You are selling an F-rated house: the estate agent asks for a DPE (Diagnostic de Performance Énergétique — the French Energy Performance Certificate, or EPC), the notaire asks for an energy audit, and you cannot see why the same home needs two assessments. Many sellers still believe the audit replaces the EPC, or that it remains optional. Both are wrong: the statutory energy audit is added to the EPC, and it is the EPC rating itself that triggers the audit obligation.
Since 1 January 2025 this obligation no longer targets only thermal sieves (passoires thermiques): it extends to E-rated homes. According to SDES, the ministry's statistical service (12 November 2025), class E accounts for 17.8% of France's 30.9 million main homes — more than classes F and G combined (12.7%).
A statutory energy audit is priced between €800 and €1,500, against €100 to €250 for an EPC — observed market prices, as no official price scale exists. It is not "a more expensive EPC": it is a different document, costing out two complete renovation pathways.
What this article covers
The exact timetable of the energy audit required on sale (F and G since 2023, E since 2025, D in 2034), which properties are in scope and which are excluded, what the audit contains beyond the EPC since the reform of 29 December 2023, a "who owes what" decision table, the effect of the 2026 mainland France coefficient (1.9) on your obligation, and the six misconceptions that cost sellers the most.
Energy audit obligation on a French sale: the 2023-2034 timetable
The obligation stems from article 158 of Act No. 2021-1104 of 22 August 2021, the Climate & Resilience Act, which created article L. 126-28-1 of the CCH: the seller of an energy-inefficient home hands the buyer an energy audit, on top of the EPC. The timetable is set by article 3 of decree No. 2022-780 of 4 May 2022, after a little-known postponement — classes F and G were due to be covered from 1 September 2022, but decree No. 2022-1143 of 9 August 2022 replaced that date with 1 April 2023.
| Rating | Mainland France | Guadeloupe, Martinique, French Guiana, Réunion, Mayotte | Reference |
|---|---|---|---|
| F and G | 1 April 2023 | 1 July 2024 | decree No. 2022-780, art. 3 |
| E | 1 January 2025 | announced for 1 January 2028 | decree No. 2022-780, art. 3 |
| D | 1 January 2034 | — | decree No. 2022-780, art. 3 |
| A, B, C | not covered | not covered | art. L. 126-28-1 of the CCH |
The 2028 overseas deadline for class E is set out in the law itself: art. 158 VIII of Act No. 2021-1104 of 22 August 2021 postpones the class E obligation to 1 January 2028 in Guadeloupe, Martinique, French Guiana, Réunion and Mayotte. On the other timetable hitting class E, see the 2034 rental ban on E-rated homes.
Which properties are actually covered?
Article L. 126-28-1 of the CCH covers buildings "used as dwellings comprising a single dwelling or several dwellings not subject to the commonhold regime" defined by Act No. 65-557 of 10 July 1965: the single-family house — a maison individuelle in the French sense, whether it stands alone, is semi-detached or sits in a terrace, since the statute counts dwellings and not walls — and the whole building sold in one go by a single owner. The consequence, often missed: the sale of a commonhold lot is never subject to the audit, even if G-rated.
On what date is the obligation assessed?
The trigger is assessed at the date of the preliminary sale agreement (art. 1589 of the Civil Code) or, failing that, of the deed of sale (art. 1582 of the Civil Code). The audit must therefore be available before the preliminary contract is signed, like the rest of the technical survey file: discovering it the day before the compromis pushes completion back by several weeks.
⚠️ Warning: the statutory energy audit attaches to a sale, and to nothing else. No text requires it for a letting: renting falls under a separate regime, the energy decency thresholds.
What the audit contains beyond the EPC
The EPC and the audit run on the same calculation engine, the 3CL-DPE 2021 methodology, and produce the same A-to-G scale. The similarity ends there: one describes a state, the other maps out a route.
The EPC: a legally binding snapshot
The EPC describes the home's performance at a given moment: primary-energy consumption, greenhouse-gas emissions, the twin labels, and indicative renovation recommendations. It has been legally binding since 1 July 2021 (art. L. 271-4 of the CCH) and is valid for ten years (art. D. 126-19 of the CCH). To decode yours section by section: how to read an EPC page by page.
The audit: two fully costed renovation pathways
The audit's content is set not by the decree but by an order of 4 May 2022 (NOR LOGL2115138A), amended by the orders of 9 August 2022 and 29 December 2023 — the latter version applying since 1 April 2024. Its article 2 requires at least two renovation proposals:
- a staged pathway, whose first step must deliver a gain of at least two classes and treat two insulation items;
- a single-step pathway, reaching the final target directly.
The final step of each pathway must achieve a "high-performance renovation" within the meaning of 17° bis of article L. 111-1 of the CCH: class A or B as a rule, once the six standard work items have been studied. That same 17° bis carries an exception that matters here — a home rated F or G before the works qualifies from class C onwards.
