for the environmental assessment of new buildings in France. In the following years, the focus is expected to shift progressively toward renovation and reducing the carbon footprint of the existing European building stock.