GEG, EnEfG & EPBD: what German law means for lighting control

For lighting control in non-residential buildings in Germany, three sets of rules are currently the most relevant: the EU Energy Performance of Buildings Directive (EPBD 2024/1275), which explicitly requires automatic lighting control with occupancy detection; the Building Modernisation Act (Gebäudemodernisierungsgesetz, GModG), which replaced the Building Energy Act (Gebäudeenergiegesetz, GEG) in July 2026 and transposes the EPBD into German law; and the Energy Efficiency Act (Energieeffizienzgesetz, EnEfG), which obliges energy-intensive companies to introduce management systems and implementation plans. According to the information portal of the Federal Institute for Research on Building, Urban Affairs and Spatial Development (BBSR), non-residential buildings with heating, air-conditioning or ventilation systems rated above 70 kW must be equipped with monitoring technology and automatic lighting control by 31 December 2029. This guide puts the requirements into context and shows what operators and planners should do now.

Overview: which rule affects whom?

EU Energy Performance of Buildings Directive (EPBD 2024/1275)

The recast EU Energy Performance of Buildings Directive was published in the Official Journal on 8 May 2024 and has applied since 28 May 2024. Member states generally had 24 months to transpose it. For non-residential buildings, Article 13 sets out the following requirements for building automation, among others, as summarised by the Gebäudeforum klimaneutral:

• Building automation in non-residential buildings with systems above 290 kW by 31 December 2024
• Building automation in non-residential buildings with systems above 70 kW by 31 December 2029
• Automatic lighting control with appropriate zoning and occupancy detection, to be implemented by 31 December 2027 (according to the BBSR summary, for non-residential buildings with systems above 290 kW)

Important: an EU directive does not apply directly to building owners but takes effect through national law. In Germany, it is transposed via the GModG.

From the GEG to the Building Modernisation Act (GModG)

What applied until now: § 71a GEG

Under § 71a GEG, non-residential buildings with a rated output of the heating system or combined space heating and ventilation system, or of the air-conditioning system, of more than 290 kW had to be equipped with a building automation system by 31 December 2024. For existing buildings, at least automation class C in accordance with DIN V 18599-11 was required. Owners who have not yet met this obligation should clarify what action is needed promptly.

What changes with the GModG

The Bundestag and Bundesrat passed the Building Modernisation Act on 10 July 2026, and it was promulgated in the Federal Law Gazette on 28 July 2026. The first provisions have applied since 29 July 2026; according to the BBSR, the provisions transposing the EPBD are coming into force in stages.

The key provision for lighting control is § 56 GModG (building automation and control of non-residential buildings). According to the BBSR's GModG information portal:

• By 31 December 2029, all non-residential buildings with a heating, air-conditioning or ventilation system (or combined systems) with a rated output of more than 70 kW must be equipped with monitoring technology and automatic lighting control (§ 56 (1)).
• The automatic lighting control must be appropriately zoned and feature occupancy detection (§ 56 (6)).
• Among other things, the monitoring technology must make data accessible via a common and freely configurable interface and enable energy efficiency benchmarking and the detection of efficiency losses (§ 56 (2)).
• For monitoring technology installed in the three years before entry into force that does not fully meet the requirements, the portal cites an extended deadline of 31 December 2039.
• Exemptions are provided for, among other cases, where compliance is technically impossible or economically unreasonable.

Fines

Breaches of § 71a GEG could be punished with a fine under § 108 GEG. Whether the GModG provides for corresponding offences, and at what level, should be checked in each individual case against the legal text.

Energy Efficiency Act (EnEfG)

The EnEfG is aimed not at buildings but at companies, depending on their total final energy consumption. Under current law:

• § 8: companies with an average annual total final energy consumption of more than 7.5 GWh must set up an energy or environmental management system.
• § 9: companies with more than 2.5 GWh must draw up, have confirmed and publish implementation plans for economic final energy saving measures. A measure is considered economic if it achieves a positive net present value in accordance with DIN EN 17463 after no more than 50 % of its service life; measures with a service life of no more than 15 years are considered.

The Federal Cabinet adopted an amendment on 24 June 2026. Among other things, it plans to raise the threshold for management systems to around 23.6 GWh and to link implementation plans to an energy audit. The parliamentary process has not been completed; until promulgation, the existing rules continue to apply.

For lighting control, § 9 is particularly relevant: if an energy audit or management system identifies lighting control as an economic measure, it belongs in the implementation plan. The guide Calculating savings and payback shows how to calculate cost-effectiveness.

Standards: DIN EN 12464-1 and DIN V 18599

Laws govern efficiency; standards govern lighting quality and energy balance calculation:

• DIN EN 12464-1 sets out requirements for the lighting of indoor workplaces, such as a maintained illuminance of 500 lx for writing, reading and data processing. A lighting control system must not fall below these values while the space is in use; daylight and constant light control must be set up accordingly.
• DIN V 18599 is the energy balance calculation method for non-residential buildings. Part 4 covers the energy demand for lighting, including dependence on presence and daylight, and Part 11 covers building automation with its automation classes. According to the BBSR information portal, the GModG refers to the version DIN/TS 18599-11:2025-10.

Funding: BEG individual measures

Under the Federal Funding for Efficient Buildings (Bundesförderung für effiziente Gebäude, BEG EM – individual measures), the Federal Office for Economic Affairs and Export Control (BAFA) funds the installation of measurement, control and regulation technology in non-residential buildings to achieve a building automation level of at least class B in accordance with DIN V 18599-11. The basic funding rate is 15 %, eligible costs are capped at 500 euros per square metre of net floor area, and an energy efficiency expert must be involved. According to BAFA's technical FAQs, daylight- or presence-dependent lighting control can form part of such measures. Specialist sources point out that optimising the lighting in isolation is usually not sufficient if the building as a whole does not reach the required automation level. You should therefore clarify eligibility for funding with your energy efficiency expert before awarding contracts.

What operators and planners should do now

1. Check whether you are affected: determine the rated output of the heating, air-conditioning and ventilation systems for each building (thresholds of 70 kW and 290 kW).
2. Assess the existing installation: is there automatic lighting control with zoning and occupancy detection? How is monitoring set up?
3. Ensure interfaces: new systems should provide data via open protocols, see BMS integration via BACnet, Modbus and API.
4. Document cost-effectiveness: for EnEfG implementation plans and funding applications.
5. Clarify funding before placing orders: BEG EM requires the application to be submitted before the project starts and an energy efficiency expert to be involved.
6. Draw up a timetable: there are only a few budget cycles left until 2029. Combine the retrofit with measures that are planned anyway.

Conclusion

With the EPBD and its transposition in the Building Modernisation Act, automatic lighting control with zoning and occupancy detection is becoming mandatory for many non-residential buildings; according to the BBSR, for buildings with systems above 70 kW by the end of 2029. At the same time, the EnEfG requires larger energy consumers to plan and implement economic measures, and the BEG funds building automation from class B upwards. Those who check now whether they are affected, assess their existing installations and plan the retrofit will avoid time pressure. The savings calculator provides an initial estimate of the savings; for a specific project, you can reach us via our contact page.