Energy Cities calls out missed opportunities by Member States to support local heating and cooling planning
The clock is ticking for Member States to transpose local heat planning obligations, but progress remains slow. Our EU Tracker reveals that while countries stall, pioneering cities are already moving forward.
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On October 2023 – two years ago- the recast Energy Efficiency Directive (EED) was published in the Official Journal of the European Union. Since then, Member States have been tasked with transposing its provisions into national law and the deadline has already passed.
According to the EED’s legal timeline, Article 25.6 on local heating and cooling planning must be transposed into national law by 11 October 2025. This means that all Member States should have established the necessary legal framework requiring municipalities with more than 45,000 inhabitants to begin planning for the decarbonisation of their heating and cooling systems.
As we mark the second anniversary of the EED, one might ask: is it time to bring out the cake and celebrate? Or should we keep the party hats on hold?
Energy Cities has updated its EU Tracker, our tool for monitoring the readiness of Member States to implement Article 25.6. This year, we focused on tracking legal transposition, while keeping an eye on the enabling measures that could turn planning obligations into real local action. So, how is the party turning out?
- 8 Member States have transposed article 25.6 into national law or have the appropriate legal framework (France, Germany, the Netherlands, Denmark, Croatia, Hungary, Estonia, Finland);
- 9 Member States have serious gaps for an adequate legal framework (Portugal, Spain, Italy, Bulgaria, Romania, Poland, Slovakia, Lithuania);
- 19 Member States are missing the deadline to transpose article 25.6 into national law.
The party will wait.
Member states are not taking the challenge seriously
While a few Member States have shown early signs of readiness, notably the Netherlands and Denmark — Germany was the first to formally transpose the directive. Back in 2024, Energy Cities welcomed this step forward. However, optimism quickly faded with the appointment of a new federal government. The recently adopted heat law has become a target of misinformation, and political leaders began to question the level of ambition. This shift in tone is part of a broader pattern observed in several Member States.
In Austria, the federal government is working with the Länder to develop a national heating and cooling strategy, aiming for full heat decarbonisation by 2040. However, the federal funding scheme — which covered up to 75% of the cost for replacing heating systems — ended in 2024 and is now under review. Hopefully, some regional programmes, such as Vienna’s, remain active for now.
In Sweden, the European Commission has initiated infringement proceedings for shortcomings in the implementation of the Energy Efficiency Directive. The main criticism concerns the lack of sufficient measures to ensure regular monitoring and follow-up of local energy planning. As of now, Article 25.6 has not been transposed. Local governments and municipalities have also voiced concerns, highlighting the lack of support and resources to meet the new requirements. Many feel overwhelmed by the administrative and financial burden that mandatory local heat planning entails.
When transposing the article 25.6 of the Energy Efficiency Directive, most Member States are showing the minimum level of ambition:
- France transposed part of Article 25.6 through the “Loi DDADUE”, applying the obligation only to inter-municipalities (EPCI) with at least one municipality over 45,000 inhabitants (which is less ambitious than EPCI with 45,000 inhabitants). No deadlines or concrete implementation requirements have yet been set. A ministerial decree and guidance document are expected shortly.
- Croatia transposed the directive with general provisions. The lastest update of the Heat Market Law (04/2025) defined that “Local government units with more than 35,000 inhabitants must develop heating and cooling plans in the manner and under the conditions specified in the regulations governing energy efficiency.” The treshold shows higher ambition than the requirement of the EED, but there is a gap with the supportive framework.
- Spain has worked on the transposition with broad consultations and the involvement of civil society. A new Heat Guide was published and will inspire the national government for the transposition. However, there has been no improvement in the supportive framework.
- Hungary has partially transposed the EED by transferring most of the corresponding responsibilities to the municipalities, without securing or providing the necessary resources. The law regulating district heating services (2005/XVIII, amended by 2025/XLV) assigns this task to the municipal councils where applicable – meaning municipalities with more than 45,000 inhabitants.
- Flanders (Belgium) has adopted the first draft of the transposition, with final adoption foreseen around November. The draft transposes Article 25.6 using the 45,000-inhabitants threshold. The Flemish government decided to stop the Local Energy and Climate Pact, which had provided valuable support to municipalities.
Visit our EU Tracker to explore detailed information for each Member State through its dedicated country factsheet. You can also discover how cities are putting these policies into practice in our featured stories on decarbonisation.
What’s next?
The European Commission will start monitoring the transposition of article 25.6 and urge Member States to transpose the provision. Member States failing to transpose the article will be facing an infringement procedure. Hopefully, it will be a wake-up call.
Beyond the transposition checks, the Commission is already busy working on a new EU Heating and Cooling Strategy. The strategy, first expected by the end of 2025, is now delayed to early 2026. Much work remains to mobilise it as a facilitating tool for Members States and their municipalities. A call for evidence is now undergoing (until the 20th of November). For Energy Cities the strategy should establish clear decarbonisation pathways for industrial and urban heat, accelerate permitting, and unlock investment in clean technologies and infrastructure. Just as the EU successfully scaled renewable electricity, it must now do the same for heating and cooling, with local authorities at the core. Find out Energy Cities’ recommendations here.
Energy Cities is also monitoring the discussion on the next Multiannual Financial Framework (MFF). The Commission’s proposal for the 2028-2034 Multiannual Financial Framework, presented on 16 July, introduces new ‘National and Regional Partnership Plans’, intended to simplify EU funding and reduce disparities. Energy Cities, along the Local Alliance, argues that this approach risks centralising the EU budget, weakening Cohesion Policy, and marginalising local and regional governments in the policy design and implementation. Yet, the MFF could be mobilised to support the deployment of heating and cooling projects. The creation of a Clean Heat Facility is an idea that could support local authorities in developing renewable heating and cooling projects, moving from planning to implementation.
