BACS Decree: a postponement that offers the opportunity to be more demanding in your BMS projects

Posted on December 2, 2025

Summary

Download our BACS Decree compliance guide

A draft decree currently open for public consultation proposes postponing certain deadlines of the BACS Decree for commercial buildings, particularly those with HVAC systems rated between 70 and 290 kW. This potential postponement could provide some relief to a portion of the building stock… but also offer a strategic opportunity for managers, operators, and owners: to prepare their projects with greater rigor and control.

Reminder: the objective of the BACS decree

The BACS Decree requires tertiary buildings equipped with HVAC (heating, ventilation, air conditioning) systems to have an automation and control system, typically a BMS (Building Management System).

Goals :

Automatic regulation of installations
continuous monitoring of consumption,
optimization of energy-intensive uses,
efficiency gains and regulatory compliance.

For a complete overview, see our article: Everything you need to know about the BACS decree: the essential FAQ for real estate asset managers

The submission depends primarily on the rated useful power of the HVAC installations.

Learn more about the BACS decree

What the draft postponement says - and what remains unchanged

The draft decree plans to postpone the deadline for existing buildings with 70 to 290 kW 2030

On the other hand :

Buildings > 290 kW remain subject to the deadline of January 1, 2025.
New buildings with installations > 70 kW also remain subject to this regulation.

This partial postponement aims to align the French timetable with European directive 2024/1275, but does not call into question the substance of the obligation: BMS remains central to the energy transition of the tertiary building.

What this means for service sector players — opportunities and risks

✅ Opportunities

Extra time for budgeting, planning, and arbitration.
Option to choose a latest generation , scalable and controllable BMS.
Integration of BACS into a comprehensive energy strategy (audit, renovation, multi-year plan).

⚠️ Risks

Risk of regulatory procrastination.
Complexity for multi-building portfolios (multiple maturities).
Regulatory confusion is possible without close monitoring.

Why act now despite a possible postponement?

Even with an additional delay, a BMS project requires anticipation, planning and trade-offs.

In our analysis "BACS Decree: Issues, delays and opportunities for the energy flexibility of tertiary buildings", we remind you that BMS is not only an obligation, but a lever for energy performance, comfort and intelligent control.

What we recommend: the 4 priorities

Energy audit + BMS audit to map, prioritize, budget.
Multi-year roadmap including BMS in efficiency work.
Choose a modular , scalable BMS that is compatible with future challenges (control, flexibility, smart-building).
Document consumption via an energy monitoring or supervision platform.

Why is a BMS audit coupled with an energy audit a profitable investment — and a strategic lever to defend your interests?

In a market where the quality of building management system (BMS) integrators varies considerably, a BMS audit combined with an energy audit is the best way to safeguard your interests, your investment, and your performance. Too many BACS projects are limited to "installing a BMS" without ever formalizing performance objectives . Yet, it is in performance—not in the equipment—that the real ROI lies.

An essential step to mastering your ROI

Accurately defining your needs and objectives allows you to:

to frame the project,
secure the commitments,
establish a clear framework for the integrator,
avoid installations that are disconnected from the actual needs of the building.

And above all: to show that the expected energy savings will be supervised, measured and compared to a solid initial model , and not to an intuitive estimate.

The approach that Sobre masters and formalizes

At Sobre, we model the energy impact of future building management systems (BMS) in advance

a quantified and realistic view of the potential savings,
an enforceable standard,
a management approach that complies with best practices.

This also makes it easier to select an integrator committed to a performance-oriented approach, ideally through an EPC (Energy Performance Contract).

The end of the EEC illusion

Energy efficiency certificates (EECs) have long artificially reduced ROI, giving the illusion that operations were secondary. In reality, actual performance depends 80% on operations, management, and continuous optimization.

the real ROI happens , the one that sustainably reduces operating costs.

The BACS Decree mandates a verifiable ROI over 10 years.

This obligation must be verified and documented :

by your project management design office,
and ideally via an energy monitoring platform,
or a module like My Eco-Performance , the only solution on the market aligned with the IPMVP standard , guaranteeing a reliable and indisputable measurement of the real impact of the BMS.