Selling or letting a home in Pointe-à-Pitre, Fort-de-France, Cayenne, Saint-Denis or Mamoudzou? Since 1 July 2024, France's Climate and Resilience Act has made the articles of the Building and Housing Code that require an energy performance certificate (EPC, diagnostic de performance énergétique or DPE) at sale, in the lease and in listings applicable in the five overseas departments (Act no. 2021-1104 of 22 August 2021, art. 158, IV). Yet the calculation method set by the State expressly excludes the overseas departments, and only Guadeloupe and Martinique have set up their own diagnosis.
The rule therefore differs by territory, and this article flags what is not established.
⚠️ Article updated in October 2026: earlier versions described a single "overseas" calculation method and class thresholds that no text sets; they also gave 2034 as the non-decency date for class F and a 450 kWh threshold. This version starts again from the texts.
EPC in overseas France: what the Climate Act made applicable on 1 July 2024
Article 158 of Act no. 2021-1104 of 22 August 2021, known as the Climate and Resilience Act, contains a paragraph specific to overseas France, its IV: "In Guadeloupe, Martinique, French Guiana, Réunion and Mayotte, articles L. 126-26 to L. 126-30, L. 126-32 and L. 126-33 of the Building and Housing Code apply from 1 July 2024." The version of this article in force is still that of 25 August 2021.
The articles made applicable in this way form the core of the EPC:
- Content (art. L. 126-26): primary and final energy consumption, greenhouse gas emissions, rating, recommendations and theoretical energy costs;
- Sale (art. L. 126-28): the EPC is given to the buyer with the technical diagnosis file, and kept available to any prospective buyer or tenant;
- Letting (art. L. 126-29): the EPC is attached to the lease when it is signed, except for rural leases and seasonal lets; the tenant cannot rely on the recommendations, "which are for information only";
- Listings (art. L. 126-33): the rating and an indication of theoretical energy costs must appear in sale or rental listings; a breach is punishable by an administrative fine of up to €3,000, raised to €15,000 for a professional legal entity;
- Transmission to ADEME (art. L. 126-32) and display in certain categories of buildings (art. L. 126-30).
The same article also dates two other overseas obligations. For the energy audit on sale of houses and buildings outside condominium ownership, the law brings the obligation into force on 1 July 2024 for F- and G-rated homes and on 1 January 2028 for E-rated homes; no date is set for class D (art. 158, VIII). But the content of the audit is set for mainland France only (order of 4 May 2022), the decree that sets its terms (Decree no. 2022-780) only covers the mainland deadlines, and the rating presupposes an EPC within the meaning of article L. 173-1-1, which raises the same difficulty as the decency timetable (see below). The difference between the two documents is explained in our article energy audit or EPC: which one applies to you. The collective EPC for residential buildings whose building permit was filed before 1 January 2013 takes effect there on 1 January 2028 (art. 158, IX).
Why the national EPC method does not apply overseas
An EPC only exists through its calculation method. In mainland France, it is set by two orders of 31 March 2021: one on the diagnosis of residential buildings "in mainland France" (that is its title), the other on the applicable methods and procedures (the 3CL-DPE 2021 method). Their article 1, worded identically, applies them "with the exception of the overseas departments". No order setting a method of its own for the overseas departments has been found in the texts consulted.
A direct consequence: the electricity-to-primary-energy conversion factor — 1.9 since 1 January 2026 (order of 13 August 2025), 1.7 from 1 January 2027 (order of 19 August 2026) — sits in annex 3 of the order on homes in mainland France. It applies to mainland France only, as explained in our article electricity conversion factor: is my home affected.
The overseas thermal regulation (RTAA DOM, three orders of 17 April 2009) covers new residential buildings; in 2013, Martinique's deliberation noted that it provided no "operational transposition of the certification component".
A postponement announced in 2023, not written into law to date
The interministerial committee for overseas France of 18 July 2023 announced an extension of the timetable for the binding EPC to 2028 (2030 in Mayotte), presented as necessary to adapt it to each climatic environment. That announcement has not been taken up in the texts: the version of article 158 in force is still that of 25 August 2021, and Act no. 2025-797 of 11 August 2025 on the rebuilding of Mayotte does not deal with the EPC.
