EBA Pillar 3: Why Your Lender Is Asking for Better EPC Data

44% of commercial real estate energy performance data was still unknown.

That is one of the more striking numbers behind the EBA’s push for better ESG data from European banks. ECB analysis of bank portfolios as of December 2023 found that lenders had actual EPC data for only 22% of commercial real estate and 29% of residential real estate. Even after estimates were used to fill some of those gaps, 44% of commercial real estate energy performance data remained unknown.

The picture is beginning to change. By February 2026, the EBA reported that banks’ reliance on proxy indicators had fallen by around 10 percentage points compared with December 2023, pointing to a gradual shift from estimated portfolio level information towards more reliable asset level data.

What does your lender actually need to know?

Under the EBA’s Pillar 3 ESG disclosure framework, banks report on the energy efficiency of the real estate securing their loans. For commercial and residential property, this means looking at several layers of information:

• Energy consumption: the building’s performance in kWh/m², grouped into defined consumption ranges.

• EPC rating: the energy performance certificate of the property, from the strongest performing classes through to the weakest.

• Data quality: whether the bank has actual energy performance information or is relying on estimates because data is missing.

• Property profile: whether the collateral is commercial or residential and where it is located.

This is already producing a clearer picture of European real estate lending. EBA data indicate that roughly half of EU real estate lending sits within the first two energy consumption buckets, below 200 kWh/m².

Why 31 December 2026 matters to borrowers

The revised EBA Pillar 3 ESG disclosure framework is expected to apply from the 31 December 2026 reporting reference date for the relevant institutions. This is a reporting date for banks, rather than a universal deadline requiring every property owner to provide an EPC by the end of the year.

For borrowers, however, the connection is practical because banks cannot improve the quality of their real estate data without obtaining better information about the buildings securing their loans.

As lenders reduce their reliance on proxies, EPCs and actual energy consumption data are likely to become increasingly relevant during refinancing, new lending and portfolio reviews.

Where verified information is missing, the lender may need to ask more questions, request additional documentation or rely on estimates and conservative assumptions in order to complete its assessment of the asset.

This can make a refinancing process more difficult because the lender has less certainty about the energy performance of the collateral and may need to spend more time resolving gaps before it can form a complete view of the building.

Energy performance is also becoming more relevant to lending decisions themselves. ECB bank lending surveys show that banks are already applying tighter credit standards to buildings with persistently low energy performance and more favourable standards to buildings with stronger or improving energy performance.

This does not mean that a missing EPC automatically results in a higher interest rate, but it does mean that weak building data and weak energy performance are becoming more relevant to how lenders assess real estate exposures.

If the data is missing, the bank still needs an answer

A missing EPC or incomplete energy dataset does not remove the asset from the bank’s assessment. Instead, it can leave the lender relying on estimates or proxies where verified building level information is unavailable.

For owners, that makes three questions particularly relevant before the next financing discussion.

- Do we have a current EPC for every relevant asset?
An expired, unavailable or incomplete certificate creates a data gap precisely where lenders are trying to reduce their reliance on estimates.

- Can we support the EPC with actual energy data?
Consumption data gives lenders a more complete view of how the building performs than an estimated portfolio level proxy.

- What does the data reveal about future investment needs?
Lower energy performance can point towards renovation requirements, additional capital expenditure and greater transition risk that may become relevant during refinancing.

The same issue is also becoming increasingly important from a regulatory perspective. Under the revised EPBD, Member States must establish minimum energy performance standards for non residential buildings, with the first threshold applying in 2030 and a tighter threshold following in 2033.

This means that weak energy performance can become relevant to the same asset in two different ways. It can affect the quality of the information available to the lender today while also indicating potential future exposure to national MEPS requirements.

We look at this regulatory side in more detail in EPBD 2026: What Asset Managers Need to Know After the Transposition Deadline, including how the 2030 and 2033 thresholds work and why they should not be treated as simple EPC classes.

The important shift is therefore from simply having an EPC somewhere in the data room to being able to provide reliable asset level information when the lender assesses the building.

From compliance document to lending data

For many property owners, EPCs have traditionally been documents needed for regulatory compliance, transactions or leasing. Pillar 3 shows why their role is becoming broader because energy performance information is increasingly feeding into how banks understand and report the real estate behind their credit exposure.

The current data gap is still substantial, but it is narrowing. With actual EPC coverage at just 22% for commercial real estate in the ECB analysis and banks already reducing their reliance on proxies, owners should expect the quality of their building level information to receive more attention.

For owners preparing for refinancing, the practical takeaway is to understand what EPC and energy data is available, identify gaps before the lender does and consider what that information says about the future performance and investment needs of the asset.

Better data makes both lending and regulatory planning easier

The shift taking place is not that Pillar 3 creates a new reporting obligation for property owners.

The more important change is that banks are being asked to understand the real estate behind their exposures with greater precision, while regulation such as the EPBD is simultaneously making the same energy performance information more important for owners themselves.

That makes the quality of asset level data increasingly relevant to both financing and portfolio planning.

Blue Auditor consolidates EPC and actual energy data at asset level, flags missing information and expired certificates, and shows how each building sits against lender and regulatory thresholds.

This gives real estate teams a clearer view of where the data is already sufficient, where information needs to be improved and where weak energy performance may point towards future investment requirements.

If you are reviewing portfolio exposure ahead of the 2030 and 2033 MEPS milestones, the next step is to understand which assets are most sensitive to changing national requirements and where better data or earlier intervention may be needed.

Blue Auditor brings EPC, energy and transition risk data together at asset and portfolio level so you can identify gaps, compare buildings against relevant thresholds and turn regulatory uncertainty into a clearer investment plan.

See how your portfolio is positioned and where action may be needed next.