Italy risks ending up before the Court of Justice of the European Union because it has not yet presented the National Building Renovation Plan, the document with which it must explain to Brussels how it intends to apply the “Green Homes” directive: which buildings to redevelop, with which measures, how many investments and with which resources. The deadline was December 31, 2025.
On 1 October 2026, the European Commission therefore advanced the infringement procedure opened in March and sent Italy a reasoned opinion. Rome now has two months to present the plan and comply. Afterwards, the case may end up before the Court of Justice of the European Union.
The European Commission says so directly in the infringement package of 1 October. The missing document is the first proposal of the National Building Renovation Plan, one of the instruments provided for by the European directive on the energy performance of buildings, the EPBD which in the Italian debate has become simply the “Green Homes Directive”.
Inside there must be a photograph of the Italian real estate assets, the objectives for 2030, 2040 and 2050, the envisaged policies, the necessary investments and the sources of financing. The proposal must also be preceded by a national public consultation. In short, the plan serves to put on paper how Italy plans to accompany public and private buildings towards lower consumption and a decarbonised heritage by 2050. The scheme and calendar are indicated by the Commission on the page dedicated to national restructuring plans.
From 19 countries that were behind schedule, nine remained
In March Italy was much less alone. The Commission had opened the same procedure against 19 Member States who had missed the 31 December deadline, including France, Germany, Sweden, the Netherlands and Portugal, as shown in the infringement package published in March.
In the meantime, many have delivered. France submitted its plan in April, Germany in May; those from Portugal and Sweden also arrived. As of 1 October, Belgium, the Czech Republic, Ireland, Italy, Luxembourg, Hungary, Malta, Poland and Slovakia remain in the group. Nine out of nineteen. For them, Brussels has moved from the letter of formal notice to the reasoned opinion.
Meanwhile, another deadline is approaching. The proposal also served to give the Commission time to examine it and make any recommendations. The definitive version of the plan must be presented by 31 December 2026, as established by European Directive 2024/1275.
Italy therefore arrives in October without having yet delivered the draft that should have opened the discussion with Brussels. The final plan, however, is expected in three months.
What the Green Homes Directive really provides
Here it is important to immediately remove one of the misunderstandings that have accompanied the EPBD since its approval. For homes, the directive does not automatically assign each Italian home an energy class to be achieved by 2030.
The rule concerns the average primary energy consumption of the entire national residential stock: it must decrease by at least 16% compared to 2020 by 2030 and by 20-22% by 2035. At least 55% of this reduction must come from interventions on the 43% of residential buildings with the worst performance. It is the States who decide on the tools, interventions and concrete trajectory, within the margins set by the EPBD.
And it is precisely here that the Italian plan becomes necessary: it must explain which buildings, which measures, how many investments and which resources will allow to achieve those results. Without that document, the European objectives remain there, while the Italian road to achieving them is still to be delivered.
A fine will not automatically arise in two months
The two months indicated by Brussels must be read for what they are. A fine does not start on the sixty-first day. If Italy does not respond satisfactorily and does not submit the plan, the Commission may decide to refer the case to the Court of Justice of the European Union. For this specific procedure, the press release of October 1st indicates the possible passage before the Court and not an automatic financial penalty at the end of the two months.
Possible economic sanctions would require further steps of the European procedure. The mechanism is explained by the Commission in the guide to infringement procedures. So talking today about “incoming sanctions” shortens the road a lot. The immediate risk is another: referral to the EU Court if Italy continues to be without a plan within two months.
And there is also another procedure on green houses
To complicate the picture there is a second file, distinct from this one. On 15 July, the Commission opened proceedings against all 27 Member States for failing to fully transpose the EPBD into national law by 29 May 2026, as the European Commission explains.
That concerns the implementation of the new European rules. The procedure brought forward on 1 October against Italy and eight other countries concerns something much more precise: the failure to deliver the proposed National Restructuring Plan. The dates do almost all the work here. The proposal was supposed to arrive by December 31, 2025. The final plan must be delivered by December 31, 2026. As of October, Italy has yet to present the first one.
