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From Split Incentives to Shared Responsibility: Evaluation of Germany’s Carbon Cost Allocation Law for Rental Buildings Cover

From Split Incentives to Shared Responsibility: Evaluation of Germany’s Carbon Cost Allocation Law for Rental Buildings

Open Access
|Sep 2026

Figures & Tables

Figure 1

10-tier model of the CO2KostAufG based on the annual CO2 emissions per living space in kg CO2eq/m². Own Figure based on CO2KostAufG (2022).

Figure 2

Mixed-methods approach of this study. Own Figure.

Table 1

Average living space (Source: 2018 Micro Census (Statistisches Bundesamt 2019)), extrapolation of total living space by heating type (Source: Census 2022 (Statistisches Bundesamt 2023)). All numbers are rounded.

TYPEAVERAGE LIVING SPACE [m2]TOTAL LIVING SPACE [MIO m2]
ALLNATURAL GASHEATING OILDISTRICT HEATINGOTHER HEATING TYPES
MFHs73.91,322.3796.2135.9329.960.3
SFHs121.3200.8117.146.911.725.1
TFHs92.6190.7103.357.37.622.5
Table 2

Emission factors as published by BAFA (2023). CO2-prices for district heating based on average EU-ETS 1 price in 2023 (Umweltbundesamt 2024b), and for natural gas and heating oil on the nETS price (BEHG 2019).

ENERGY SOURCEEMISSION FACTOR [t CO2/MWh]CO2 PRICE [€/t CO2eq]
Natural Gas0.18 (heating value)
0.201 (calorific value)
30.00
Heating Oil Light0.266 (calorific value)30.00
District Heating0.28 (calorific value)83.66
Figure 3

Number of rented apartments (in millions) in Germany by building type and ownership type, categorized by heating sources (Source: Statistisches Bundesamt 2023).

Figure 4

Estimated CO2 costs by emission tier covered by landlords and tenants for German rented multi-family dwellings in 2023 based on energy performance certificates (source: DIBt).

Figure 5

Breakdown of the rented living space by emission levels for the portfolios of three major German billing service providers (source: billing service provider data).

Figure 6

Estimated share of CO2 costs covered by landlords for multi-family buildings in 2023 based on the survey responses (source: survey).

Table 3

Overview on the CO2 cost distribution between landlords and tenants.

ENERGY CERTIFICATESBILLING SERVICE PROVIDERSSURVEY
Share Landlords52% (only MFH), 60% (MFH, SFH, TFH)26%, 27%, 36% (only MFH)33%
Share Tenants48% (only MFH), 40% (MFH, SFH, TFH)74%, 73%, 64% (only MFH)67%
Figure 7

Share of tenant households with central heating systems based on EU-SILC 2023 microdata (Eurostat 2024b), tenant households include “Tenants, rent at market price”, “Tenant, rent at reduced price”, and “Tenant, rent free”. According to Eurostat rules, Sweden, Latvia, and Croatia (for central heating) as well as Romania, Norway, Spain, and Croatia (for district heating) should be flagged due to a low number of observations (20–49 observations). Additionally, for district heating, Belgium, Ireland, Greece, and Portugal cannot be shown due to a low number of observations (<20 observations).

DOI: https://doi.org/10.66506/ed.32 | Journal eISSN: 3119-4044
Language: English
Page range: 3 - 3
Submitted on: Apr 29, 2026
Accepted on: Jul 14, 2026
Published on: Sep 4, 2026
Published by: European Council for an Energy Efficient Economy (eceee)
In partnership with: Paradigm Publishing Services

© 2026 Franka Sunder, Sibylle Braungardt, Tilman Hesse, Friedhelm Keimeyer, published by European Council for an Energy Efficient Economy (eceee)
This work is licensed under the Creative Commons Attribution 4.0 License.