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APE: when it is required, its value and the risks without it

The APE is mandatory for selling, renting, and even just for publishing the listing. It is valid for a maximum of ten years, must be prepared by an independent qualified technician, and in Lombardia requires an inspection and registration with the regional energy registry CENED to be valid.

Let’s clarify immediately a point where online information is largely stuck twelve years ago: a sales deed without APE is not null and void. The nullity introduced in 2013 was abolished a few months later by Article 1, paragraph 7, of Decree Law 145/2013 and replaced with a monetary penalty — with retroactive effect. However, penalties do exist, and they are not minor.

Penalties, divided by case

They are often confused with each other, while there are three distinct tracks provided by Legislative Decree 192/2005.

Violation Amount Charged to
Failure to provide APE in a sale €3,000 – €18,000 Owner / seller
Failure to provide in a new lease €300 – €1,800 Owner
Omitted clause or attachment in sale €3,000 – €18,000 The parties, jointly and in equal parts
Omitted clause in lease €1,000 – €4,000 (halved if the duration does not exceed 3 years) The parties jointly
Listing without energy data €500 – €3,000 Listing responsible party

The last row also concerns us as an agency and is the reason why we do not publish a listing without an APE: the penalty affects the publisher, not only the owner.

When it is required and when not

The APE is mandatory for sales, transfers for free, every new lease, and for commercial advertisements distributed by any means — paper, web, radio, television (Article 6 of Legislative Decree 192/2005).

Exemptions are listed in Article 3, paragraph 3:

  • protected cultural assets;
  • industrial and artisanal buildings heated for production process needs;
  • non-residential rural buildings without air conditioning systems;
  • buildings declared uninhabitable or collapsed;
  • isolated buildings with usable surface area less than 50 square meters;
  • boxes, cellars, garages, storage, and seasonal non-air-conditioned structures;
  • places of worship.

A useful clarification for those renting: since December 2013 it is no longer mandatory to attach the APE to lease contracts of single real estate units. However, delivery to the tenant and inclusion of a clause in the contract remain mandatory.

Validity: ten years, but not always

The validity is ten years from issuance (Article 6, paragraph 5). It expires earlier in two cases:

  • if the control and maintenance requirements of heating systems are not met — the system logbook must be kept updated;
  • following renovation or upgrading interventions that modify the building’s energy performance.

The second case is the one that catches people unprepared: those who have changed the boiler or reapplied insulation after obtaining the APE hold an expired document and usually notice this in front of the notary.

Who can prepare it

A technician qualified to design buildings and systems, registered with their respective order or college, possessing the requirements under DPR 75/2013. The decree requires independence and impartiality: the certifier declares in the APE not to have been involved in the design or construction of the property, and the client cannot be a spouse or relative within the fourth degree.

In Lombardia, additional rules apply: the certifier must be accredited with the regional energy registry CENED, the inspection is mandatory, and the certificate must be registered to be valid. An APE issued without inspection in Lombardia is not an APE.

Regarding cost: there is no mandatory rate schedule and prices are free. Any figure indicated online is a market datum, not a norm — ask for a couple of quotes from accredited certifiers.

How much the energy class affects the price

There are many estimates here, often without sources. The most solid data available is from the Bank of Italy.

A study published in the series Questioni di Economia e Finanza (number 818, November 2023) analyzed Italian real estate listings with a hedonic model: the asking price for properties in the top four energy classes is on average about 25% higher than those in class G. The differential varies significantly by province, depending on climate and regional regulations.

In the Annual Report for 2025, published in May 2026, the Bank of Italy also found that that year properties in class A or B saw price increases of about 2%, while those in class F or G decreased by about 4%, and that mortgages for efficient properties have lower spreads.

There are also higher figures circulating — up to 50% — from private observers. They may be accurate, but we do not report them as data because we cannot verify their methodology. The 25% from the Bank of Italy is a prudent and documented estimate: if you need to make an economic assessment, start from there.

The “Green Homes” directive: what is true

Many owners ask us whether they will be required to renovate, or if they can still sell a house in class G. The short answers are no and yes, which you can find fully explained in the article we dedicated to the directive. In summary: Italy has not yet implemented the European directive, so no obligations arising from it currently burden individual owners, and in no case does the European text provide for sales or rental bans for low classes.

Instead, a recent and real Italian intervention should be noted: the Ministry of the Environment decree of October 28, 2025, effective June 3, 2026, updated the calculation methodologies and minimum requirements. It concerns how the APE is prepared, not the obligations of the holder. Certificates issued beforehand remain valid for their ten years and do not need to be redone.

In summary

The APE is required for selling, renting, and publishing the listing; it is valid for ten years unless it expires earlier, and in Lombardia requires inspection and CENED registration. The deed without APE is not null but penalties can reach €18,000. Regarding value, the serious reference is the Bank of Italy study: about a 25% difference between the top classes and class G.

If you are about to sell or rent in Milano San Felice or Segrate and do not know if your APE is still valid, we can check it along with the rest of the documentation.

Frequently Asked Questions

When is the APE mandatory?

For sales, free transfers, every new lease, and the publication of real estate listings. Exempt are, among others, protected cultural assets, uninhabitable or collapsed buildings, isolated buildings under 50 square meters of usable surface, and boxes, cellars, and garages.

How long does the APE last?

Ten years from issuance. It expires earlier if heating system maintenance obligations are not met or if interventions modify the building's energy performance.

What happens if I sell without an APE?

The deed is not null — nullity was abolished in 2013 — but a penalty from €3,000 to €18,000 applies. If the clause or attachment is missing in the deed, the penalty is joint and several among the parties and equally divided.

Is the APE required for renting?

Yes, for every new lease, with mandatory delivery to the tenant and clause in the contract. It is no longer mandatory to attach it to lease contracts of single real estate units.

Does the energy class increase the home's value?

According to the Bank of Italy study from November 2023, properties in the top four classes have on average asking prices about 25% higher than class G, with significant variations between provinces. The Annual Report for 2025 confirms the divergence: classes A and B growing, classes F and G declining.

Do I need to redo the APE after the 2025 decree?

No. Certificates issued before its entry into force remain valid for their ten years: the decree applies to APEs issued from that moment on and has no retroactive effect.

Who pays for the APE, the seller or the buyer?

The seller. The obligation to provide it lies with the seller, who must deliver it to the buyer.