New Requirements: Insulation of Heating Networks

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🔎 Things to remember

A broad and extensive scope: The strengthened law applies equally to both new and existing buildings, whether they are multi-family residential buildings or commercial and service sector facilities (offices, retail spaces, warehouses).

Mandatory Hourly Control Starting in 2027: Effective January 1, 2027, all affected sites must be equipped with a system that adjusts heating and cooling temperatures at least once per hour, by room or by zone (buildings equipped with a BACS system are automatically compliant).

Widespread Adoption of Thermal Insulation: As of January 1, 2027, thermal insulation will become mandatory for all hot water distribution systems (heating, domestic hot water) and cooling systems that pass through unregulated areas or are located outdoors, and must meet at least Class 4 of the NF EN 12 828 standard.

Exemptions Subject to Strict Conditions: Technical or economic exemptions are still possible, particularly with regard to regulation, if the owner submits a study proving that the return on investment (ROI) for the work exceeds 10 years.

As part of the drive to reduce energy consumption, temperature control and insulation requirements for heating and cooling distribution networks have been stepped up.

Which buildings are affected?

Multi-dwelling buildings (or parts of buildings) and buildings (or parts of buildings) in which tertiary activities are carried out, whether for new or existing buildings.

Requirements Related to Temperature Control

From January^1, 2027, control systems will have to regulate heating and cooling temperatures by room or, if justified, by zone, in minimum hourly steps.

Heating systems connected to a building automation and control system (BACS) are deemed to comply with this regulatory requirement.

The heating temperature control requirement does not apply when the heating system's heat generator is an independent appliance for which the fuel supply is not automated.

An exemption is also provided when their installation is not technically or economically feasible, i.e. when the owner produces a study establishing that the installation of such a control system is not feasible with a payback time of less than ten years.

Previously, this requirement was mandatory for :

new buildings for which the building permit is submitted on or after July 21, 2021;
other existing buildings (building permit filed before July 21, 2021), if work to install or replace heat generators (e.g. boilers) is undertaken on or after July 21, 2021. The obligation then applies to the owner of the emitters connected to the installed or replaced generator.

Requirements for Insulating Heating and Cooling Distribution Networks

From January^1, 2027, thermal insulation will be mandatory for :

heating distribution networks, used for heating or domestic hot water (including those connected to a heating network) and passing through unheated premises or those located outdoors;
cooling distribution networks (including those connected to a cooling network) passing through uncooled premises, or located outdoors.

This insulation must comply with the characteristics defined by the Order of June 8, 2023. When the insulation is class 4 or higher according to NF EN 12 828 + A1: 2014 "Heating systems in buildings - Design of water heating systems", it is deemed to meet the required characteristics.

However, when the owner of the distribution network draws up or has drawn up a study establishing that it is technically impossible to comply with the insulation characteristics required by the Order of June 8, 2023, the network is insulated in order to achieve the lowest possible heat transmission coefficient

Previously, the obligation to insulate heating and cooling distribution networks only applied to residential and commercial buildings undergoing renovation (RT element by element or RT global).

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Legal references

Decree no. 2023-444 of June 7, 2023 on temperature control systems for heating and cooling systems and the insulation of heating and cooling distribution networks.

Order of June 8, 2023 on temperature control systems for heating and cooling systems and insulation for heat and cold distribution networks

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Regulatory Aspects	New Requirements (Effective January 1, 2027)	Buildings Affected	Exemptions / Presumptions of Compliance
🌡️ Temperature Control	• Requirement to install automatic temperature control systems (heating and cooling). • Technical note: Control must be provided on a per-room or per-zone basis, with a minimum adjustment interval of one hour.	• Multi-family residential buildings • Commercial buildings (Applies equally to both new and existing* buildings)*	• ✅ Presumption: Buildings equipped with a BACS system. • ❌ Exemption: Standalone, manually fed generators (e.g., non-automated wood-burning stoves) OR a study demonstrating a payback period of more than 10 years.
❄️/🔥 Insulation of Pipelines (Thermal Insulation)	• Requirement to insulate heat distribution systems (heating and domestic hot water) that pass through unheated spaces or the exterior. • Requirement to insulate cooling distribution systems that pass through uncooled spaces or the exterior.		• ✅ Presumption: Insulation class ≥ 4 (according to standard NF EN 12 828). • ❌ Exception: If a technical study demonstrates that it is absolutely impossible, the maximum insulation that is technically feasible must be used.
Reference documents: Decree No. 2023-444 and Ministerial Order of June 8, 2023.