By Renewable Partners B.V. · Published and updated:
The proposal names several categories that are excluded from the obligation to improve to label D by 2029 at the latest: monuments, temporary rental homes and small detached rental homes. An exception is also envisaged for rental homes in a mixed owners' association (VvE) that cannot carry out the sustainability measures due to a negative VvE decision. The exact, final criteria have not yet been established.
The four named categories
Already in the announcement of March 2025 and in the internet consultation of autumn 2025, the cabinet named specific categories to be excluded: monuments (national and municipal), temporary rental homes, small detached rental homes, and rental homes within a mixed VvE where sustainability measures are not possible due to a rejecting VvE decision.
An additional condition applies to the VvE exception: the exception only applies if a change to common areas is needed to reach label D, the VvE makes a negative decision about this, and sustainability measures thereby become impossible for the individual landlord.
What has not yet been established
The precise sizing for 'small detached rental homes' and the exact delineation of 'temporary rental homes' have not been published in detail in reporting so far. This kind of elaboration detail usually follows only in the final regulatory text or in later explanatory notes.
Because the draft decree still has to go through the review period and advice from the Council of State, the exception categories and their conditions may still change before the amendment is finally included in the Bbl.
- Monuments (national and municipal): excluded.
- Temporary rental homes: excluded, exact delineation not yet published.
- Small detached rental homes: excluded, exact sizing not yet published.
- Mixed VvE with a negative decision on necessary measures to common areas: exception under conditions.
Official sources
- Rijksoverheid – Elaboration of energy performance requirements for rental homes and utility buildings
- Rijksoverheid – Start of internet consultation on minimum energy label D for rental homes
- Woonbond – Landlords required to pursue sustainability measures before 2029
- Energieprestatielabel.eu – Minimum energy label D for rental homes from 2029
- House of Representatives – Decision memorandum on the review procedure for the Bbl amendment on EFG labels
General information, not individual legal or financial advice. Proposed legislation and subsidy conditions can change. Check the source and have your property, contract and improvement plan assessed.
An evidence-based property file
Request an on-site assessment or advice. From 5 properties, you can request a free Portfolio Scan.