A requirement raised in 2024: until 31 March 2024, the first step only had to gain one class and reach class E. Many online sources still quote that outdated version, or a "class C in a single step" target that no longer exists.
Article 3 of the order allows derogations where technical, architectural or heritage constraints stand in the way, or where the cost of the works would be manifestly disproportionate to the value of the property (art. R. 112-18 of the CCH). The targets are then lowered: class C for a home initially rated E, class D for an F, class E for a G.
Each step is costed: primary and final energy consumption, greenhouse-gas emissions, EPC rating after works, prices including VAT, estimated savings, available grants, and ventilation warnings. The audit is then filed with ADEME's DPE-Audit Observatory (PDF and XML files).
Who can carry out a statutory energy audit?
Article 1 of decree No. 2022-780 restricts the work to three families of professionals: firms holding a quality mark within the meaning of the order of 30 May 2018 (OPQIBI 1905 and 1911, Qualibat 8731, or the RGE "offre globale" label — RGE for Reconnu Garant de l'Environnement, the French label for qualified renovation firms); architects on the Ordre register who have completed dedicated training; and certified EPC assessors whose additional skills have been verified by their certification body. Impartiality, professional indemnity insurance and a ban on subcontracting also apply. At least one site visit is mandatory: a desk-based audit is irregular.
| Criterion | EPC | Statutory energy audit |
|---|---|---|
| Trigger | Sale and letting | Sale only, by rating and property type |
| Legal basis | art. L. 271-4 of the CCH | art. L. 126-28-1 of the CCH |
| Content | Energy and climate labels, indicative recommendations | Two costed pathways, prices incl. VAT, available grants |
| Validity | 10 years | 5 years |
| Author | Certified assessor | Qualified firm, trained architect or authorised assessor |
| Observed price | €100 to €250 | €800 to €1,500 |
Who owes what in 2026: the decision table
The rule fits in one sentence: the EPC is always due, the audit only where three conditions are met — a sale, a property outside commonhold, a rating reached by the timetable.
| Situation | EPC | Statutory energy audit |
|---|---|---|
| Sale of a single-family house rated A, B or C | Mandatory | Not covered |
| Sale of a single-family house rated D | Mandatory | No, before 2034 |
| Sale of a single-family house rated E | Mandatory | Yes, since 2025 |
| Sale of a single-family house rated F or G | Mandatory | Yes, since 2023 |
| Sale of a whole building outside commonhold rated E, F or G | Mandatory | Yes |
| Sale of a commonhold lot, any rating | Mandatory | Not covered |
| Letting, any rating | Mandatory | Not covered |
Cost: two documents that cannot be compared
Neither ADEME nor the ministry publishes a price scale: prices are free. The ranges collected from comparison sites and survey firms put the EPC between €100 and €250, and the audit between €800 and €1,500 — observed market prices, not official data, varying with floor area and region.
Worked case: you are selling a 110 sqm detached house that has never been renovated. Here is the energy section of your sale file depending on whether the EPC rates it D or F.
| Energy section item | House rated D | House rated F |
|---|---|---|
| EPC (due in both cases) | €100 to €250 | €100 to €250 |
| Statutory energy audit | Not required before 2034 | €800 to €1,500 |
| Validity of the documents | 10 years | 10 years (EPC) and 5 years (audit) |
| Cost of the energy section | €100 to €250 | €900 to €1,750 |
| Extra cost driven by the rating | + €800 to €1,500 | |
The extra cost is not a disguised tax: it buys a different deliverable. Where the EPC tells you where you stand, the audit hands over two complete routes to class A or B — a document the buyer will use to price their offer, and you to defend yours.
The MaPrimeRénov' audit: same word, different scheme
A second confusion: the statutory audit on sale is not the incentive audit funded by MaPrimeRénov'. According to the official service-public.gouv.fr factsheet F35083 (verified on 19 June 2026), it is optional in the single-measure pathway, with a flat grant of €500 (blue profile, very low income), €400 (yellow, low income) or €300 (purple, middle income), capped at €800, the pink profile being excluded; the grant is paid once per dwelling and requires at least one renovation measure. In the supported pathway, known as whole-house renovation, it becomes mandatory before and after the works, for a home rated E, F or G and at least fifteen years old. The scheme reopened on 23 February 2026, and wall insulation and biomass boilers have not been funded since January 2026.
The 2026 trap: in mainland France, the 1.9 coefficient may take you out of scope
The order of 13 August 2025 lowered the primary-energy conversion coefficient for electricity from 2.3 to 1.9 for certificates issued in mainland France from 1 January 2026. That coefficient is the multiplier applied to electricity consumption in the 3CL-DPE method: lowering it mechanically improves the rating of electrically heated homes. The new value applies to "all EPCs or energy audits issued from that date", and "no home will see its label fall".
