Implementing minimum energy performance requirements ‘from the middle’: shifting levels of agency and capacity of housing developers in Sweden

Minimum energy performance requirements (MEPR) for new buildings are a key policy instrument to achieve climate targets and have been part of the EU's Energy Performance of Buildings Directive (EPBD) since 2002. This study provides a novel longitudinal approach, following seven housing developers in Gothenburg, Sweden, and examining their engagement with MEPR implementation in newly built multi-family buildings across the design, construction, and use phases. Drawing on the middle-out perspective, it explores the agency and capacity of developers over time, offering insight into how motivations, priorities, and capabilities affect MEPR compliance. Energy performance data are combined with two rounds of developer interviews (2012 and 2021/2022) and planning documents to compare calculated and actual performance and to understand developer perspectives. Findings reveal that developer agency and capacity decline over time, particularly for those building to sell, and that meeting MEPRs requires not only local government enforcement but also active engagement from residents and energy managers. Based on these insights, four policy recommendations are proposed: (1) verify calculated and measured energy performance using high-resolution or smart meter data, (2) clarify responsibilities across national and local levels, integrating MEPR verification into mandatory inspections and post-occupancy monitoring, (3) strengthen operational energy management by extending accountability and promoting post-occupancy feedback, and (4) improve energy performance certificate (EPC) reliability through standardised, measurement-based methodologies to support compliance, evaluation, and user engagement. • Longitudinal study of housing developers' engagement with MEPR in Sweden. • Developers' agency and capacity shift and often decline over time. • Only one-fourth of the buildings met the local MEPR of 60 kWh/m 2 per year. • MEPR verification must go beyond design to measured data. • Clearer accountability across EPBD policy levels is needed.