The decree formalizing the postponement of the 2027 deadline for the BACS Decree was published in the Official Journal on December 26, 2025. It confirms that the compliance of existing commercial buildings equipped with HVAC systems with a power output exceeding 70 kW is now expected by January 1, 2030.
This postponement mainly concerns the tertiary sector located between 70 and 290 kW , while buildings with HVAC installations exceeding 290 kW remain subject to the deadline of January 1, 2025.
The regulatory obligation is therefore maintained; only the deadlines are changing.
A clarified timetable, but the challenges remain
This new timetable primarily provides clarity. It does not alter the objective of the BACS Decree, nor the expected functional requirements of automation and control systems. However, it comes at a time when the building management systems (BMS) market has experienced a period of significant acceleration, the effects of which are only now beginning to be fully analyzed.
In recent years, numerous projects have been launched under the combined effect of regulatory pressure and funding mechanisms. This dynamic has made it possible to quickly launch projects that had been delayed for a long time, but it has also highlighted the importance of upstream planning , particularly when considering actual performance during the operational phase.
From historical lag to recent acceleration: from 6% to 15% of buildings equipped with BMS
Before the entry into force of the BACS Decree, the rate of equipment of tertiary buildings with energy management systems (BMS) remained limited.
According to a report published by the Energy Regulatory Commission (CRE) in 2023 , approximately 6% of commercial buildings larger than 1,000 m² had an energy consumption management system at that time. This figure highlighted a structural lag in the building stock, but also significant potential for improvement.
From 2023 onwards, the bonuses for Energy Savings Certificates (CEE) , combined with the increase in regulatory obligations, have contributed to an acceleration of deployments.
Market studies estimate that by 2024, the rate of BMS equipment in commercial buildings larger than 1,000 m² will reach approximately 15%.
This progress reflects a genuine recovery from a historically low level. However, it does not yet allow for definitive conclusions to be drawn regarding the energy performance associated with all of these deployments, some of which are still recent.
CEE GTB 2023–2024: real acceleration, performance still to be confirmed
The acceleration effect observed between 2023 and 2024, largely linked to the financing mechanisms of Energy Savings Certificates (CEE) and their bonuses, is now well documented. It has contributed to the emergence of numerous projects and a rapid increase in the rate of equipment in the commercial building stock.
At the same time, initial feedback from the field shows that assessing the actual energy savings generated requires further consideration. Rapid deployments, sometimes carried out under tight deadlines, have not always allowed for the integration of an energy framework as precise as expected beforehand.
Without generalizing, some projects appear to have benefited from a windfall effect , a phenomenon already observed in other energy efficiency incentive programs. In more cautious analyses, these discrepancies are sometimes referred to as a rebound effect , when the actual savings turn out to be lower than the initial projections. In these situations, the expected ROI may be jeopardized , not by the technologies themselves, but by the way they were designed, deployed, and operated.
Energy impact modeling as an anchor point
Postponing the deadline to 2030 offers an opportunity to learn from this acceleration phase. Among the levers identified, modeling the energy impact of building management systems (BMS) upstream of projects appears to be a key element.
Ex-ante modeling allows, in particular:
- to set savings targets consistent with the actual uses of the buildings,
- to compare different BMS architecture scenarios,
- to rank the sites according to their potential,
- and to have a benchmark to be compared with observed performance.
This approach is particularly relevant in multi-site contexts, where the consistency of architectures and the consolidation of results determine the overall readability of performance.
CPE and IPMVP: clarifying the rules of the game from the outset
Combining an Energy Performance Contract (EPC) – even in a simplified form – with a recognized protocol such as IPMVP provides a shared framework. It helps align the building owner, the building management system integrator, and the maintenance provider around measurable objectives, without necessarily complicating projects.
Operations, ROI and scaling up
10-year ROI approach , designed to be verified and documented. This requirement underscores that the performance of a building management system (BMS) project is built over time, through continuous monitoring, adjustments, and optimization, well beyond the initial installation phase.
The new timetable also facilitates the emergence of third-party financing , which can help to alleviate CAPEX constraints and accelerate deployment across multi-site assets, provided that they are based on solid energy and operational expertise.
Towards more controlled BACS projects by 2030
The publication of the decree postponing the deadline of the BACS Decree to 2030 provides visibility, while confirming the trajectory undertaken towards a more structured management of energy consumption in the tertiary sector.
Recent years have shown that a rapid acceleration of deployments can produce mixed results. While it has helped to make up for some of the historical lag, it has also highlighted the importance of early planning, consistent architectures, and the ability to measure performance over time. These lessons, still being analyzed, now provide a useful foundation for approaching the future with greater maturity.
In this context, the postponement of the deadline can be interpreted as an opportunity to structure projects more gradually and consistently, particularly across multi-site portfolios. Regulatory compliance is a necessary foundation; real, measurable, and sustainable energy performance, on the other hand, is built continuously, from design to operation.
Sources
- Ministry of Ecological Transition - Decree relating to building automation and control systems (BACS Decree), published in the Official Journal on December 26, 2025.
- Ministry of Ecological Transition - Official FAQ - BACS Decree (tertiary buildings)
- XERFI - The smart building and BMS market in France (2024 edition).
- ADEME - Energy management and performance of commercial buildings