As the heating season begins, much of Europe will again keep warm by burning fossil fuels, leaving households and city budgets exposed to volatile energy prices. Local heating and cooling plans are how cities can change this: cutting demand, tapping local renewable and waste heat, and coordinating investments with building renovation and electricity networks.
Yet more than a year after the transposition deadline of 11 October 2025, our EU tracker shows that progress on local heating and cooling planning remains limited. One year after the transposition deadline, only one more country, Romania, has joined the nine Member States that have established a legal framework for Article 25(6). This provision requires Member States to ensure that municipalities with more than 45,000 inhabitants prepare local heating and cooling plans.
The Commission has started to act: on 1 October 2026, it issued reasoned opinions to Greece, Spain, Italy and Malta for failing to fully transpose the recast Energy Efficiency Directive. These proceedings concern the directive as a whole, and the delay on local planning goes well beyond these four countries.
More countries could close the gap by spring 2027. Spain and Ireland are preparing both the obligation and the support arrangements, Poland and Sweden plan to fold heating and cooling into existing municipal energy planning, and Estonia and Luxembourg also report legislative work underway. For most of them, the texts are still in preparation and the arrangements have yet to become operational.
Existing instruments also still need careful assessment. Greece’s municipal emission reduction plans cover municipal assets and activities, but do not replace heating and cooling planning across the whole territory, including residential and commercial buildings.
Romania shows another route. Its new law requires local authorities in territories of at least 20,000 inhabitants to prepare heating and cooling plans, going beyond the EU threshold of 45,000. It provides an indirect path towards implementing Article 25(6), although full alignments remain to be assessed.
Even where the law exists, municipalities need capacity, expertise and funding, and support. In Belgium, the region of Flanders has introduced a statutory planning obligation. Although the Flemish energy agency and association of municipalities continue to provide technical guidance, the Local Energy and Climate Pact providing financial support is being phased out and ends on 1 January 2027. Other funding remains available, but losing this framework raises concerns about municipalities’ capacity to maintain their work.
The Brussels Region has published a zoned vision identifying suitable heating solutions, while transposition of the municipal planning obligation is still ongoing. Support tools are being assessed, and the suspension of RENOLUTION grants currently limits available financial support. No developments were identified in Wallonia during our analysis.
In Slovakia, the Regional Centres for Sustainable Energy project was stopped in 2025, with no replacement identified. Municipalities need continuity in the support structures on which their planning depends.
The Netherlands, on the other hand, shows how analysis and capacity can go together. Its updated Startanalyse compares alternatives to fossil gas at neighbourhood-level, and CDOKE resources can support staff and external expertise. Moreover, as the funds go through the Municipal Fund, municipalities are the ones who decide how they are allocated.
Delayed transposition is only part of the problem. Around 1,220 municipalities across EU Member States, covering more than 154 million citizens, need to be ready to prepare and implement local heating and cooling plans. This requires sufficient staff and expertise, demand for qualified consultants, energy agencies and other experts. Countries that extend the obligation to smaller municipalities, like Romania, further increase the challenges.
The Commission should therefore:
The international context and difficulties in energy markets make further delays costly. Exposure to gas prices affects household bills and local budgets. Giving municipalities the means to plan the end of fossil heating should be a core part of Europe’s response to energy affordability and resilience.