EU Tracker – Local heating and cooling plans in Belgium

Summary

What is the status of the transposition of Art 25.6 (EDD) and its implementation ?

Belgium’s three regions are responsible for transposing and implementing article 25.6 of the Energy Efficiency Directive.

Flanders has established a legal obligation for municipalities with more than 45.000 inhabitants to prepare local heating and cooling plans, while further implementing rules are being developed. Brussels has published a regional “zoned vision” to support heating planning, and the municipal planning obligation is still undergoing transposition. In Wallonia, the March 2024 assessment identified mandatory studies on opportunities for heat networks; an updated assessment of its legal and support frameworks is pending.

Municipalities need sufficient staff, expertise, accessible data and predictable financing to translate planning into implementation. The phase-out of the Flemish Local Energy and Climate Pact raises concerns about the continuity of support, while Brussels is assessing additional assistance for municipalities preparing their plans.

Flanders, Wallonia and Brussels are assessed separately because of their regional responsibilities for energy and spatial planning.

The legal framework and the obligations (Belgium overall)

The support framework (Belgium overall)

Flanders, Wallonia and Brussels have been analysed separately due to their degree of autonomy on energy and spatial planning related issues. They are consequently presented separately below

Flanders 

Flanders has incorporated local heating and cooling planning requirements into its Energy Decree. Municipalities with more than 45.000 inhabitants are subject to a statutory planning obligation, while further implementing rules are being developed.

VEKA and VVSG continue to provide guidance, tools and knowledge-sharing opportunities. However, municipalities face difficulties with data, staff capacity, expertise and financing, particularly when moving from planning to implementation.

The phase-out of the Local Energy and Climate Pact (LEKP), which ends on 1 January 2027, removes an important source of support for local climate and energy action. The previous participation rate in LEKP should therefore no longer be used as evidence of a continuing commitment by virtually all municipalities to prepare heating and cooling plans.

Detailed assessment

The legal framework and the obligations

Overview of the legal frameworks per governance level

Regional

The Flemish heat plan 2025 acknowledges the importance of area-specific approach for the deployment of heat supply and encourages the development of heat plans by local authorities.   It also mentions support from the region to local authorities to develop and implement their climate and energy plans including their heat plans.   Flanders has incorporated the provisions of Article 25(6) of the recast Energy Efficiency Directive into the Flemish Energy Decree. Further implementing legislation is being prepared to clarify practical obligations, governance arrangements and support mechanisms.

Local

Flanders has moved beyond a purely voluntary approach to local heating and cooling planning through the incorporation of Article 25(6) of the recast Energy Efficiency Directive into the Flemish Energy Decree. Further implementing legislation is being prepared to clarify practical obligations and governance arrangements. Following the discontinuation of LEKP, it can no longer be assumed that virtually all Flemish municipalities remain committed to developing local heating and cooling plans voluntarily. The Flemish Energy and Climate Agency together with the Association of Flemish Cities and Municipalities (VVSG) developed extensive guidance to support the development of complete and quality heat plans.  These guidelines recommend to include: data collection; vision development including target settings; heat zoning map; an action plan; participative roll-out in residential districts and business parks. Stakeholders can be involved in the above-mentionned steps depending on their expertise, interest, and data ownership (different local governements services, DSOs, provinces, inter-municipal organization, local citizens’ energy cooperatives, major heat or waste producers, business park managers etc.)

 The support framework

VEKA and VVSG continue to provide guidance, tools, methodologies and knowledge-sharing opportunities for local authorities. However, municipalities continue to face challenges related to data, staff capacity, expertise and financing, particularly when moving from planning to implementation.

Nevertheless, the lack of staff or skills within municipalities as well as the financial limited means slow down the process.  

Provided Support

Technical and organisational	5/5	The Flemish energy and climate agency along with VVSG has developed four types of technical guidance products for local heat planning:   (1) A heat guide “Warmtegids” which contains step by step guidance for drawing up a local heat plan, an overview of potential partners and financing options, technical background knowledge on heat solutions (catalogue of technologies) and answers to often asked questions.   (2) A heat zoning inspirational map provides to municipality a first view on the different heating zones and the potential for district heating and cooling network on their territories.   (3) A template for tender specifications for the making of local heat plans.   (4) A programme to support certain municipalities and cities (so far 12 gathered in 5 trajectories) to develop their local heat plans. This includes co-financing, technical and human resources support with the appointment of an engineering office. This program aims at sharing good practices and lessons learned with other Flemish municipalities.    In addition to technical guidance, VVSG has organised recurrent exchange sessions on practices for heat panning between local governments.
Financial	3/5	The financial support for the development and implementation of heating plans by municipalities is insufficient and not structural. The discontinuation of LEKP has reduced a key source of financial support for local climate and energy initiatives. Many municipalities are concerned about maintaining sufficient capacity to develop and implement heating and cooling strategies, particularly in smaller administrations. 5 local heat planning (covering 12 municipalities) also received co-financing support (€10.000/trajectory) from VVSG.   It has to be noted that the Flemish climate and energy agency provides operational funding for the VVSG Climate Network. In doing so, the Flemish government indirectly supports local governments in the development of their local heat plans.
Staff & skills	3/5	There is an important lack of staff and more importantly skills within local government administrations to coordinate the development of local heat plans. It is especially the case to coordinate the participatory roll-out of the strategies in residential districts and business areas. There is an important gap between large municipalities having an internal expert team and the small municipalities where the person in charge is not dedicated only to heating.   The guidelines developed by the Flemish government and VVSG recommend hiring an expert (consultant, engineering office) as the topic is complexed and require special data analysis and planning skills.
Access to data	4/5	In the heat zoning inspirational map, the VVSG with the support of the Flemish region has made available the energy demand data at a street level combined with detailed building data (from Vito’s urban energy pathfinder).   The mapping of renewable potentials and heat sources is quite good although some information is missing on industrial waste energy and shallow geothermal potential.   In general, municipalities can get good knowledge on district heating networks but have difficulties to get information on gas grids.

