New rules for building products, buildings and letting
Building materials manufacturers, contractors and property owners work under EU regulations, German law and the rules of the countries where they build or let. COBACK reads new publications every day and checks them against your plants, products, sites and buildings.
Topics and rules
What is changing, who in the company works with it and which legal acts are behind it.
Building products and materials
The new Construction Products Regulation has applied since 8 January 2026 and replaces Regulation (EU) No 305/2011 in stages until 2040. Once harmonised specifications under the new rules apply to a product family, manufacturers issue a declaration of performance and conformity; environmental information and a digital product passport follow through delegated acts. Importers of cement, steel or aluminium from outside the EU have been under the definitive CBAM regime since January 2026 if their CBAM goods together exceed 50 tonnes a year. Product management, quality assurance and procurement are affected.
Examples
- Construction Products Regulation (EU) 2024/3110
- Regulation (EU) No 305/2011
- CBAM Regulation (EU) 2023/956
Building energy and heating
The Energy Performance of Buildings Directive requires new buildings owned by public bodies to be zero-emission from 2028 and all new buildings from 2030. For non-residential buildings, the worst-performing 16 percent must be renovated by 2030. Germany implements it, among other things, through the Building Modernisation Act, as the Buildings Energy Act has been called since 29 July 2026. It drops the 65 percent requirement for new heating systems. Anyone who then installs a gas or oil heating system in an existing building must produce at least 10 percent of the heat from biomethane, bio-oil or hydrogen from 2029, and at least 60 percent from 2040. Project development, technical asset management and fund management are affected.
Examples
- Energy Performance of Buildings Directive (EU) 2024/1275
- Building Modernisation Act (Gebäudemodernisierungsgesetz, GModG), formerly the Buildings Energy Act, amended by BGBl. 2026 I No. 226
Carbon costs and emissions trading
Heating oil and natural gas carry a carbon price in Germany under the Fuel Emissions Trading Act, auctioned in 2026 within a corridor of 55 to 65 euros per tonne. From 2028, EU emissions trading for fuels used in buildings and road transport applies. How landlords and tenants share the carbon costs is set by the Carbon Dioxide Cost Allocation Act, which directly affects property management and service charge statements.
Examples
- Fuel Emissions Trading Act (Brennstoffemissionshandelsgesetz, BEHG)
- Directive (EU) 2023/959 (ETS2)
- Carbon Dioxide Cost Allocation Act (Kohlendioxidkostenaufteilungsgesetz, CO2KostAufG)
Safety and hazardous substances on site
Directive (EU) 2023/2668 lowers the occupational exposure limit for asbestos to 0.01 fibres per cubic centimetre, to be transposed by 21 December 2025. Since December 2024, Germany's Hazardous Substances Ordinance has required clients to give contractors the construction year and known hazardous substances before work starts. Only where construction began after 31 October 1993 may it generally be presumed that no asbestos is present. In England, buildings of at least 18 metres or seven storeys with at least two residential units fall under the Building Safety Act 2022 and its regulator. Project management, occupational safety and construction procurement are affected.
Examples
- Directive (EU) 2023/2668 (asbestos at work)
- Hazardous Substances Ordinance (Gefahrstoffverordnung, GefStoffV), sections 5a and 11a
- Building Safety Act 2022 (United Kingdom)
Tenancy law and service charges
The rent cap in sections 556d et seq. of the German Civil Code has been extended to the end of 2029; the federal states designate by ordinance which areas it covers. Where a new gas or oil heating system under the Building Modernisation Act is installed in a let existing building, landlord and tenant each pay half of the carbon costs and gas network charges from 2028. From 2029 they also split the cost of the mandatory bio-fuels, up to a 30 percent share of the fuel used. Letting, property management and legal are affected.
Examples
- Rent cap (Mietpreisbremse), sections 556d et seq. German Civil Code (BGB)
- Carbon Dioxide Cost Allocation Act (CO2KostAufG), section 5a
- Building Modernisation Act (GModG), section 43
Anti-money laundering in property deals
Since April 2023, the purchase price for German real estate may no longer be paid in cash, crypto assets, gold, platinum or gemstones, and this also applies to share deals. From 10 July 2027, the EU Anti-Money Laundering Regulation applies directly, with a cap of 10,000 euros on cash payments for goods and services. Transaction teams, estate agents and money laundering reporting officers are affected.
Examples
- German Anti-Money Laundering Act (Geldwäschegesetz, GwG), section 16a
- Anti-Money Laundering Regulation (EU) 2024/1624
Sustainability reporting and financing
The omnibus package limits reporting under the CSRD to companies with more than 1,000 employees and more than 450 million euros in turnover. Anyone holding buildings through funds or financing them as green works with the EU Taxonomy criteria for new construction, renovation and the acquisition and ownership of buildings. Finance, investor relations and fund management are affected.
Examples
- Directive (EU) 2026/470 (Omnibus I)
- Taxonomy Regulation (EU) 2020/852
The path of a change
Example: the new Building Modernisation Act
01Law database
The act amending the Buildings Energy Act is promulgated in the Federal Law Gazette (BGBl. 2026 I No. 226) and renames it the Building Modernisation Act. COBACK picks it up in its daily run.
02Relevance
The twin shows that your company holds 41 residential buildings, 18 of them with gas boilers that the maintenance plan in SharePoint schedules for replacement in the coming years. The relevance score is 87 out of 100. The reasoning names the dropped 65 percent requirement, the mandatory bio-fuel shares from 2029 and the equal split of carbon costs with tenants from 2028.
03Open questions
Whether the replacements will run on gas again is not recorded in the twin. COBACK asks technical asset management. After the answer, the head of compliance decides the act is relevant.
04Task
COBACK creates tasks with deadlines: asset management reviews the replacement plan by 30 November 2026, property management adjusts the service charge statements and tenant information, and the finance team checks funding.
Working with COBACK
Daily reading of new publications
COBACK reads new legal acts from EUR-Lex and the Bundesgesetzblatt every day, along with publications from regulators and parliaments in Europe and worldwide.
Checked against plants, products and buildings
Each publication is checked against your twin and gets a relevance score from 0 to 100. The reasoning names the sources and the facts COBACK used, such as sites, product groups or heating types in your portfolio.
Questions where facts are missing
If the twin lacks a fact, such as the year a building was built, COBACK asks. A person decides whether a change is relevant.
Tasks and an optional module
Relevant changes become tasks with steps, owners and deadlines. Building products manufacturers can add an optional product compliance module that checks bills of materials against substance lists such as REACH SVHC, REACH Annex XVII and PFAS.
Frequently asked questions
Does COBACK work for property owners who do not build themselves?
Yes. Your twin then mainly covers your companies, buildings and processes such as letting and property management. The relevance scores follow from that: rules on building energy and tenancy tend to affect you more than rules for materials manufacturers.
How does COBACK know our buildings and systems?
From connected systems such as SharePoint or Google Drive, public registers, your website and a questionnaire. Nobody uploads files by hand. Where a fact is missing, COBACK asks.
Will COBACK tell us which heating system to install?
No. COBACK gives no legal or technical advice and does not decide for you. It shows which new rules touch your plans, backs that with sources and, once you decide, turns it into tasks.
Does COBACK cover projects outside Germany?
Yes. COBACK reads publications from the EU, European countries and other regions of the world. You choose which countries to watch.
