The energy diagnosis in co-ownership is not just an administrative formality. Since January 1, 2026, all co-ownerships with a building permit issued before January 1, 2013, must have a collective energy performance diagnosis (DPE), including small residences with fewer than 50 lots. This obligation, attached to the building and not to the type of property manager, changes the game for many co-ownerships that believed they were still safe.
Mandatory collective DPE schedule: deadlines by size of co-ownership
The gradual rollout of the obligation allows for measuring the scale of the task. Here is the schedule stabilized by the Climate and Resilience law:
| Size of the co-ownership | Date of entry into force | Condition |
|---|---|---|
| More than 200 lots | January 1, 2024 | Building permit before January 1, 2013 |
| 50 to 200 lots | January 1, 2025 | Building permit before January 1, 2013 |
| 50 lots or fewer | January 1, 2026 | Building permit before January 1, 2013 |
The key point to remember: the obligation is attached to the building, not to the number of co-owners or the type of property manager. A building managed by a volunteer property manager is subject to the same rules as a large residence managed by a professional property manager.
Co-ownerships located in Guadeloupe, Martinique, Guyana, and Réunion benefit from an additional delay: the collective DPE will become mandatory there starting from January 1, 2028.
To delve deeper into the specifics for each configuration, the energy diagnosis habitatfuturvert.fr for co-ownership on Place A details the steps tailored to each size of residence.
Collective DPE, DTG, and PPPT: what each diagnosis really measures
The confusion between the different diagnoses regularly slows down decision-making in general meetings. Collective DPE, DTG, and PPPT serve distinct objectives.
The collective DPE assesses the energy consumption and greenhouse gas emissions of the building as a whole. It assigns an energy label (A to G) to the building but does not prioritize the work to be undertaken.
The Global Technical Diagnosis (DTG) goes further. It analyzes the condition of the common areas, collective equipment, and the financial situation of the co-ownership to estimate a total cost for upgrading over ten years.
The Multi-Year Work Plan Project (PPPT) relies on the results of the collective DPE or the DTG to concretely schedule renovation work over several years, with a budget timeline.
- The collective DPE informs about overall energy performance, without proposing a quantified action plan
- The DTG provides a complete technical and financial status of the building
- The PPPT translates these findings into a planned and budgeted work program
In practice, the collective DPE often serves as the mandatory entry point before any consideration of a DTG or a PPPT. A co-ownership rated F or G will have every interest in quickly following up with an energy audit to identify the most relevant renovation scenarios.
3CL-DPE Method: what the March 2025 decree changes for co-ownerships
A decree dated March 27, 2025, applicable from July 1, 2025, imposes the 3CL-DPE method for energy audits in co-ownership. This technical change has direct consequences on the reliability and comparability of results.
Before this harmonization, study offices used various methodologies to model the energy performance of a collective building. The results of an audit and those of a DPE could significantly diverge for the same building, complicating decision-making in general meetings.
Aligning with the 3CL-DPE method reduces this gap. Co-owners now have consistent data between the collective DPE and the audit, making it easier to compare the proposed work scenarios.
For the property manager, this evolution means ensuring that the chosen diagnostician masters the new methodology. A diagnosis carried out according to the old method before July 2025 remains valid for its duration, but any new diagnosis must apply the 3CL-DPE method.
Property manager and energy diagnosis: concrete responsibilities and common pitfalls
The property manager is responsible for including the collective DPE on the agenda of the general meeting. This obligation does not depend on the goodwill of the co-owners: the property manager must propose the vote, even if the subject raises budgetary resistance.
Several pitfalls frequently arise:
- Not putting diagnosticians in competition, leading to overly high quotes or incomplete services
- Confusing collective DPE with individual DPE, whereas the former concerns the entire building and does not replace the latter during a sale or rental
- Postponing the diagnosis from one meeting to another without justification, exposing the co-ownership to a lack of regulatory compliance
- Forgetting to transmit the results of the collective DPE to the national register of co-ownerships, a declaration obligation that has recently been strengthened
The volunteer property manager finds themselves in a particular position. The obligation to carry out the collective DPE applies equally to volunteer property managers, who cannot invoke their status to delay the process. Legal responsibility remains the same.
Preparing technical data in advance
A reliable collective DPE relies on the quality of the information provided to the diagnostician: building plans, energy bills for common areas, descriptions of heating and hot water equipment, history of completed works.
Gathering these documents before the diagnostician’s visit reduces approximations in modeling and speeds up the return of results. The property manager has every interest in anticipating this collection as soon as the diagnosis is voted on in the general meeting.
The energy label obtained conditions the next steps: a building rated in the low category will need to quickly engage in reflection on the PPPT, or risk seeing the value of the lots deteriorate and regulatory constraints on rentals gradually tighten.