Do I need an Energy Performance Certificate for a non-residential building unit?

The EPC for a non-residential building unit (EPC NR) reflects the energy efficiency of a building unit used as an office, school, store, hospital, etc., and indicates how much work is still needed to renovate it into a carbon-neutral building unit. 

The EPC of a non-residential building unit not only provides the owner(s) or tenant(s) with insight into the building’s energy performance but also indicates how that performance can be improved.

The EPC NR is therefore a tool to guide owners toward the long-term goal (carbon neutrality).
Per non-residential building unit
The energy performance certificate of a non-residential building unit (EPC NR) is issued per non-residential building unit.

Non-residential building units are all building units whose primary use (open definition) is “non-residential,” meaning all building units except residential buildings, industrial buildings, and agricultural buildings.
 
The owner of a small non-residential (kNR) building unit may choose to have an EPC for a small non-residential building unit issued instead of an EPC NR. The format and content of this EPC kNR are similar to the EPC for residential building units and have been specifically developed for small non-residential building units that bear strong similarities to residential buildings in terms of architecture, systems, materials, use, etc.
Mandatory
An EPC NR is mandatory for rentals and for all forms of notarial transfer of full ownership (open definition) (e.g., sale) At the time the building unit (open definition) is offered for sale or rent, a valid EPC must be available.
At the time of the transfer (open definition) (no later than the date of execution of the deed or the establishment of the right of superficies or the leasehold), the EPC must be provided to the new owner or tenant.
There are a few exceptions. See: Scope of Application EPC (Small) Non-Residential Exceptions (on the EPC-pedia).
Buildings that are protected (monuments, city or village views, etc.) must also have an EPC NR issued.
Please note: this requirement applies only if an entire building unit is sold, transferred, or leased. If only a part of a building unit is leased (e.g., a small office space in an office building), an EPC NR does not need to be issued.
When putting a property up for sale or rent, certain elements from the EPC must be included in advertisements or announcements offering the building unit for sale or rent. The mandatory inclusion of EPC data in advertisements applies to owners, but equally to real estate agents, notaries, etc.
This EPC must be issued by a certified Energy Expert (Type D).(opens in new window)
Procedure
The preparation of a Non-Residential Energy Performance Certificate (EPC NR) entails a number of tasks and responsibilities for various parties involved: the building owner or their authorized representative, the energy expert, and the building user.

You will also find a handy overview of the steps you need to take in the starter guide (PDF file opens in a new window).

Step 1
The owner appoints an energy expert
 
Step 2
The owner gathers supporting documents
 
Step 3
The owner provides access to the building unit for the energy expert
 
Step 4
The energy expert prepares the EPC NR and delivers it to the applicant
 
  
Validity
An EPC for a non-residential building unit is valid for a maximum of 5 years.
The EPC NR expires: if the building unit changes use (for example, from non-residential to residential or industrial)
or if a new EPC is submitted.
Contents of the EPC NR
You can see what an EPC for a non-residential building unit looks like in this example “EPC Non-residential Unit” (PDF file opens in a new window).If the necessary measurement data is not available, you will receive an EPC with label X (PDF file opens in a new window).
The EPC NR consists of two complementary parts: an energy score and an energy label (from G to A) that reflects the energy performance of the building unit on a scale from red (poor) to green (good).
The EPC NR also contains recommendations on how the non-residential building unit can be made even more energy-efficient. The recommendations in the EPC NR are advisory, but not mandatory.
From the EPC NR, you can determine which modifications are necessary to comply with the renovation obligation.
Timeline of Obligations
The requirement to have an EPC NR will be phased in gradually until every large non-residential building unit has an EPC by 2026, even if it is not being sold or rented out.

The government and public organizations serve as role models and are therefore taking some steps earlier.

Step 1/12/2023
: EPC NR mandatory for sales, leasehold transfers, building rights, and rentals
 
 
Step 1/5/2023
: EPC NR mandatory for all notarial transfers and rentals
 
Step 1/12/2024
: EPC NR mandatory for all public and government buildings

 
Step 1/1/2025
EPC NR mandatory for all large non-residential building units (with a floor area greater than 1,000 m²)
 
 
Step 1/1/2026
EPC NR mandatory for all large non-residential buildings
 
Step 1/1/2028
Minimum Label E for public and government buildings
 
Step 1/1/2030
Minimum Label E for every large non-residential building unit
 
 
To prevent buildings scheduled for demolition from having to obtain an EPC, the Flemish government provides for an exception to the general EPC requirement (points 2024, 2025, 2026, 2028, and 2030 above). Buildings for which a demolition permit has been granted are not subject to the EPC requirement. The owner (or leaseholder/holder of a right of superficies) must report this no later than one month before the EPC is due for renewal and must provide proof within five years that the demolition work has been completed. Please note: this exception does not apply in the event of a transfer (point 2023 above). An EPC NR remains required for all notarial transfers.

Examples:

You are selling a non-residential building in 2024: you must have an EPC NR at the time the building is listed for sale, and the EPC NR must be handed over to the buyer at the time of transfer.
You own a non-residential building of 1,800 m²: you must have an EPC NR issued by January 1, 2025 (general obligation to have an EPC NR). Unless the building is demolished and a demolition permit has been granted. In that case, you do not need to have an EPC NR issued.
You are selling a non-residential building of 600 m² in 2026: your building already has an EPC NR (general obligation to have an EPC NR).
New construction units

New units with a valid EPC Construction can use that EPC Construction to meet the EPC requirement. Note: a unit that meets the new construction requirements does not automatically meet the minimum label for the EPC NR. After all, the latter can only be demonstrated based on usage data, which is not known for a new building.
Cost
There is no fixed cost for an EPC NR. The price depends on the size and complexity of the building and the travel expenses of the Type D energy expert. It is best to compare the price and quality of different energy experts.

 

Source: https://www.vlaanderen.be/bouwen-wonen-en-energie/niet-residentiele-gebouwen/energieprestatiecertificaat-van-een-niet-residentiele-gebouweenheid-epc-nr