EPC in overseas France, territory by territory: where the diagnosis really exists
| Territory | Text | Diagnosis and method | Still to be established |
|---|---|---|---|
| Guadeloupe (971, except 97133 and 97150) | Act no. 2021-1104, art. 158, IV; regional council deliberation no. CR/19-1156 of 31 October 2019 | DPEG, compulsory at sale and letting since 1 June 2020 for existing homes with at least one air-conditioned bedroom; calculated on the RTG/DPEG platform; electricity factor: 3.5 | The diagnosis of a home with no air-conditioned bedroom |
| Martinique (972) | Act no. 2021-1104, art. 158, IV; regional council deliberation no. 13-1219-1 of 28 June 2013 | DPE-M, to be produced at any sale or letting (deliberation in force since 1 September 2013) for existing homes with at least one air-conditioned bedroom; thresholds and factors set in annexes to the deliberation | The electricity factor (annex 7, not read); the diagnosis of a home with no air-conditioned bedroom |
| French Guiana (973) | Act no. 2021-1104, art. 158, IV | No method found in the texts consulted | What actually applies |
| Réunion (974) | Act no. 2021-1104, art. 158, IV | No method found in the texts consulted | What actually applies |
| Mayotte (976) | Act no. 2021-1104, art. 158, IV | No method found in the texts consulted | What actually applies |
| Saint-Martin (97150) | French local authorities code (CGCT), art. LO 6314-3 | Rules set by the collectivity | The local rules (not read here) |
| Saint-Barthélemy (97133) | CGCT, art. LO 6214-3 | Rules set by the collectivity | The local rules (not read here) |
| Saint-Pierre and Miquelon (975) | CGCT, art. LO 6414-1 | Rules set by the collectivity | The local rules (not read here) |
Guadeloupe and Martinique: a diagnosis set up by the region
Empowered at the time in energy matters (article 73 of the Constitution), both regions created their own diagnosis. In Guadeloupe, the regional council deliberation of 31 October 2019, published in the Journal officiel of 8 April 2020, sets up the DPEG; its provisions take effect on 1 June 2020 (art. 30). For existing homes, it covers those "with at least one bedroom equipped with an air-conditioning system" (art. 3): their owner must have a DPEG drawn up in the event of a sale or letting (art. 8), show its label in listings and hand it to the new tenant or buyer before signature (art. 25). The certificate for an existing home is valid for ten years (art. 27).
The DPEG is not calculated like the national EPC. Its conventional consumption is simulated on the Region's RTG/DPEG calculation platform (art. 14); its label rates an indicator expressed in final energy, from A (15 kWh/m²/year or less) to G (more than 90 kWh/m²/year) for residential buildings (annex 3); and primary energy is derived from it with a factor of 3.5 ("Ep = 3.5 × E", art. 21). A DPEG rating is therefore not comparable with a mainland EPC rating.
In Martinique, deliberation no. 13-1219-1 of 28 June 2013, published in the Journal officiel of 31 August 2013 and in force the following day (art. 26), sets up the DPE-M on the same model: existing homes with at least one air-conditioned bedroom (art. 3), a certificate produced "at any property transaction by way of sale or letting" (art. 8), the indicator shown in listings (art. 21). Its label thresholds and conversion factors are set in annexes (3, 4 and 7) that are not reproduced in the version published online. According to the impact assessment of the Martinique enabling bill (January 2026), the DPE-M and Martinique's thermal regulation "remain applicable" but have not been updated since 2013.
Key takeaway: in these two regions, an existing home with no air-conditioned bedroom falls outside both the DPEG and the DPE-M, and the national method does not apply there: no text we read says which diagnosis it should have.
French Guiana, Réunion, Mayotte: the law without the method
No diagnosis specific to these three collectivities and no national order setting a method for them has been found in the texts consulted. ANIL, the national housing information agency, notes in its legal analysis of the EPC, up to date as of 29 August 2025, that "an EPC framework currently only exists in Guadeloupe" and in Martinique, and writes that the EPC measures "are applicable in Guadeloupe and Martinique since 1 July 2024", but that "they are not in French Guiana, Réunion and Mayotte". ANIL does not state its grounds; the law, for its part, declares these articles applicable. What actually applies there is not established.
ADEME's national database bears the trace of this. As of 25 October 2026, out of 15.85 million EPCs for existing homes drawn up since July 2021, 32 carry an entered postcode beginning with 97, of which at least 8 actually describe a home in mainland France. The others — 14 in Réunion, 5 in Guadeloupe, 3 in French Guiana, 1 in Martinique, none in Mayotte, plus one doubtful case — were drawn up in the national format; the text on which they rest overseas is not established.
Saint-Martin, Saint-Barthélemy, Saint-Pierre and Miquelon: collectivities with their own powers
These three collectivities are not overseas departments, and article 158 of the Climate Act does not name them. The French local authorities code gives them the rules on "urbanisme ; construction ; habitation ; logement" (urban planning, construction, housing and accommodation) (art. LO 6214-3 for Saint-Barthélemy, LO 6314-3 for Saint-Martin, LO 6414-1 for Saint-Pierre and Miquelon). The rules they have adopted on energy diagnosis have not been read here. Saint-Pierre and Miquelon, in particular, does not fall under the mainland method merely because of its climate.
French Polynesia, New Caledonia and Wallis and Futuna, governed by specific statutes (Constitution, article 74 and title XIII), are outside the scope of this article: their rules have not been read here.
