New requirements: insulation of heat distribution networks

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🔎 Key takeaways

A massive and extensive scope: The strengthened legislation targets both new and existing buildings, whether they are multi-family residential buildings or commercial premises (offices, shops, warehouses).

Mandatory hourly regulation by 2027: As of January 1, 2027, all affected sites must be equipped with a system that adjusts heating and cooling temperatures with a minimum hourly interval, per room or zone (buildings equipped with a BACS system are automatically compliant).

Generalization of pipe insulation: As of that same date, January 1, 2027, thermal insulation becomes mandatory for all hot (heating, domestic hot water) and cold distribution networks passing through non-regulated areas or located outdoors, and must meet at a minimum class 4 of the NF EN 12 828 standard.

Exemptions under strict conditions: Technical or economic exemptions remain possible, particularly for regulation, if the owner provides a study proving that the return on investment (ROI) for the work is greater than 10 years.

Please note: This article concerns French legislation. The requirements described may not apply in other countries.

As part of energy conservation efforts, requirements for temperature regulation and insulation of heating and cooling distribution networks have been strengthened.

Which buildings are affected?

Collective residential buildings (or parts thereof) and buildings (or parts thereof) used for commercial activities, whether for new or existing buildings.

Obligations related to temperature regulation

As of January 1^st , 2027, regulation systems must control heating and cooling temperatures on at least an hourly basis, either by room or, where justified, by zone.

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

The heating temperature regulation 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 installation is not technically or economically feasible, meaning the owner provides a study establishing that installing such a regulation system would not have a return on investment of less than ten years.

Previously, this requirement was mandatory for:

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

Obligations regarding the insulation of heat and cold distribution networks

As of January^1, 2027, pipe insulation will be mandatory for:

hot distribution networks used for heating or domestic hot water (including those connected to a district heating network) that pass through unheated rooms or are located outdoors;
cold distribution networks (including those connected to a district cooling network) that pass through uncooled rooms or are located outdoors.

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

However, when the owner of the distribution network establishes or has a study conducted establishing that it is technically impossible to meet the insulation characteristics required by the decree of June 8, 2023, the network must be insulated to achieve the lowest possible thermal transmission coefficient.

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

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Legal references

Decree No. 2023-444 of June 7, 2023, regarding temperature control systems for heating and cooling systems and the insulation of heat and cold distribution networks

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

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Regulatory area	New obligations (from 1 January 2027)	Buildings concerned	Exemptions / Presumptions of compliance
🌡️ Temperature control	• Requirement to install automatic temperature control systems (heating and cooling). • Technical detail: Control required per room or zone, with a minimum hourly step.	• Collective residential buildings • Tertiary (commercial/office) buildings (Applies equally to new and existing* buildings)*	• ✅ Presumption of compliance: Buildings fitted with a BACS system. • ❌ Exemption: Standalone, manually fed generators (e.g. non-automated wood stove) OR a study demonstrating a payback period over 10 years.
❄️/🔥 Network insulation (Lagging)	• Requirement to insulate heat distribution networks (heating and domestic hot water) running through unheated premises or outdoors. • Requirement to insulate cold distribution networks running through non-cooled premises or outdoors.	• ✅ Presumption of compliance: Insulation of class ≥ 4 (per standard NF EN 12 828). • ❌ Waiver: Where a technical study demonstrates absolute impossibility, the maximum technically achievable insulation applies.
Reference texts: Decree No. 2023-444 and Ministerial Order of 8 June 2023.