Energy certification – Exemption

In this article, we will cover what you need to know about the fee exemption at ADENE. 2025. When we talk about the exemption from energy certificates, we refer to the situation where the property owner is exempt from paying fees to the Energy Agency (ADENE) or, in certain cases, is exempt from requesting the energy certificate.

Regarding the exemption from fees to ADENE when requesting an energy certificate, there are usually two associated costs: the expert’s service fee, which can vary depending on the company or expert chosen, and the fees payable to ADENE, depending on the property type or the size of the commercial space.

Find more information about energy certificate prices here.

It is important to highlight two specific situations involving the exemption from fees to ADENE. In the first case, if you already have a valid energy certificate (valid for 10 years) and have implemented measures to improve the building’s energy rating to at least a “B-“, you are exempt from paying fees to the Energy Agency. In the second case, if the building is considered a ruin — that is, unfit for habitation — you are also exempt from paying ADENE fees. However, there are other situations in which energy certificates are not required, as detailed below.

 

Exemption from Energy Certificates

According to Decree-Law No. 101-D/2020 of December 7, certain types of properties are exempt from presenting an energy certificate:

  • Single-family buildings with a useful floor area equal to or less than 50 m²;
  • Non-residential industrial, livestock, or agricultural facilities and workshops with no current or expected energy consumption related to space heating or cooling intended for human comfort;
  • Buildings used as places of worship, such as churches, synagogues, mosques, and temples;
  • Buildings exclusively intended for unconditioned (non-climate-controlled) parking;
  • Warehouses where human presence does not exceed 2 hours per day or does not represent an occupancy greater than 0.025 persons/m²;
  • Sales or transfers in fulfillment of buildings to a co-owner, tenant, or expropriating entity, when resulting from an enforcement or insolvency process, or when made for their total demolition, subject to prior confirmation by the competent licensing authority;
  • Non-remunerated transfers, namely donations, legacies, and inheritances;
  • Rentals of the landlord’s primary residence for a period shorter than 4 months;
  • Rentals to the previous tenant of the building immediately prior to the new legal transaction;
  • Large commercial and service buildings that are not in operation, provided that they are not sold, transferred in payment, leased, or assigned;
  • Buildings in ruins;
  • Military infrastructures and buildings subject to control and confidentiality rules, namely those assigned to security forces and services or information systems;
  • Commercial and service buildings located within facilities subject to the regime approved by Decree-Law No. 71/2008 of April 15, as currently amended.

 

Improvements for Energy Efficiency

In addition to exemptions, it is essential to consider some improvements to increase energy efficiency, namely:

  • Wall insulation;
  • Roof insulation;
  • Renewal of windows and doors;
  • Replacement of windows and doors;
  • Ventilation systems;
  • Solar thermal systems;
  • Heat recovery units and wood-burning stoves;
  • Water heaters and boilers;
  • Domestic air conditioning;
  • Photovoltaic solar systems.

It is important to highlight that the list of exemptions from energy certificates may be subject to changes or updates in accordance with any future modifications to applicable laws and regulations. In summary, although certain types of properties may be exempt from presenting an energy certificate under specific circumstances as described above, it is crucial that owners are aware of their obligations and comply with any energy certification requirements that may apply to their specific type and situation.

 

Other additional situations: Contact our team of specialists.