RE2020 2028 thresholds: the Ic construction ceiling falls by 10 to 18%

A housing development whose outline design starts this autumn has a good chance of submitting its building permit in 2028, and will be assessed against RE2020’s third tier: for every permit application submitted from 1 January 2028, the construction carbon impact ceiling falls by 10 to 18% depending on use. It falls to 580 kgCO2e/m² for apartment buildings from 650, to 475 for detached houses from 530 and to 710 for offices from 810.

The timetable has not changed: the Decree of 18 March 2026, issued following Robin Rivaton’s RE2020 evaluation report, left the 2028 thresholds intact, except for high-rise buildings. However, summer 2026 brought 2 developments: release of RE2020 observatory data, which we used to measure the gap between completed buildings and the 2028 tier, followed by the Decree of 12 September confirming the end of gas in new homes from 2027 permits.

1What RE2020’s 2028 threshold measures

RE2020 sets minimum outcomes for every new building on energy (bioclimatic demand Bbio, consumption Cep and Cep,nr), summer comfort, measured in degree-hours of discomfort, and carbon. The 2025, 2028 and 2031 tiers concern the 2 carbon indicators, with Ic énergie ending in 2028; energy and summer comfort requirements remain stable, apart from a few adjustments, including the Bbio adjustment for offices over 500 m².

2 carbon ceilings, calculated over 50 years

Ic construction measures the climate impact of building components and the construction site: product manufacture, transport, installation, maintenance, replacements and end of life, over a 50-year reference period. Ic énergie measures energy consumption’s impact over the same duration. The 2 are expressed in kgCO2e per m² of reference floor area, habitable floor area for housing and usable floor area for other uses.

Calculation follows a simplified dynamic life cycle assessment: the later an emission occurs in the building’s life, the less weight it carries, and carbon stored for 50 years in bio-based materials is taken into account. Data come from product environmental declarations (FDES) and equipment declarations (PEP) or, failing these, default environmental data, a point becoming decisive in 2028. Our guide to reading FDES for RE2020 calculations details their treatment in software.

An average threshold, adjusted project by project

Published values are average thresholds, valid for a typical building. A project’s legally binding ceiling is obtained by applying adjustments, including: dwelling and building size, climate zone (+30 kgCO2e/m² for housing in zone H2d or H3 below 400 m altitude), converted lofts, ceiling height, balconies and 4 corrections relating to foundations, roads, photovoltaics and default data use.

For completed apartment buildings recorded by the observatory, with permits mainly submitted in 2022 and 2023, the adjusted ceiling reaches a median of 754 kgCO2e/m² for an average threshold of 740: adjustments move a typical project’s target little, mainly affecting projects with a large underground car park or very small dwellings.

2Ceilings 10 to 18% lower depending on use

The 2028 tier applies to all uses subject to RE2020, with varying intensity: the reduction required is greater for uses entering the regulations in May 2026 than for housing, offices and education, which are at their third tier.

Housing, offices, education: the third of 4 tiers

For the 4 original uses, the average Ic construction threshold falls from 530 to 475 kgCO2e/m² for detached houses, from 650 to 580 for apartment buildings, from 810 to 710 for offices and from 770 to 680 for primary and secondary education. The reduction required represents 55 to 100 kgCO2e/m², or 10 to 12% of the ceiling. Compared with 2022, the 2028 ceiling is 22% lower for apartment buildings and 28% lower for offices, and the final tier, in 2031, will reduce them to 490 and 600 kgCO2e/m² respectively.

Hotels, shops, healthcare: a first tier 20 months after entry

The 13 uses subject to RE2020 since 1 May 2026 under Decree No 2026-16 (hotels, restaurants, shops, nurseries, universities, libraries, healthcare, sport, industry and craft activities, airport terminals…) face their first tightening in 2028, and it is greater: 14 to 18%. A hotel falls from 820 to 680 kgCO2e/m², a shop or restaurant from 800 to 670, an industrial building from 840 to 695 and a healthcare establishment from 880 to 760.

Operators already measuring the footprint of their hotels, hospitals, universities or industrial sites find in Ic construction an approach close to the capital assets category of their Bilan Carbone®, calculated here building by building over 50 years.

