In Brussels, no home can be put up for rent without a valid EPC (PEB) certificate, and its energy class must appear in every listing. For the agency that lets on behalf of an owner, the obligation is direct. And the 1 January 2033 deadline for homes rated F and G needs preparing now.

When is the EPC certificate mandatory for a rental?

The Brussels Air, Climate and Energy Management Code (COBRACE) settles the question. Its Article 2.2.13 covers anyone acting on their own account or as an intermediary. It applies to letting, lease assignment and lease renewal. That person must state unambiguously, in the related advertising, the energy performance information of the property. They must provide a copy of the EPC certificate free of charge, on any request. Finally, they must make sure this information appears in the transaction deed. The holder of the right must have a valid EPC certificate at the time the deed is signed between the parties. The agency is therefore not a mere relay for the owner: the text targets it directly, as an intermediary. In practice, a property without a certificate should not be advertised. The check therefore takes place when the mandate is taken, before any viewing.

Who orders the certificate and how long is it valid?

According to the Brussels Environment page on the EPC certificate for a home, it covers any individual dwelling of 18 m² or more. It must be drawn up before the property is put on the market. It is up to the owner to have it drawn up and to pass it on. It is issued by an accredited certifier, whom the owner chooses freely from the regional list. The COBRACE limits its validity to a maximum of ten years (Article 2.2.4/1). The online register of certificates lets you check, from an address, whether a valid certificate already exists. The price is not regulated. For information, Brussels Environment cites at least EUR 210 including VAT for a 90 m² flat. What matters for the agency lies elsewhere: the certifier only takes into account what is seen or proven. The same page states that the more technical evidence you provide, the better the certificate’s result.

Insulation invoices and technical sheets for the window frames and the boiler therefore belong in the unit file. In a co-ownership, Brussels Environment advises asking the syndic for these documents. If the home is let, the visit date is agreed with the tenants.

What goes into the listing and into the lease?

For the listing, a Brussels Environment fact sheet requires the energy class to be stated in all advertising: small ads, internet, posters, estate agency windows. Its examples simply show “PEB : C+”. From 1 July 2028, the decree of 3 July 2025 on the EPC certificate specifies the content. The listing will show the energy consumption indicator and the energy class indicator (Article 4.1.1).

For the lease, the Brussels Housing Code lists the energy performance certificate among the pre-contractual information. The landlord provides it no later than the conclusion of the lease (Article 217, § 1, 5°). Any public communication about a letting must include this information. The Regional Inspection Service can impose a fine of EUR 50 to EUR 200 for a breach (Article 217, § 2). Since 1 January 2025, lease registration also requires the energy certification level and the certificate number (Article 228/3).

What are the penalties if the certificate is missing?

Breaching any of the three obligations in Article 2.2.13 is a criminal offence (COBRACE, Article 2.6.5, 8° to 10°). The penalty refers to Article 31, § 1, of the Inspection Code. It provides for imprisonment of eight days to two years and a fine of EUR 50 to EUR 100,000, or one of these penalties only. If the public prosecutor does not prosecute, Brussels Environment can impose an alternative administrative fine. It ranges from EUR 50 to EUR 62,500 and can fall below the minimum in mitigating circumstances (Article 45). Brussels Environment says it carries out checks to verify that EPC data appear in listings. For an agency, the risk is not theoretical. A listing published without an energy class engages the intermediary’s liability, not only the owner’s.

What does the 2033 deadline change for rented homes?

The ordinance of 7 March 2024 set performance targets for all existing buildings, whether sold or not. For homes, the decree of 3 July 2025 on EPC indicators and requirements, published on 31 December 2025, is precise. It requires primary energy consumption of no more than 275 kWhEP/m² per year on 1 January 2033 (Article 2.1.2). It then sets 150 kWhEP/m² per year within twenty years of the provision’s entry into force. According to Brussels Environment, the 275 threshold currently corresponds to energy class E at most. Homes rated F and G will therefore have to improve. A ministerial decree of 19 February 2026, published on 9 March 2026, sets the entry into force of this part at 1 July 2028. The two decrees of 3 July 2025 enter into force on the same date.

Two consequences for rental management. First, every holder of a right in rem will need a valid certificate, even without a letting. The deadline is five years after entry into force, that is 1 July 2033 (Article 2.2.4/2). Second, the link with the classes is not fixed: Brussels Environment says “currently”, and the decree on the calculation of indicators applies from 1 July 2028. For the 150 threshold, the same page states 31/12/2045 at the earliest, a date the government still has to set. The Walloon roadmap follows its own timetable, detailed in our article on the Walloon energy roadmap.

How much will an F or G home cost after 2033?

Article 2.6.1/1 of the COBRACE provides for an administrative fine when the valid certificate shows that the requirement is not met. It targets the certificate holder and, where relevant, the association of co-owners. It can be imposed up to five years after the deadline. The main rate is EUR 2.5 per 1 kWh/year gap in total primary energy. For homes, the gap taken into account is capped at 125 kWh/m² per year. Take an 80 m² flat at 450 kWh/m² per year: the 175 kWh/m² gap is brought down to 125. On our reading of the scale, 125 × 80 × 2.5 gives EUR 25,000. Brussels Environment can, however, split the fine. One part, at most half, is paid directly. The rest is only due if the offender has not complied within two years. The percentages depend on whether or not the holder bears the energy costs of the home. A landlord whose tenant pays for energy therefore falls under a separate key.

