Policy Opinion Submitted on the Draft Regulation of the Energy Efficiency Obligation Scheme

In our view, residential building energy renovations and energy efficiency investments serve key social and economic interests. It is therefore particularly important that the regulatory framework governing these investments genuinely supports the achievement of their objectives, rather than imposing unnecessary administrative and financial burdens on those concerned.

Agreement on the objective – concerns about the chosen instrument

We agree that providing information on available support schemes, financing options, and implementation possibilities plays a crucial role in ensuring the success of energy efficiency programmes, the effective use of available funding, and the full uptake of allocated resources.

At the same time, we have serious concerns regarding the provision of the draft regulation that would make it mandatory for investments implemented under the Energy Efficiency Obligation Scheme (EEOS) to display a commemorative plaque in a clearly visible location on the property.

In our assessment, this instrument in itself is not suitable for providing meaningful, wide-reaching information about energy efficiency opportunities, while it raises a number of practical and legal concerns.

Conflicts with urban design and legal requirements

The mandatory installation of such a publicity board may conflict with other legal provisions and local regulations governing building façades and townscape protection. These include, for example, Government Decree No. 280/2024 (IX. 30.) on the Basic Rules of Spatial Planning and Building Requirements, local spatial development plans, and local building codes.

These rules may render any alteration of a building façade subject to a permit, including the placement of a commemorative plaque. We consider the requirement to conduct such permitting procedures for small-scale residential energy efficiency investments to be unrealistic and disproportionate.

Resources could be better used elsewhere

In our view, the resources spent on the production, installation, and—where applicable—permitting of funding support signs would be better allocated directly to achieving energy efficiency objectives.

More effective uses of these resources could include:

• Tailored energy efficiency advice, helping households identify further measures to improve the energy performance of their buildings beyond the initial EEOS investment;
• Technical inspection of completed investments, contributing to quality assurance and the achievement of actual energy savings.

Comprehensive communication is needed, not signs

Beyond the specific draft regulation, Energiaklub recommends the development of a comprehensive and targeted communication strategy. This should be implemented through a structured campaign involving relevant organisations to inform the public.

Such a campaign would be capable of providing genuinely broad-based information to households about available support and financing—unlike isolated signs, which have minimal practical impact.

Conclusion

According to the position of the Energiaklub Climate Policy Institute, the success of energy efficiency investments depends not on visibility requirements, but on well-targeted professional support and deliberate strategic communication. For this reason, we consider it justified to reconsider the relevant provisions of the draft regulation.

📄 The full text (in Hungarian) of our submitted opinion is available here: Our opinion on the amendment of the regulation governing the implementation of certain provisions of the Energy Efficiency Obligation Scheme (PDF)