The impact is massive: the ministry estimates that around 850,000 homes leave classes F and G, out of the 4.8 million recorded on 1 January 2023, while the SDES simulation points to nearly 700,000 further homes leaving thermal-sieve status, taking the national rate from 12.7% to 10.4%. A home rated E that becomes D falls out of the audit's scope, class D being covered only in 2034.
The rating still has to be updated. EPCs issued before 2026 remain valid for ten years with their old label; the recalculation at the 2026 coefficient of 1.9, specific to mainland France, goes through a certificate downloadable free of charge from ADEME's DPE-Audit Observatory, with no new visit and for the same validity period. If you hold a 2024 E-rated EPC and do nothing, you remain subject to the audit. To choose between the free certificate and a new assessment: should you redo your EPC in 2026 or wait until 2027?
What to check before listing: the exact rating on your EPC and its issue date. If it predates 1 January 2026 and the home is electrically heated, download the ADEME certificate before ordering an audit: the recalculated label may exempt you. The ministry's FAQ confirms the certificate is valid for a sale, without settling the E-to-D reclassification point — one to confirm with your notaire.
The six misconceptions that cost sellers the most
Misconception 1 — "The audit replaces the EPC"
The two documents are cumulative. The EPC remains due as part of the technical survey file (art. L. 271-4 of the CCH), and the audit is added according to the rating and the type of property. Without an EPC there is in fact no trigger: the label is what determines the obligation.
Misconception 2 — "My flat is F-rated, so I need an audit"
Article L. 126-28-1 of the CCH excludes homes subject to the commonhold regime: an F- or G-rated lot is sold without an audit. Commonholds fall under building-level schemes of their own — the collective EPC (art. L. 126-31 of the CCH) and the multi-year works plan (art. 14-2 of the Act of 10 July 1965).
Misconception 3 — "You need an audit to let a thermal sieve"
The obligation attaches exclusively to a sale. A landlord letting an F-rated home has no audit to produce: they fall under the energy decency thresholds, which follow their own timetable.
Misconception 4 — "Without an audit the sale is void and I will be fined"
No specific criminal or administrative penalty is provided for. The consequences fall under general law: fraudulent concealment and vitiated consent (art. 1112-1 and 1137 of the Civil Code), contractual liability, damages for the lost chance to negotiate the price, the notaire's duty to advise — and completion being blocked while the document is missing. On 17 October 2024 the Cour de cassation held (3rd civil chamber, No. 22-22.882) that an erroneous EPC is merely informative, but that the assessor's breach opens compensation on that basis. See also the legally binding EPC and its legal consequences.
⚠️ Warning: announcing an "automatic cancellation of the sale" where the audit is missing is legally inaccurate. The risk is no smaller: a price-reduction claim based on the lost chance to negotiate remains open under general civil law, and completion stays blocked while the document is missing.
Misconception 5 — "I have to carry out the works the audit recommends"
The audit is an information document handed to the buyer. No text obliges the seller to carry out the scenarios proposed: they inform the buyer's decision — and, very often, feed the negotiation. All the more reason to have modelled your own beforehand.
Misconception 6 — "The audit lasts ten years, like the EPC"
The audit lasts five years, the auditor having to keep it available to successive owners over that period (decree No. 2022-780, art. 2). The EPC lasts ten years (art. D. 126-19 of the CCH). A 2023 audit expires in 2028 while the EPC stays valid until 2033: see the ten-year EPC validity rule in 2026.
Cost out your renovation scenarios before ordering the audit
OneDpe renovation works simulator
From your EPC's ADEME number, the tool rebuilds the building fabric and costs out renovation packages: expected class gain, consumption and emissions after works, estimated cost item by item, and available grants. You reach the auditor with orders of magnitude, instead of discovering the scenarios mid-sale.
Going further: the EPC check, to confirm the rating that triggers the audit obligation, and the EPC simulation, to estimate a class before any assessment.
Conclusion
The question is never "audit or EPC", but "EPC alone, or EPC and audit". The EPC is due on every sale and every letting; the audit is added only for sales of single-family houses — detached, semi-detached or terraced alike — and of buildings outside commonhold rated E, F or G, under a timetable that will reach class D in 2034. Since 1 April 2024 its two pathways target class A or B.
Three reflexes before listing: check the date and rating on your EPC, test, if the property is in mainland France, the effect of the 2026 coefficient of 1.9 through ADEME's free certificate, then cost out your own scenarios. The OneDpe renovation works simulator estimates the class gain, the cost and the grants for each renovation package — enough to read your auditor's report against a benchmark, and to defend your price against a buyer who will use it to negotiate.
