The European Commission opened infringement procedures by sending letters of formal notice to EU Member States that have not notified full transposition of three directives with recently expired deadlines, covering energy efficiency, renewable transport fuels and financial markets. Member States have two months to respond, complete transposition and notify the Commission, after which the process may move to a reasoned opinion. For the recast Energy Efficiency Directive (EU) 2023/1791, transposition notifications were due by 11 October 2025 (with some specific provisions subject to their own deadlines) and only Czechia has notified full transposition, prompting formal notices to the other 26 Member States. The directive sets a binding EU target to reduce final energy consumption by 11.7% by 2030 (compared to 2020 projections) and includes measures requiring the public sector to cut its own final energy consumption by 1.9% each year (compared to 2021 levels) and renovate at least 3% of public buildings annually, alongside requirements such as national “one-stop shops” for advice and support, energy efficiency reporting by data centres, and promotion of energy efficiency services and financing solutions. Separately, Belgium, Czechia, Denmark, Germany, Estonia, Ireland, Greece, Spain, Croatia, Latvia, Malta, the Netherlands, Austria, Portugal and Finland were put on notice for not fully transposing Delegated Directive (EU) 2024/1405 by 14 September 2025, which updates Annex IX feedstocks under the Renewable Energy Directive for the production of biofuels and biogas used in the transport sector. In financial services, Belgium, Bulgaria, Germany, Estonia, Greece, Spain, France, Italy, Lithuania, the Netherlands, Poland, Portugal and Romania received formal notices for not fully transposing Directive (EU) 2024/790 by 29 September 2025, which amends the Markets in Financial Instruments Directive to ensure coherence with the Markets in Financial Instruments Regulation (MiFIR) and requires national sanctions for infringements of new MiFIR provisions related to consolidated tapes.
European Commission 2025-11-21
European Commission issues letters of formal notice over Member States’ failure to transpose energy efficiency, renewable feedstock and Markets in Financial Instruments Directive amendments
The European Commission initiated infringement procedures against EU Member States for not fully transposing directives on energy efficiency, renewable transport fuels, and financial markets. Only Czechia has fully transposed the Energy Efficiency Directive, while 26 other Member States received formal notices. Several countries were also notified for not fully transposing directives on renewable energy feedstocks and financial market regulations.