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The 2027 EED deadline for tenant heat billing
Quick summary
From 1 January 2027, every home in the EU with heat and hot-water meters must have remotely readable devices, with monthly consumption information during the heating season. A Danish Tenancy Act change effective 1 January 2024 lets landlords pass the cost of delivering that information to tenants. Together, these create a clear case for acting on sub-metering and tenant-billing systems now.
Introduction
Heating and hot water account for a large share of the energy used in European homes, which is why the EU has spent several years tightening the rules on how that consumption is measured and communicated. The Energy Efficiency Directive sets out a phased path towards remotely readable metering and frequent consumption information, and the final phase arrives soon.
From 1 January 2027, meters and heat cost allocators that cannot be read remotely must be replaced or upgraded, and consumers in buildings with remotely readable devices are entitled to monthly consumption information during the heating season. In Denmark, a 2024 change to the Tenancy Act has removed a practical barrier to delivering that information by letting landlords recover the cost from tenants. For anyone managing rental or sub-metered property, the combination makes the case for acting now, well ahead of the deadline. The directive sets the destination and the Danish change removes a common excuse for delay, which is why the planning that matters most can begin today rather than in 2026.
What the EED actually requires, and by when
The Energy Efficiency Directive introduced its metering and billing requirements in phases, so it helps to see the sequence rather than just the final date.
The direction was set years ago. Newly installed heat, hot-water and heat-cost-allocation devices have had to be remotely readable since October 2020, and since January 2022, consumers in buildings already fitted with remotely readable devices have been entitled to consumption information at least monthly during the heating season. The final step completes the transition.
Article 9c of the directive states plainly that meters and heat cost allocators which are not remotely readable but are already installed must be rendered remotely readable or replaced with remotely readable devices by 1 January 2027, except where a member state shows this is not cost-efficient (European Commission, 2019). The European Commission has been clear that this cost-efficiency exception should be read very restrictively, with any deviation specific, justified and documented.
The reason the 2027 date is effectively firm is that the Commission treats the cost-efficiency exemption as a narrow exception rather than a general escape route, so most building owners cannot rely on it to avoid acting. The directive's own reasoning notes that most heat cost allocators and meters are replaced within roughly ten years anyway for battery or calibration reasons, which undercuts the argument that existing devices represent unrecoverable sunk costs.
Takeaway: By 1 January 2027 effectively all heat and hot-water metering must be remotely readable, and the cost-efficiency exemption is deliberately narrow.
The Danish Tenancy Act change that removes the cost barrier
Delivering monthly consumption information sounds straightforward, but in rental property it created a practical friction. The information has to be collected and distributed every month during the heating season, often through a third-party metering provider, and that carries a cost. Some Danish landlords, despite having installed remotely readable meters, held back from sending the information because of the expense involved.
A change to Danish law has removed that friction. An amendment adopted on 28 December 2023, Lov nr. 1793, took effect on 1 January 2024 and altered the Tenancy Act so that landlords must include the third-party costs of delivering the monthly EED consumption information in the tenant's consumption account (EjendomDanmark, 2024). What had been a discretionary cost the landlord absorbed became a cost recoverable through the heating account.
The framing matters. As the Danish property federation and metering providers have noted, this is not merely a right but an obligation: landlords are to include these third-party delivery costs in the consumption account rather than absorb them. The change applies where remotely readable energy or heat-allocation meters are installed, and Danish practice treats drive-by reading as a form of remote reading for this purpose.
The Danish Housing Ministry has clarified the timing. Only costs for delivering monthly consumption information incurred after 1 January 2024 fall under the change, so the new provision applies to consumption accounts covering 2024 onward, not retrospectively to 2023 costs.
The interpretive point is that the 2024 change makes monthly EED reporting cost-neutral for Danish landlords, which removes the main practical reason many had for delaying, and is likely to accelerate the shift to compliant remote metering and reporting. A barrier that was financial as much as technical has been taken away.
Takeaway: Since 1 January 2024, Danish landlords recover the cost of monthly EED consumption reporting through the tenant's heating account, removing a key barrier to compliance.
Why this is the moment to act on metering and billing
The two developments point the same way. The EED makes remotely readable metering and monthly information mandatory by 2027, and the Danish change makes delivering that information cost-neutral for landlords now. For property owners and managers, waiting carries more risk than acting.