Wallonia

Since 2023, all Walloon municipalities have been required to develop an opportunity study for the development of heat networks. The Walloon government is in the process of developing a substantial technical and financial support mechanism and will aim at improving the quality of the data. However, there is a lack of support for strategic heat planning including all the heating and cooling technologies. 

The legislative framework focuses on district heating only, it should address the entire heating sector to be ready for the transposition of the new provision (article 25) of the recast Energy Efficiency Directive.

Detailed assessment

The legal framework and the obligations

Overview of the legal frameworks per governance level

Regional

The 2021 Wallonian Strategy for heating and cooling networks powered by cogeneration, waste energy (recovered heat) or renewable energy sources puts forward the idea of an opportunity study for the municipal level, and the integration of heat networks into the concept of municipal plans.

Local

Since 2023, according to Decree of the Walloon Government implementing the decree of 15 October 2020 on the organization of the thermal energy market and thermal energy network ( chapter 10- articles 110 to 112),  all Walloons local authorities have to carry out an opportunity study based on a methodology provided by the ministry of Wallonia on the possibilities of deploying a thermal energy network powered by waste energy or renewable energy sources. This shoud be assessed when municipalities develop energy and decarbonisation related plans such as SECAPs, and in cases when waste heat is available on the territory, in a quantity sufficient to power a district heating system. This opportunity study shall be reviewed every 4 years. The first study will have to be submitted by the end of March 2024.   Nevertheless, these studies will not cover all heating technologies and do not offer a strategic and spatial vision for the decarbonisation of the heating and cooling sector on the whole territory of the municipalities.

The support framework

A technical and financial support framework is under development and show promising signs. Opportunity studies for district heating will be 75% funded by the region. However, Walloon cities lack expertise in this area, and are heavily dependent on external contractors for energy planning purposes. Limited access to quality energy-related geodata is also a large constraint.

Provided Support

Technical and organisational	3/5	A methodology on heat planning is about to be published by the Ministry of Wallonia. The ministry will also produce a template for the terms of references for the tenders that municipalities will release for the feasibility study of district heating and the project implementation. The ministry has also provided an information section on its website dedicated to the new requirement of a municipal heat opportunity study.
Financial	3/5	Wallonia region will finance 75% of the cost of the opportunity study and realisation of the project. The Walloon region has set up a system of accreditation for consultancy firms authorised to carry out these studies on behalf of the local authorities, which already recognises 140 consultancy firms.  To ensure the quality of the plans and to avoid long lead times on the budget of the local authorities, the region pays the consultancy directly and the municipality pays the reminding cost to the region when the study is delivered. The other financial supports from the region will now be under the condition to have this opportunity study done.
Staff & skills	2/5	In municipal administration, there is a clear lack of expertise on heating and cooling topics. Municipalities have more expertise in the building sector. The feasibility studies are therefore thought to be done mainly by a municipal employee, supported by an accredited consultant.
Access to data	2/5	The access to qualitative data needs to be improved in Wallonia.   Regarding energy demand, municipalities do not have access to residential building data and public building data are uneven depending on previous analysis. The grid operators do not have obligation to share data but could be willing to do it as a city level on an annual or monthly basis.   The Walloon ministry is trying to provide aggregated demand and set up a quality open-source database for municipalities.

Brussels 

With the adoption of its Air, Climate and Energy Plan (ACEP, 2023) and the RENOLUTION ordonnance (2024), the Brussels Capital Region adopted concrete measures to implement the new provisions of the Energy Efficiency Directive. Bruxelles Environnement has also published a regional “zoned vision” identifying suitable renewable heating solutions by area. The report and indicative maps provide a basis for local planning and the development of a future regional heating plan. Bruxelles Environnement also offers technical and financial support to municipalities while leading the works on the regional heating plan.

