French EPC and mandatory energy audit: which certification lets you do what

Three documents deal with the energy performance of a French dwelling: the DPE (diagnostic de performance energetique, the energy performance certificate), the mandatory energy audit required when selling certain energy-inefficient properties, and the energy audit that unlocks subsidies for a deep retrofit. Three missions, three competence frameworks, three lists of authorised operators — which only partly overlap. A professional certified for one is not entitled to the other two, and the mistake is costly: a mission rejected by the notary, a subsidy application turned down, liability exposed.

The table to keep in mind

	DPE (EPC)	Mandatory energy audit (sale)	Subsidy-linked energy audit
Trigger	Sale, letting, new build, multi-dwelling residential building	Sale of a single-family house or of a single-owner residential building rated E, F or G	Funded deep retrofit project
Legal basis	Articles L. 126-26 et seq. of the construction and housing code	Article L. 126-28-1 of the same code, decree no. 2022-780 of 4 May 2022	Framework of public energy retrofit subsidies
Who may do it	Certified surveyor, without or with mention depending on the building	Closed list: professional holding a quality mark, trained registered architect, and — single-family houses only — a certified DPE surveyor meeting the required competences	Professional qualified under RGE etudes, referenced architect, company certified for a global offer
Competence framework	Personal certification, body accredited by Cofrac	Depending on the route: company qualification, registration with the architects’ board, or extension of the DPE certification	Company qualification recognised as RGE
Validity of the document	10 years	5 years	Depends on the subsidy scheme

The tipping point is easy to remember: the DPE rests on a personal certification, the audit rests overwhelmingly on a company qualification — with one narrow door open to surveyors, and only for single-family houses.

The DPE: a two-tier personal certification

The DPE is issued by a surveyor certified by a body itself accredited by Cofrac, the French accreditation committee. Since 1 July 2021 it is legally binding: no longer a purely informative document, except for the works recommendations, which remain advisory. It is valid for ten years.

Without mention or with mention: what changes

The order of 20 July 2023, applicable since 1 July 2024, split the DPE certification into two levels — a text separate from the one covering the five other domains of the profession, as set out in our overview of the six certification domains of the French property surveyor.

• Without mention: single-family homes and residential units.
• With mention: in addition, multi-dwelling residential buildings, buildings mainly used for purposes other than housing, non-residential units within those buildings, and dwelling-level EPCs generated from whole-building data.

The distinction is anything but anecdotal in 2026. The whole-building EPC has become compulsory in stages for multi-dwelling residential buildings whose planning permission was filed before 1 January 2013: 1 January 2024 for single-owner buildings and condominiums of more than 200 lots, 1 January 2025 for those between 50 and 200 lots, and 1 January 2026 for condominiums of at most 50 lots. In other words, the pool of missions opening this year — small condominiums, by far the most numerous — is reserved entirely for surveyors certified with mention.

The logic mirrors asbestos and lead, where the mention unlocks pre-works surveys: see our article on certification with mention.

The cycle: training, examinations, surveillance

Access requires prior training, a theoretical examination in questionnaire form and a practical examination on a real building. Certification is granted for seven years, with documentary and on-site checks during the cycle, continuing training, then a recertification examination at expiry: see our article on surveillance and seven-year recertification.

The mandatory energy audit: a closed list of operators

Created by the Climate and Resilience Act of 22 August 2021, the mandatory energy audit applies to the sale of the least efficient dwellings: classes F and G since 1 April 2023, class E since 1 January 2025, class D from 1 January 2034. It covers single-family houses and residential buildings belonging to one and the same owner — not the sale of an individual lot in a condominium.

Its content is regulated: a general survey, a performance estimate, staged works proposals with cost estimates and available subsidies. Since April 2024, the first stage of the works pathway must deliver a gain of at least two classes and address two insulation elements, with class B remaining the ultimate target where achievable. The audit is valid for five years, requires at least one on-site visit and may not be subcontracted.

Who may carry it out, depending on the building

Decree no. 2022-780 of 4 May 2022 draws a distinction between two cases. This is where most professionals get it wrong.