High-rise buildings: the only relaxed tier

Decree No 2026-200 of 18 March 2026, applicable to permits submitted since 1 July 2026, adapts thresholds for high-rise buildings (top floor more than 50 m high for housing, more than 28 m for other uses), which the ministry considers too difficult to meet, particularly given fire safety constraints. For these, the 2028 threshold is set at 95% of the 2025 threshold, or 617.5 kgCO2e/m² for a residential tower instead of 580, then at 95% of that value in 2031, and the adjustment lowering the ceiling for large buildings is neutralised or reduced.

The same decree stops counting, for housing, balcony carbon above a certain area and carbon from ceiling heights above 2.5 m, and grants 25 kgCO2e/m² to buildings connected to a designated district heating network that install air conditioning, without changing the other 2028 average thresholds.

Like any threshold set by decree, this timetable remains amendable by the government, a risk examined in our article on environmental obligations exposed to the 2027 presidential election. The ministry has published no draft legislation to that effect: as recently as 3 September 2026, it presented publication of observatory data as a way to "prepare for the next regulatory milestones".

3Ic énergie: the exemption for designated district heating networks ends

For energy, 2028 is also the final Ic énergie tier, but ceilings for most uses have already been at their final level since 2025. The reduction primarily affects buildings connected to district heating, and gas leaves new housing through separate legislation from 2027.

District heating: ceilings align on 1 January 2028

In housing and education, a building connected to an urban district heating network currently benefits from a higher Ic énergie ceiling. If the network is designated, every building even retains the 2022 values for a permit submitted before 31 December 2027: 560 kgCO2e/m² for apartment buildings, against 260 without a network. From 2028, ceilings for the 4 original uses align, with or without a network: 260 for apartment buildings, 160 for detached houses, 200 for offices, 140 for education. For uses entering in 2026, only the designated-network exemption disappears.

Among completed apartment buildings connected to district heating recorded by the observatory, 35% would exceed the 2028 Ic énergie ceiling, against 2% of those heated by heat pumps. For a project connected to a designated network whose permit slips into 2028, the network’s carbon content should be checked before designing plant rooms.

Gas leaves new housing from 2027 permits

RE2020 already effectively excludes gas boilers as the main heating system, since 2022 for detached houses and 2025 for apartment buildings, but allows supplementary heating. Decree No 2026-863 of 12 September 2026 goes further: in a new building, every heating, cooling or domestic hot water appliance must use energy emitting less than 79 gCO2e/kWh, the threshold adopted for electricity, excluding gas even for supplementary use.

The obligation targets permits and prior declarations submitted from 1 January 2027 for housing, 1 January 2028 for buildings belonging to public bodies and 1 January 2030 for others, except district heating connections and emergency equipment. Heat pump selection must consider the European refrigerant timetable, and heating gas will enter the second European carbon market in 2028.

4Does a permit submitted in late 2027 still fall under the 2025 threshold?

Yes: the year of submission of the building permit application, or prior declaration, sets the applicable tier, regardless of construction or completion date. A permit submitted on 31 December 2027 remains assessed against the 2025 thresholds even if the building is completed in 2030; submitted on 3 January 2028, it falls under the new tier.

Compliance is checked 2 times: through a certificate attached to the permit submission, then a certificate on completion of works, based on an updated study that must remain below the submission year’s ceilings.

Amending permit, new permit: 2 distinct situations

An amending permit requires no new RE2020 certificate, according to the ministry’s FAQ: the updated end-of-works study incorporates project changes. The FAQ does not specify the applicable tier, but this absence of a new certificate supports retaining the initial permit’s tier. A new permit, submitted after refusal, withdrawal or a redesigned programme, falls under the tier of its own submission year.

The practical risk concerns developments designed to the 2025 threshold whose submission slips a few weeks, because land agreement or programme finalisation is lacking: an apartment building outline design at 640 kgCO2e/m², compliant for submission in December 2027, is no longer compliant for submission in January 2028, with the same adjustments.

Housing faces 2 deadlines within 12 months

For a housing programme, the timetable stacks 2 reductions: permits submitted in 2027 must already dispense with gas, including supplementary use, and those submitted in 2028 must also meet the new carbon ceilings. For their other buildings, schools, offices or facilities, public clients face the 2 deadlines on the same day, 1 January 2028, while also having to incorporate an environmental criterion in their procurement.

