From January this year, non-residential buildings with a thermal capacity of at least 290 kW must comply with the BACS requirement (Building Automation and Control Systems). Despite this, there is still considerable uncertainty in the real estate sector about what the regulation entails. In this blog, I explain what buildings are required to meet, what is still unclear and how you can prepare.
The GACS requirement is no longer a policy intention but is formally embedded in Dutch law through the Besluit Bouwwerken Leefomgeving (BBL). The functional requirements for GACS are defined in Articles 3.145, 3.146, 4.160d and 4.160e of the BBL, making GACS an enforceable obligation under the Dutch building regulations.
According to figures from the European Parliament, buildings account for 36% of greenhouse gas emissions in the EU. This is why the European Commission introduced the Energy Performance of Buildings Directive (EPBD IV). The aim of the EPBD is to achieve very low-energy, zero-emission buildings by 2050. Interim targets for non-residential buildings are to upgrade the worst-performing 16% by 2030 and the worst-performing 26% by 2033.
EU member states implement this regulation individually. The BACS requirement is the Dutch implementation. Not all countries apply the same deadlines. Germany’s version of BACS, GEG §71a, for example, has been in force since January 2025.
To meet the 2050 targets, regulation will become progressively stricter. While the BACS requirement applies from January this year to buildings with systems from 290 kW upwards, this threshold will be lowered to 70 kW from 2030. Investing in building decarbonization will therefore only become more urgent after January.
What do you need to do?
Checklist for building automation
The BACS requirement consists of two parts: building automation (BA) and the control system (CS). BA refers to the level of automation of the building management system. The requirements for BA are set out by the RVO in a checklist based on the NEN-EN-ISO 52120 standard. A specialized installer or technical advisor can use this checklist to assess compliance.
BACS distinguishes between four performance classes: A, B, C and D, with A being the highest level. From January 2026, a minimum of class C is required for building automation. Most buildings subject to BACS already have a building management system with some level of automation. Meeting the BA requirement therefore comes down to reviewing the checklist and making targeted upgrades where needed.
Monitoring through a control system
For the CS requirement, building operators must demonstrate that their buildings are equipped with systems that structurally monitor energy performance and allow for manual optimization. This requires insight into total energy consumption, from main meters to individual installations and even per tenant. This data underpins regulatory reporting such as ESG disclosures, certifications like BREEAM and BACS compliance.
From January this year, the minimum CS requirement under BACS is class B. Class B means that energy flows within a building can be measured effectively. Based on these measurements, an installer can manually optimize building automation.
From compliance to strategic advantage: BRIGHTER as a control system
With smart solutions such as BRIGHTER, you can be confident that your control system meets the requirements. BRIGHTER does more than monitor energy flows. Using data from the building management system, main and sub-meter data and weather forecasts, BRIGHTER automatically optimizes performance. As an example, after integrating BRIGHTER, the Acanthus office building in Amsterdam now meets BACS class A. This higher class will become mandatory in the future and already provides a strategic advantage in attracting tenants and investors.
More than 75% of non-residential buildings perform worse in practice than their energy label suggests, mainly due to a lack of optimization. By continuously monitoring and optimizing, BRIGHTER reduces operational costs and lowers energy consumption by an average of 28% per year, while also improving tenant comfort. As Spectral CEO Philip Gladek explains in this blog, a control system should not be seen purely as a regulatory obligation, but as a strategic opportunity.
Uncertainty is not a reason to wait
Not all aspects of BACS enforcement are clear yet. For example, it is still unknown how enforcement will take place and on what basis reporting will be assessed. Will enforcement start immediately? These answers are still pending. What is clear is that the Omgevingsdienst will be responsible for enforcement and that reporting will be required at municipal level.
It is also clear what compliance delivers: higher asset value, improved comfort and increased attractiveness for tenants. Thanks to optimization, the investment typically pays back quickly. Non-compliance carries risks such as fines, value depreciation and stranding risk.
BACS is a strategic opportunity. Investing in a system like BRIGHTER is a first step towards a future-proof portfolio. Paris Proof starts with insight into your systems and the centralization of data. Only then do opportunities for decarbonization become visible. What you can’t see, you can’t manage.
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