This framework (ACEP, RENOLUTION) adds on the already existing ban on heating using fossil fuels in Brussels (Climate law and COBRACE). Indeed, there is already in Brussels a robust framework that prohibits fossil fuel heating for new constructions (2025) and heavy renovation (2030) as well as a gradual phase out of oil powered boilers. A regional Taskforce (with multiple stakeholders, including the regional DSO) is working on a regional long-term strategy to phase out gas heating. The Brussels region also finances energy experts in each municipality and continues to develop accessibility to data. Nevertheless, the transposition of the new article 25 of the Energy Efficiency Directive will require additional means to support municipalities in the implementation of the identified projects.

Detailed assessment

The legal framework and the obligations

Overview of the legal frameworks per governance level

Regional

The regional Climate law adopted in 2021 introduced the first ban on fossil fuel heating for new building as well as the phasing out of new oil powered boilers for all buildings. This provision was then strengthened by the adoption of the new regional Energy & Climate plan (ACEP, 2023) and the RENOLUTION Ordonnance (2024). This new plan outlines all regional actions to fulfil EED’s provisions (before the 2023 recast), and particularly the drafting a regional heating map covering all municipalities (with more or less than 45.000 inhabitants). The plan aims at supporting new district heating infrastructures by 2030.   Through various technical and financial schemes, the region supports municipalities, and the DSO, in their energy planning. The local association of municipalities is also supported by the region and consulted.   The transposition of Article 25.6 of the recast EED into regional law is ongoing. According to the update received, the draft introducing the municipal planning obligation has passed its first reading but has not yet been adopted.

Local

All municipalities are supported by the region in the drafting of their Local Energy and Climate Action Plan (LECP) (HR or project financing, technical support, community of practice,…).   All municipalities can benefit from regional support to implement energy efficiency measures (eg: Renoclick, EPB experts,…). LECP are to be coherent with the regional ACEP.  For example, the LECP of the City of Brussels aims at building a new district heating infrastructure in cooperation with Bruxelles Energie (waste incinerator) by 2030. This is in line with the ACEP.

 The support framework

Municipalities can access technical support from regional authorities. The support provided by the Regional Agency is very complete and accessible. The collection of data is an ongoing process and will help municipalities to identify opportunities.

The regional zoned vision provides an additional basis for identifying suitable heating solutions. The Region is also assessing dedicated tools and templates to support municipalities in preparing their local heating and cooling plans

Nevertheless, the lack of staff or skills within municipalities as well as the financial limited may slow down the process.  

Provided Support

Technical and organisational	4/5	The Brussels Energy and Environnement Agency (Bruxelles Environnement – BE) organizes regular trainings and informative sessions for municipalities. BE also finances multiple “Facilitators” mandated to help citizens and local authorities in the design and implementation of energy projects (energy communities, EV charging stations, …). The region plans to increase the visibility of the facilitator’s service for the development of heat networks and gradually move towards an integrated “One Stop Shop” service.   The Brussels region still needs to implement a regional multi-level governance to accelerate the deployment of district heating projects.
Financial	2/5	The financial support for the development and implementation of heating plans by municipalities is insufficient and not structural. The distribution of responsibilities between the municipalities and the region, regarding the implementation of art 25, is still being discussed.   For many years, Bruxelles Environnement has supported various stakeholders to support municipalities. Sibelga (DSO) is financially supported by the Brussels Region to support municipalities (technical and financial support). Energy experts in municipalities are also financed by the regional authority but their task is more related to energy efficiency measures than heating policy.   The regional Energy and Climate (2023) plans foresees to, if necessary, structure one or more mechanisms support (support and financing) of renewable heat, including the addition of a bonus for RES heating networks. This measures still need to be implemented. However, there is already a significant shift from gas boilers subsidies to heat pumps and RES heating (air-water, water-water including geothermal energy, riot thermal energy, aquathermal energy, etc.).   RENOLUTION grants are currently unavailable for works with final invoices dated 2025 or 2026. The Region is assessing the financial support it could provide to municipalities preparing local heating and cooling plans. Individual district heating and cooling projects have secured EU funding, but this does not constitute a general funding scheme for municipal LHCPs.
Staff & skills	4/5	The distribution of responsibilities is shared between municipalities and BE. Due to the institutional context of the Brussels-Capital region, Bruxelles Environment staff provides technical information to the municipalities and takes care of regional planning.   The implementation of art 25 will require strong cooperations between the regional and municipal level which will request additional staff. However, municipalities can benefit from the skills and expertise of the Regional Agency. This regional approach answers the need of both small and large municipalities.
Access to data	3/5	The published regional zoned vision and its indicative maps provide additional information on renewable heating options and opportunities for district heating. However, gaps remain in building-level data on heating systems nd energy consumption. The Region is assessing further data support for municipalities preparing local heating and cooling plans   Although the ongoing discussion on the future of gas will impact municipalities’ ability to plan district heating solutions. The collection of data must also contribute to give certainty for project developments. The set of available date needs further developments.