Energy decency and rent freeze: an overseas timetable of its own
The energy-decency timetable, by contrast, names the five departments expressly. Article 6 of Act no. 89-462 of 6 July 1989, as worded by article 160 of the Climate Act, and article 3 bis of Decree no. 2002-120 of 30 January 2002, as worded by Decree no. 2023-796 of 18 August 2023, set the minimum performance level of a decent home:
| Home considered non-decent | Mainland France | Guadeloupe, Martinique, French Guiana, Réunion, Mayotte |
|---|---|---|
| G-rated | 1 January 2025 | 1 January 2028 |
| F-rated | 1 January 2028 | 1 January 2031 |
| E-rated | 1 January 2034 | No deadline set |
These texts, which target no category of lease, do not name Saint-Martin, Saint-Barthélemy or Saint-Pierre and Miquelon, where neither timetable can be assumed to apply. The thresholds of the national EPC classes A to G are set out in our 2026 EPC label guide.
The rent freeze for F- and G-rated homes — no annual revision, no increase on renewal, no increase between two tenants — applies overseas to leases concluded, renewed or tacitly renewed after 1 July 2024 (Act no. 2021-1104, art. 159, IV), against 24 August 2022 in mainland France.
What to check on your EPC: these deadlines refer to the classes "within the meaning of article L. 173-1-1" of the Building and Housing Code, those of the national EPC. The texts we read do not say how a DPEG or a DPE-M, whose labels rest on other indicators, fits with them; and where no diagnosis exists, ANIL notes that "it is possible to wonder" about the conditions under which these measures take effect.
⚠️ One to watch: the bill on the relaunch and decentralisation of housing, adopted by the Senate on 8 July 2026 and sent to the National Assembly, aims among other things to clarify the energy-compliance obligations of homes put up for rent (Senate summary). Until it is finally adopted and published, the deadlines above are those of the law in force. For the details of the text and its passage through Parliament, see our analysis updated on 25 October 2026.
Grants and VAT: rules of their own overseas
Overseas owners have access to the national schemes (starting with MaPrimeRénov' and its new 2026 rules), with rules of their own overseas:
- MaPrimeRénov' is open there through the single-action route only: full-scale renovation is reserved to mainland France (Decree no. 2020-26 of 14 January 2020, art. 2, I, 1°). For applications filed since 1 September 2026, the single-action route funds only the items listed in annex 1 of Decree no. 2020-26, as rewritten by Decree no. 2026-822 of 25 August 2026: insulation, ventilation and air conditioning are not on it. Overseas, the list keeps, with amounts of their own, solar water heating, protection of glazed or opaque walls against solar radiation, ventilated over-roofs and ventilated cladding. We did not find a general 20% overseas increase of the amounts in the texts we read (Decree no. 2020-26 and the order of 14 January 2020).
- VAT: a reduced 2.1% rate in Guadeloupe, Martinique and Réunion for energy renovation works (French General Tax Code, art. 296, until 31 December 2026; French Code of Taxes on Goods and Services, art. L. 213-151, from 1 January 2027). In French Guiana and Mayotte, VAT does not apply for the time being until 31 December 2026 (French General Tax Code, art. 294), and from 1 January 2027 these two territories are not taxation territories (French Code of Taxes on Goods and Services, art. L. 211-7).
What it amounts to: on €25,000 of works before tax that would fall under the 5.5% rate in mainland France, the 2.1% rate applicable in Guadeloupe, Martinique and Réunion makes a difference of 3.4 points, i.e. €850 (€25,000 × 3.4%). This advantage is already included in the price invoiced including tax: it is not a grant paid out, and it does not add to the grants.
Check an EPC against your territory's timetable
The OneDpe EPC checker reads an EPC recorded in ADEME's national database and applies the decency timetable of the territory of its postcode: 1 January 2028 for a G-rated home and 1 January 2031 for an F-rated home in the five overseas departments, no date asserted in Saint-Martin, Saint-Barthélemy or Saint-Pierre and Miquelon. In the eight collectivities listed, it applies no electricity conversion factor. A DPEG or a DPE-M is not in that database.
EPC in overseas France: mistakes to avoid
Believing that a single "overseas" EPC method exists
No national method of its own for the overseas departments has been found in the texts consulted. There are two regional diagnoses, the DPEG and the DPE-M, which for existing homes cover only those with at least one air-conditioned bedroom; no method has been found for French Guiana, Réunion or Mayotte.
Looking for a 450 kWh threshold
The 450 kWh/m²/year final-energy threshold was a decency criterion for mainland France only, for leases signed from 1 January 2023 (Decree no. 2021-19 of 11 January 2021); it was replaced by classes on 1 January 2025. Overseas, decency is assessed by class, at the 2028 and 2031 deadlines.
In short, the law set 1 July 2024 for the EPC to arrive in the five overseas departments, while the national method excludes them. Only Guadeloupe and Martinique have a diagnosis, limited to air-conditioned homes; the 2028 and 2031 decency deadlines, by contrast, are written into the law. To read a national-format EPC, use the OneDpe EPC checker.
