The recast of the Energy Efficiency Directive proposed by the European Commission as part of the Fit-for-55 package (July 2021) clarified in its new Article 3 that the Energy Efficiency First (EE1st) principle should apply to all planning, policy and major investment decisions related to energy systems as well as non-energy sectors that have an impact on energy consumption and energy efficiency. 

Member States provided limited, if any, information in their National Energy and Climate Plans (NECPs) in 2019-2020 on what EE1st means in their national context and how they plan to operationalise it. EE1st was then a relatively new concept, and implementing it has proved to be a difficult task for Member States. Acknowledging this, the European Commission developed further guidelines for the implementation of EE1st in the energy, end-use, and finance sectors.  

To support the implementation of EE1st in the Member States, this report offers a deep–dive analysis of the implementation of EE1st in three different countries: Germany, Hungary, and Spain. Under consideration are the different policy frameworks in these countries, with a focus on buildings and their energy supply (more specifically, power and district heating sectors). The main policies relevant for EE1st implementation, potential, gaps and national specificities are analysed. The policy assessment is based on the combination of literature review and semi-structured interviews. 

Making EE1st a reality requires a systemic approach to policymaking, with integrated planning and investment decisions, so that supply-side and demand-side resources are considered jointly. The debate around EE1st should embrace policies that are often seen from a supply perspective. Reciprocally, the energy efficiency policies should be designed with supply-side impacts in mind, considering the energy system as a whole. Implementing EE1st is not necessarily about adopting new policies: it is firstly about ensuring that the existing policies are in line with the EE1st principle.