Flanders' top 15% benchmark has changed. What does it mean for real estate investors?

When VEKA published its first benchmark, based on approximately 12,400 EPC NR certificates filed in 2023 and 2024, the top 15% threshold stood at 267 kWh/m²/year across all building functions and 206 kWh/m²/year for offices. Fast forward to June 2026. The database has nearly tripled to 36,389 registered EPC NRs. One might expect a larger and more representative sample to confirm or even strengthen the benchmark. Instead, the thresholds have moved upwards, reaching 274 kWh/m²/year across all functions and 210 kWh/m²/year for office buildings.

The explanation is simple. The top-performing buildings have not become less efficient. Rather, thousands of lower-performing buildings have entered the database as owners progressively complied with EPC obligations. This shifts the overall distribution upwards, resulting in a higher energy consumption threshold for the top 15%. The paradox is striking: qualifying for the EU Taxonomy in Flanders is becoming easier, not because buildings are improving, but because the average building entering the database performs worse. Rather than signalling progress, the new benchmark highlights how much of the Flemish commercial building stock still requires significant energy improvements.

At Pulse, we help investors and asset managers understand where their assets stand today and identify the interventions that create the greatest long-term value while balancing CAPEX, energy performance, regulatory resilience and market attractiveness. Our multidisciplinary approach combines technical expertise, financial analysis and ESG insights to build pragmatic revalorisation roadmaps that protect asset value while preparing portfolios for tomorrow's market.