5Fewer than one in 5 completed apartment buildings would pass the 2028 threshold

Since summer 2026, the ministry has published RE2020 observatory data from regulatory certificates on data.gouv.fr. We used the extract as at 1 January 2026, covering 110,906 completed new buildings with permits submitted between 2022 and 2025, and recalculated each one’s 2028 ceiling with project-specific adjustments, excluding balconies and ceiling height, introduced in 2026.

A median gap of 15 to 26% above the threshold

As built, 17% of apartment buildings, 9% of detached houses and 21% of office buildings would already meet the 2028 ceiling. The median gap above the threshold reaches +15% for apartment buildings, or around 90 kgCO2e/m², +19% for detached houses and +26% for offices, where dispersion is greatest.

These buildings targeted the 2022 threshold. Nevertheless, the share of apartment buildings below the 2028 threshold is rising, from 16% for 2022 permits to 22% for 2024 permits. Developments submitting in 2028 still start from current practice around 90 kgCO2e/m² from the target.

Default data: a bonus until 2024, a penalty from 2028

The Mided coefficient adjusts the ceiling according to the contribution of default data and fixed values in the calculation, excluding foundations, roads and photovoltaics. Above a use-specific threshold (250 kgCO2e/m² for apartment buildings, 275 for offices, 300 for education, 370 for detached houses), it increased the ceiling by 30% of the excess until 2024, has had no effect since 2025, and lowers it by 30% of the excess from 2028.

In completed offices, 85% of projects exceed this threshold, particularly because the electrical power work package’s fixed value, used by 85% of them, alone amounts to 115 kgCO2e/m², and the heating-ventilation value to 200 when used. Applied to completed offices, the 2028 Mided would subtract a median of 57 kgCO2e/m² from the ceiling, more than half the reduction between 2025 and 2028.

6Where kgCO2e/m² are saved, work package by work package

In a completed apartment building, average Ic construction of 687 kgCO2e/m² is distributed across 13 work packages and the construction site. Superstructure accounts for 21%, far ahead of other packages, and not all count the same way for compliance.

Structure: the first lever for the required reduction

In completed apartment buildings, the superstructure package has a median impact of 154 kgCO2e/m² when the declared structure is concrete, 120 for mixed timber-concrete and 64 for solid timber. The gap between concrete and timber, 90 kgCO2e/m², alone exceeds the 70 kgCO2e/m² reduction required in 2028. It is 53 kgCO2e/m² for detached houses (91 versus 38), against a reduction of 55, and 63 for offices (146 versus 83), against a reduction of 100 that moving away from fixed values must complement.

These comparisons involve modest sample sizes for timber (45 buildings) and a material declared for information in the study, with no effect on the calculation: they give an order of magnitude. A concrete project wanting to pass 2028 without changing its construction system must optimise quantities and specify concrete with reduced clinker content, documented through individual FDES.

Foundations and roads: above a baseline, the threshold adjusts

Adjustments add to the ceiling everything by which the foundations and infrastructure package exceeds 40 kgCO2e/m², roads and utility networks exceed 10 (20 for detached houses) and photovoltaics exceed 20. An underground car park therefore increases the footprint without jeopardising compliance: 61% of completed apartment buildings exceed the baseline of 40 and have the excess neutralised.

Reducing a building’s foundations from 120 to 90 kgCO2e/m² therefore does not bring it closer to the threshold, because only the share below 40 counts. The saving remains real for the climate and for a developer’s scope 3, which includes these emissions in its own footprint.

Technical work packages: moving away from fixed values

The electrical power package uses fixed values in 83% of completed apartment buildings (48 kgCO2e/m²), 84% of houses (98) and 85% of offices (115). Replacing them with PEP declarations for the specified equipment reduces the share of default data, and therefore the 2028 penalty, and lowers Ic construction as soon as products outperform the fixed value. Our guide to FDES, PEP and EPD details what each declaration covers.

Façades and fit-out: a stable source of impact

Façades, partitions and coverings together account for 190 kgCO2e/m² in apartment buildings, 28% of Ic construction. Yet the façade package varies little: its median remains between 58 and 70 kgCO2e/m² depending on the declared insulation, polystyrenes, mineral wool, wood fibre or cellulose insulation. Savings are achieved product by product, with references covered by individual FDES. These materials’ end of life also falls under construction EPR, whose reform is under way.

