The modulation technical file is a mechanism provided for in the tertiary decree allowing’adapting energy consumption reduction targets when these cannot be reached under standard regulatory conditions.
This is neither an exemption nor an automatic postponement, but rather a "one-off". framed system, based on documented technical, economic and asset analyses.
Its goal: set a realistic, justified trajectory that complies with, taking into account the specific constraints of each building or site.
What is the purpose of a technical modulation file?
The modulation file demonstrates that, despite the implementation of relevant and proportionate actions, meeting regulatory targets is not possible according to the methods laid down in the decree.
It serves several purposes:
- Objectivating constraints specific to a reporting functional entity (RFE) ;
- Analyze the levers for improvement that can really be mobilized; ;
- Demonstrate the residual gap between regulatory targets and achievable performance; ;
- Secure regulatory compliance by the deadline in question.
The file thus constitutes a security tool, which can be used in the event of a subsequent inspection or justification.
What are the deadlines for submitting a modulation file?
The technical modulation file is part of the ten-year logic of the tertiary sector decree.
For the first deadline :
- Objective 2030 → dossier to be submitted before September 30, 2027
The same principles will apply thereafter:
- For the 2040 deadline → filing before September 30, 2037 ;
- For 2050 → deposit before September 30, 2047.
The file can be updated in the event of changes in assumptions, usage or actions undertaken.
In which cases is it possible to modulate targets?
Modulation is only admissible in situations precisely defined by the law.
It must be explicitly justified and does not apply automatically.
Technical constraints
Certain building configurations objectively limit the energy gains that can be made (structure, networks, existing equipment).
Modulation is then based on a reasoned technical note, based on energy analyses.
Architectural or heritage constraints
When conservation obligations (façades, volumes, materials, heritage prescriptions) prevent certain actions, modulation can be based on a detailed opinion from a competent professional.
Economic disproportionality
The regulations also provide for modulation when the gross return on investment of actions exceeds certain thresholds, after deduction of available aid.
Regulatory thresholds include :
- Building envelope: 30 years ;
- Energy equipment: 15 years ;
- Steering and management systems: 6 years.
In this case, the dossier must demonstrate that the actions envisaged do not enable the objectives to be achieved without manifest disproportion.
Modulation, adjustment, automaticity: clearly distinguishing mechanisms
Not all lens adaptations require a technical file.
- Automatic adjustments These are linked in particular to climatic rigor or changes in activity volumes, calculated directly via usage intensity indicators.
- Documented modulations These require a formal technical file, validating the impossibility of achieving the objectives.
This distinction is essential to avoid unnecessary or incomplete procedures.
What should a technical modulation file contain?
The content of the file is governed by the decrees implementing the tertiary decree.
It is based on a structured energy analysis, adapted to the perimeter concerned.
Elements common to all modulation
- An energy study describing the reference situation; ;
- Identify existing constraints; ;
- Analysis of technically feasible actions; ;
- Estimated energy savings and avoided emissions; ;
- A coherent, prioritized action plan.
Specific elements depending on the type of modulation
Depending on the basis for modulation, the file includes :
- A detailed technical note (technical constraints) ;
- A detailed opinion (architectural or heritage constraints) ;
- An economic calculation (return on investment).
The set is accompanied by standardized summary files, filed on the OPERAT platform.
At what scale should the dossier be drawn up?
The modulation file is built to scale. the most relevant function, depending on the configuration of the estate.
Building level
Suitable for :
- Multi-purpose ;
- Multi-occupancy ;
- Heterogeneous functional zones.
Site level
Relevant when the CPE groups together several buildings of different ages, uses or performance levels.
In this case, the study can be based on subset approaches or by sampling.
Who can prepare a technical modulation file?
The regulations require that the file be drawn up by professionals with proven skills, especially :
- Energy consulting firms ;
- Specialized consulting engineers ;
- Architects or heritage experts, where applicable.
Need to assess the relevance of a modulation file?
An exchange of views enables us to analyze the situation, identify the levers that can be mobilized and determine whether the use of modulation is justified in light of the objectives of the tertiary sector decree.
Our teams support companies and public bodies in structuring their energy performance trajectory, from the initial analysis to the creation and securing of technical modulation files, in line with OPERAT declarations and actions undertaken.
Why anticipate modulation rather than undergo it?
A modulation file submitted late or with insufficient supporting documentation undermines regulatory compliance.
Conversely, a proactive approach allows you to :
- Securing the trajectory upstream ;
- Avoid irrelevant investments; ;
- Linking modulation, actions and financing ;
- Maintain consistency with the OPERAT declaration.
FAQ - Technical modulation file
Is the modulation file compulsory?
Only when targets cannot be met and no automatic adjustment applies.
Can I submit a single application for several modulations?
Yes, a single file can cover several modulation bases for the same CPE.
Does the file guarantee acceptance of the modulation?
No. It is used to justify the application, which must comply with regulatory requirements.
Should we wait until 2030 to start modulation?
No. The process can be anticipated to secure the trajectory before the deadline.
