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Decarbonizing your commercial assets: a 2030 trajectory steered by Kytom — KYTOM
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Decarbonizing your commercial assets: a 2030 trajectory steered by Kytom

Four regulations, a single value trajectory

Decarbonizing to reach -40% by 2030 costs between EUR 45 and EUR 180/tCO2: below EUR 95/tCO2, it is an investment with positive NPV; above EUR 150/tCO2, it is a compliance expense, not value creation. The distinction is crucial for an Asset Manager weighing up retrofit CAPEX, disposal and offsetting. Commercial real estate decarbonization accounts for 17% of national emissions (ADEME, Chiffres-cles du climat, 2024 edition), across a stock of 960 million heated m2 (INSEE, Tableaux de l’economie francaise, 2024 edition). Kytom, founded in 2006, delivers a scopes 1, 2 and 3 carbon audit in 6 weeks then manages an action plan over 12 weeks, aligned with ISO 14064, the Tertiary Decree OPERAT and the CRREM trajectory. This page details the regulatory framework, the 5-step method, results measured across 380 sites and capital allocation trade-offs.

02

The regulatory framework brings together four regulations: the Tertiary Decree OPERAT (-40% by 2030, -50% by 2040, -60% by 2050 on final energy, decree no. 2019-771), the BACS Decree on BMS (no. 2020-887), the CSRD directive applicable since 2024 to more than 50,000 European companies (European Commission, directive 2022/2464), and the green taxonomy (criterion 7.2 on renovation, regulation 2020/852).

The orders of magnitude of the stock to be transformed:

  • 960 million m2 of heated commercial real estate in France (INSEE, Tableaux de l’economie francaise, 2024 edition)
  • 38% powered by natural gas
  • 4.2% annual reduction required by the SBTi 1.5 °C trajectory (Science Based Targets initiative, Corporate Net-Zero Standard v1.2, 2024)
  • 35 kgCO2/m2/year: CRREM 2030 threshold exceeded by 65% of buildings audited by Kytom

| Framework | Metric | 2030 target |
|—|—|—|
| Tertiary Decree | kWh fe/m2/year | -40% vs reference |
| SBTi 1.5 °C | absolute tCO2eq | -42% cumulative |
| CRREM offices FR | kgCO2/m2/year | 17 |
| CSRD ESRS E1 | reporting | mandatory |

For the Asset Manager: decarbonization is a matter of asset value, not ESG. An undecarbonized asset loses between 8% and 22% of its market value by 2030, according to estimates from our partner brokers. The Tertiary Decree penalty of EUR 7,500 per site is marginal; the real risk is CRREM “stranding” which excludes the asset from Article 9 SFDR funds and erodes liquidity at disposal. The “name and shame” published on the OPERAT platform (ADEME) exposes shortcomings to institutional investors.

Contrarian position: regulatory pressure does not justify immediate investment across all assets. Contrary to the received wisdom that pushes for triggering SBTi across the entire portfolio, for a commercial real estate asset whose disposal is scheduled within 24 months, the full trajectory is not relevant: an abatement cost above EUR 120/tCO2 will not be amortized and the marginal valuation remains below 4%. In that case, favor a targeted Tertiary Decree audit with LED + BMS quick wins, and let the buyer bear the heavy retrofit.

What carbon abatement cost is acceptable for an Asset Manager?

Below EUR 95/tCO2, the investment has positive NPV over an 8-12 year horizon: managed LED + BMS (EUR 45/tCO2) and switching from gas to heat pump (EUR 95/tCO2) fall into this category. Above EUR 150/tCO2, such as envelope insulation at EUR 180/tCO2, the operation is a matter of Tertiary Decree compliance rather than value creation: the disposal/offsetting trade-off becomes relevant.

05 — Inspirations

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