7Where to start for a permit submitted in 2028

For a project submitting its permit from 2028, the regulatory calculation is a complete life cycle assessment, managed from outline design, while structure and heating choices remain open. The stages follow those of an eco-design process applied to a building.

• Set the permit submission date: 2025 thresholds until 31 December 2027, the 2028 tier thereafter; for housing, gas excluded from 2027.
• Calculate against the 2028 threshold from outline design, including adjustments, keeping a margin for the end-of-works study.
• Inventory default data and fixed values work package by work package, and request suppliers’ FDES and PEP before inviting contractors to tender.
• Decide on structure first: this is the package with the greatest gap between solutions, enough to cover the required reduction for apartment buildings.
• Check heating: the network’s carbon content if designated, the heat pump’s refrigerant.

For us at Projet Celsius, the costliest mistake is basing a project on the 2025 threshold because its permit is due to be submitted in late 2027: a refusal or programme redesign is enough to push the new submission into 2028, and a structure fixed at outline design is difficult to remedy during execution. Once completed, non-residential buildings of at least 1,000 m² will also fall under the Tertiary Decree, which will track their actual consumption.

8Key takeaways

• The 2028 tier applies to permits submitted from 1 January 2028: submission year sets the threshold, regardless of completion date.
• Ic construction ceilings fall by 10 to 18%: 580 kgCO2e/m² for apartment buildings, 475 for houses, 710 for offices, 670 to 950 for non-residential uses entering in 2026.
• Only high-rise buildings obtained a relaxation, to 95% of the 2025 threshold; no postponement is confirmed as at 28 September 2026.
• Completed buildings are far from meeting it: 17% of apartment buildings and 9% of houses would already pass, and default data become a penalty.
• The reduction is achieved through structure and product data, with foundations and roads neutralised above a baseline.

For the calculation itself, our guide to LCA for a new building describes the study stages, and our article on choosing between LCA, PEF and product carbon footprint helps construction manufacturers produce the data their customers will now require.

Further resources

Frequently asked questions

1When does RE2020’s 2028 threshold apply?

It applies to building permit applications and prior declarations submitted from 1 January 2028. A permit submitted by 31 December 2027 remains assessed against the 2025 thresholds, regardless of completion date. The next tier will concern submissions from 1 January 2031.

2What is the 2028 Ic construction threshold for an apartment building?

The average threshold is 580 kgCO2e/m² of habitable floor area, compared with 650 for permits submitted from 2025 to 2027; it will fall to 490 in 2031. The project’s legally binding ceiling is obtained by applying project-specific adjustments. For a residential tower classified as a high-rise building, whose top floor exceeds 50 m, the 2028 threshold is 617.5 kgCO2e/m².

3Does the 2028 threshold concern non-residential buildings?

Yes: offices fall from 810 to 710 kgCO2e/m² and education from 770 to 680. The 13 uses entering RE2020 on 1 May 2026 (hotels, shops, restaurants, healthcare, industry, sport, universities…) also face their first tier, a 14 to 18% reduction depending on use, for example 680 kgCO2e/m² for a hotel or 670 for a shop.

4Has RE2020’s 2028 threshold been postponed?

No: as at 28 September 2026, no legislation postpones the 2028 tier. Decree No 2026-200 of 18 March 2026, issued following RE2020’s evaluation, only relaxed the high-rise threshold, set at 95% of the 2025 value, and added a few adjustments.

5Does an amending permit submitted in 2028 move the project to the 2028 threshold?

In principle no, although the ministry does not state this explicitly: according to its FAQ No 035, an amending permit requires no new RE2020 certificate, and the updated end-of-works study incorporates project changes. A new permit, submitted after refusal, withdrawal or programme redesign, instead falls under its submission year’s tier.

6Can a gas boiler still be installed in a new home?

No, for housing permits submitted from 1 January 2027: Decree No 2026-863 of 12 September 2026 prohibits every heating, cooling or domestic hot water appliance whose energy emits 79 gCO2e/kWh or more, even for supplementary use. Only district heating connections and emergency equipment remain possible. The ban extends to public buildings in 2028 and others in 2030.

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