The energy renovation plan: what the regulation actually requires
A building owner can commission an energy renovation plan. From 1 October 2026 the rules say exactly what each stage must contain. Boverket had not published any guidance when we wrote this guide, but the rules are published.
In brief
- Owners can order an energy renovation plan. It is voluntary. The rules on its content apply from 1 October 2026.
- The plan splits the renovation into stages. Each stage lists cost, saving and the energy class the house should reach.
- The plan must be filed with Boverket, and only a certified energy expert can do that.
- Anyone may advise on renovating in stages, but that is not an energy renovation plan.
- Boverket had not published its guidance when this guide was written. Nobody knows how many owners want a plan.
On this page
The plan is Sweden's implementation of the EU renovation passport in directive (EU) 2024/1275, article 12. It arrives through SFS 2026:869, which inserts 8 a § into förordningen (2006:1592) om energideklaration för byggnader. It is voluntary: no owner is obliged to commission one.
What each stage must contain
This is the core. The regulation requires a roadmap of stages and the order between them, and for each stage six items:
1. which renovation measures the stage includes and which alternatives exist,
8 a § of ordinance 2006:1592, added by SFS 2026:869 — our translation
2. the estimated energy savings in primary and delivered energy, expressed in kWh/yr and as a percentage improvement on the energy use before the measures,
3. the estimated costs of carrying out the stage,
4. how large a reduction in operational greenhouse-gas emissions the stage is estimated to bring,
5. the estimated savings in the form of lower energy costs, and
6. which energy class the building is judged to reach once the stage is complete.
Point 2 demands the most work and is the easiest to misread: both primary and delivered energy, each in kWh/yr and as a percentage against the starting point. That is four figures per stage for the energy part alone.
Beyond the stages, the plan must also cover the building's current energy performance, the minimum requirements that apply, district heating and cooling, the share of renewable energy, circularity, health and comfort, climate adaptation, and financing.
The order of the stages is a competence requirement
From the same date the requirements on the certified energy expert are tightened. BFS 2026:11 (CEX 8) adds, as a competence requirement in its own right:
”kunskap om energirenoveringsplanens innehåll och hur dess etapper tas fram och ordnas i optimal ordningsföljd”
BFS 2026:11 (CEX 8), punkt 12
The same regulation adds competence in calculating the building's operational greenhouse-gas emissions (point 13). No calculation software is named for either. The software requirement in CEX still covers only the calculation of a building's energy use.
Who may produce one?
12 § of the energy declaration act says that whoever wants a plan "shall appoint an independent expert" (our translation), and the bill adds that the building must first be inspected on site. 10 § of the ordinance (2006:1592), which requires certification, names only the energy declaration and the inspection report. SFS 2026:869 did not amend it.
Certification still decides it, through filing. Point 3 of the act's 12 § says the expert must transfer the plan to Boverket. BFS 2026:10 (BED 13) 16 § says this is done on Boverket's electronic form, directly into the declaration register, and 17 § that it requires authorisation, which only certified energy experts hold.
The plan replaces the recommended measures
”Om en energirenoveringsplan upprättas tillsammans med en energideklaration, ska rekommendationer enligt 9 § första stycket 4 inte lämnas i deklarationen.”
Lag (2026:744)
If the plan is produced alongside the declaration, the recommended measures fall away — the two do not coexist. The summary's new layout from 1 October also carries its own box for "Information om åtgärdsförslag, energirenoveringsplan, eller information om energiklassning A0".
What is not yet settled
- Boverket had not published any guidance in September 2026. The 28 August press release says it "will be published gradually" (our translation). No date is given.
- The form's fields are not published. Since the content beyond the provisions follows Boverkets elektroniska formulär, that form is in practice the template. It cannot be read from outside the register.
- No price exists. Regelrådet explicitly criticised the impact assessment for lacking quantitative estimates of the cost to businesses.
- Demand is untested, and the bill says so itself: it remains "fortfarande oklart om möjligheten till … energirenoveringsplaner kommer att efterfrågas i en större skala".
Sources and caveats
Sources and caveats. Förordning (2006:1592) as amended by SFS 2026:869 · lag (2006:985) as amended by lag (2026:744) · BFS 2026:10 (BED 13) · BFS 2026:11 (CEX 8) · prop. 2025/26:159 · directive (EU) 2024/1275 · BeBo 2025:02 · Regelrådet's opinion RR 2026-31. Quotations are taken from the statutory texts. This guide is a reading of the rules, not legal advice, and Boverket's forthcoming guidance may refine or change the interpretation.