The same article protects one specific case. Take a certificate drawn up after 1 January 2017, which shows that the requirement is met. Its end of validity was later declared for a reason unrelated to its quality control. The fine linked to the 2033 deadline then does not apply. Keeping favourable certificates, even expired ones, is therefore worthwhile.

How does the EPC affect the rent?

The first effect concerns indexation. Under Article 224/2 of the Brussels Housing Code, an upward indexation requires two conditions. The written lease has been registered, and the EPC certificate has been provided to the tenant. For properties rated E, F or G, the same article provides for a correction factor since 14 October 2023. Its calculation is detailed in our article on autumn 2026 rent indexation.

The second effect concerns the reference rent. The official simulator loyers.brussels, published by Brussels Housing, asks for the EPC level. It states that this information will be used for the bonuses and penalties applied to the indicative reference rent. It adds that if you do not know the level, you should enter level G. Yet Article 224 of the Code presumes abusive a rent that exceeds its reference rent by twenty percent. The presumption falls if substantial comfort features justify the gap. The EPC certificate is one of the documents in this justification file. Our article on Constitutional Court ruling 105/2026 recalls that these rules remain in place.

What should the agency do when the flat is in a co-ownership?

The flat’s certificate remains its owner’s business. From 1 July 2028, Article 2.2.4/3 of the COBRACE adds obligations for the association of co-owners. It appoints an EPC expert, who issues a certificate for each private unit that lacks a valid one. The expert writes a summary report with renovation recommendations and sends it to Brussels Environment. If this report targets common parts, the duty to carry out works also falls on the association (Article 2.2.4/5). When the requirement is not met, the association of co-owners is presumed to have failed in its obligation. It can rebut this presumption by proving its diligence. A co-owner acting in good faith can escape the fine for common works. They must show they did everything possible to have the association approve the necessary works (Article 2.6.1/1). They remain liable for the share linked to their private unit.

For the agency advising the owner of a flat, three reflexes follow. Ask the syndic for the technical documents needed for the certificate. Have energy works put on the general meeting agenda, in writing. Keep the requests, minutes and votes: they are the evidence of good faith. Brussels Environment warns, on its page on EPC in co-ownership, that the summary report does not exist yet. It is therefore not yet possible for a co-ownership to meet this obligation.

What checklist for a let property in Brussels?

  1. When taking the mandate: check the register for a valid certificate, its date and its class.
  2. Before the listing: obtain the certificate, then show the energy class on every medium.
  3. At the lease: mention the certificate in the pre-contractual information, hand it to the tenant and enter its number at registration.
  4. At indexation: check that the certificate was provided to the tenant before requesting the adjustment.
  5. For 2033: identify the F and G units in the portfolio and propose a dated works plan to the owner.
  6. After works: have the certificate redone with the invoices and technical sheets.

Boiler maintenance falls under a separate EPC inspection, covered in our article on boiler and detector maintenance by region.

How does Seido help prepare for these deadlines?

Managing several properties? In Seido, the management report details the works and their cost. Indexations appear in an appendix, with the old and new rent. The owner thus sees what has been done on the property, in each monthly or quarterly report. It is a concrete basis for discussing the works to plan before 2033. See how automated owner reporting works.

Frequently asked questions

Can the agency publish the listing while waiting for the certificate?

No. Article 2.2.13 of the COBRACE expressly targets the person acting as an intermediary. That person must state the energy performance information in the advertising, which presupposes an existing certificate. Brussels Environment specifies that the certificate must be drawn up before the property is put on the market. A listing without an energy class exposes the agency to the criminal penalty in the Inspection Code, or to an alternative administrative fine.

Can a G-rated home still be let in 2026?

Yes. None of the provisions cited here currently prohibits letting a G-rated home. The 1 January 2033 deadline imposes a performance level, not a ban on letting. After that date, non-compliance is punished by an administrative fine. The class already weighs on the rent, however: it feeds into the reference rent simulator and governs certain indexation rules.

Who pays the 2033 fine in a co-owned building?

The fine targets the certificate holder and, where relevant, the association of co-owners. The association is presumed at fault when the requirement is not met and the summary report targeted common parts. A co-owner acting in good faith can be exempted for common works if they prove they did everything to have them approved. They remain liable for works that depend solely on their private unit.

Should an old EPC certificate be redone before re-letting?

If it is less than ten years old and still valid, it is enough to let. Brussels Environment nevertheless recommends updating it after works, if new technical evidence turns up, or if it dates from before 2017. A more favourable certificate improves the listing and the rent file. After works, it is also the certificate that will show the 2033 requirement is met.

Sources and references

Last updated: October 2026. This article is provided for information purposes only and does not constitute legal advice. For any specific situation, consult a real estate law professional.