Multi-dwelling residential building owned by a single owner: professionals holding a quality mark covering the energy audit of collective buildings — typically a design-office qualification recognised under RGE etudes — or firms of architects and architects registered with the board who have completed the required training. Property surveyors are not on that list.

Single-family house: the same routes, plus a third one — persons certified to produce DPEs who meet the necessary competences for carrying out the audit.

Three requirements apply in every case: no link liable to compromise the auditor’s impartiality and independence towards the owner or their agent, professional liability insurance covering that activity, and at least one visit of the property.

The surveyor’s certification extension

Those “necessary competences” are not a vague formula: they are defined by decree no. 2023-1219 of 20 December 2023, applicable since 1 July 2024. The scheme takes the form of an extension of the DPE certification, under precise conditions.

• Prerequisite: holding a valid DPE certification for at least two years within the previous three years.
• Prior training: a minimum of 70 hours, at least half of it practical, including a compulsory share of fieldwork in real or purpose-built premises.
• Assessment: a theoretical multiple-choice examination and a practical examination in a real situation.
• Upkeep: annual continuing training plus documentary and on-site checks aligned with the DPE certification cycle.

The transitional regime, which allowed earlier attestations to be relied upon, ended on 30 April 2025. In 2026 there is therefore no shortcut left: without that extension, a surveyor cannot sign a mandatory audit, not even on a single-family house.

The subsidy-linked audit: RGE etudes territory

The third case, often confused with the second: the audit that unlocks deep-retrofit subsidies. It is triggered not by a sale but by a funded works project, with compulsory support for the household and a required gain in energy classes. Here the operators fall within the RGE etudes field — qualified design offices, referenced architects, companies certified for a global offer.

For a design office, everything hinges on the exact scope of the qualification: our comparison of OPQIBI 1905 and 1911 draws the boundary between collective housing and commercial buildings on one side and single-family houses on the other, and our article on RGE etudes explains what the recognition changes. The scheme as a whole is on our OPQIBI qualification page.

What research says about the reliability of these documents

The severity of the certification framework is explained by a measured problem: the gap between the theoretical label and actual consumption.

The study by Stefano Cozza, Jonathan Chambers, Chirag Deb, Jean-Louis Scartezzini, Arno Schlüter and Martin K. Patel, “Do energy performance certificates allow reliable predictions of actual energy consumption and savings? Learning from the Swiss national database” (Energy and Buildings, 2020), draws on the Swiss national database of energy certificates and shows a performance gap that varies strongly with the label: the worst-rated buildings consume markedly less than theory predicts, while the best-rated ones consume slightly more (see the study). The consequence for an auditor: a works scenario calibrated on conventional consumption alone exposes the client to disappointment, and the professional to a dispute.

The economic stake is documented by Franz Fuerst, Patrick McAllister, Anupam Nanda and Peter Wyatt in “Does energy efficiency matter to home-buyers? An investigation of EPC ratings and transaction prices in England” (Energy Economics, 2015), based on 333,095 dwellings sold at least twice between 1995 and 2012: better-rated dwellings sell at a measurable price premium, with wide variation across regions and property types (see the study). A label is not a formality: it feeds into the price.

What is changing in 2026

The electricity conversion coefficient falls from 2.3 to 1.9 in the DPE calculation as of 1 January 2026, under an order published in the Official Journal of 26 August 2025. No dwelling sees its label downgraded as a result; earlier DPEs remain valid and can be updated without a new visit through the Ademe DPE-Audit observatory. Further reliability measures have been announced: before turning one into a training module, check the text in force with your certification body.

What it means for training providers

Training these professionals means operating on three distinct markets: the training preceding DPE certification, the 70-hour training that opens the audit extension, and the training of technical officers on the RGE side. Each has its own framework and funding channels — our overview of approved RGE training maps the retrofit side, and our guide on training property surveyors sets out the constraints specific to that audience.

Take action

Take your last three rejected or disputed missions and ask a single question: did the credential you relied on cover exactly the building and the document requested? If you are targeting the sale audit on single-family houses, check first how long you have held your DPE certification, then start the training; if you are targeting condominiums, the mention is what you need to go after. Our Property surveyor certification page sets out the scheme domain by domain.