The practical reasons to move early are concrete:
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Lead times are real, since replacing or upgrading meters across a portfolio, especially where individual metering did not previously exist, takes planning and installation time that compresses badly close to a deadline
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Sunk-cost risk rises as 2027 approaches, because any non-remotely-readable device installed late is likely to need replacing again, a point the Commission has made directly
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The monthly reporting obligation already applies where remotely readable devices are installed, so compliance is not only a 2027 concern but a present one
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Drive-by reading counts as remote reading in Danish practice, but a fixed-network solution is generally better suited to the monthly cadence the directive requires
Beyond pure compliance, frequent consumption data has a genuine purpose. Monthly information lets residents see the effect of their behaviour within weeks rather than waiting for an annual statement, which is exactly the awareness the directive is trying to create, and the same data can surface anomalies such as leaks or faulty devices early.
The reason early action is the lower-risk path is that the obligations are firm, the deadline is fixed, lead times are non-trivial, and in Denmark the cost barrier has already been removed, so the main argument for waiting has largely disappeared. The organisations that plan their metering and billing transition now will reach 2027 in control rather than under pressure.
For property owners, housing associations and the metering and software providers that serve them across Denmark and the wider Nordics, this is a defined, near-term compliance task with a clear technical answer rather than an open-ended one.
Takeaway: With firm deadlines, real lead times and the Danish cost barrier removed, planning the metering and billing transition now is the lower-risk path to 2027 compliance.
Conclusion
The EED's final metering phase makes remotely readable heat and hot-water meters with monthly consumption information mandatory from 1 January 2027, and the Commission has signalled that the cost-efficiency exemption will not be a way out for most. In Denmark, the 2024 Tenancy Act change has made delivering that monthly information cost-neutral for landlords, removing the main practical reason for delay.
For property owners and the providers that support them, the sensible response is to treat the metering and tenant-billing transition as a near-term project: plan portfolio upgrades, choose metering and reporting solutions suited to the monthly cadence, and use the resulting data to give residents the consumption awareness the directive intends. Acting now turns a looming deadline into a manageable, well-paced transition.
FAQ
What does the EED require by 1 January 2027?
Under Article 9c of the Energy Efficiency Directive, meters and heat cost allocators for heating, cooling and hot water that are not remotely readable must be rendered remotely readable or replaced with remotely readable devices by 1 January 2027, unless a member state demonstrates this is not cost-efficient. The European Commission has stated that this exemption must be interpreted very restrictively.
When did the monthly consumption information requirement start?
Since January 2022, consumers in buildings equipped with remotely readable meters or heat cost allocators have been entitled to consumption information at least monthly during the heating season. This obligation already applies wherever remotely readable devices are installed, so it is a current requirement, not only a 2027 one. Newly installed devices have had to be remotely readable since October 2020.
What changed in the Danish Tenancy Act in 2024?
An amendment adopted on 28 December 2023 (Lov nr. 1793) took effect on 1 January 2024 and changed the Danish Tenancy Act so that landlords include the third-party costs of delivering the monthly EED consumption information in the tenant's consumption account. This makes monthly reporting cost-neutral for landlords. It applies where remotely readable meters are installed, and only to costs incurred from 1 January 2024 onward.
Does drive-by meter reading count as remote reading?
In Danish practice, drive-by technology is treated as a form of remote reading for the purposes of these rules. However, because consumption information must be provided monthly during the heating season, a fixed-network solution that collects data automatically is often better suited to that cadence than a drive-by approach that requires a vehicle to pass each building each month.
Sources
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Commission Recommendation (EU) 2019/1660 on the implementation of the metering and billing provisions of the Energy Efficiency Directive (Article 9c) – EUR-Lex – 2019 – https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019H1660
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Energy Efficiency Directive – European Commission, Energy – 2023 – https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficiency-targets-directive-and-rules/energy-efficiency-directive_en
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Præcisering af regler om forbrugsregnskabet (Lov nr. 1793 af 28. december 2023) – EjendomDanmark – 2024 – https://ejd.dk/nyheder/praecisering-af-regler-om-forbrugsregnskabet
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Krav om fjernaflaeste maalere samt forbrugsoplysninger – EjendomDanmark – 2020 – https://ejd.dk/nyheder/nye-krav-til-fjernaflaeste-maalere-samt-forbrugsoplysninger
