Missing EPC and certificate of habitability: what it means for the buyer
It is the most widespread risk after unauthorised building work and occupation, and almost nobody explains it.
Of 13,474 auction properties with an analysis of the appraisal report, 5,813 have missing or incomplete certificates: 43%, two in five. And yet “no APE” and “no agibilità” end up on the same line of the report as if they were the same thing.
They are not at all.
The EPC: a nuisance, not a problem
The Energy Performance Certificate (APE) says how much energy the property consumes. It is obtained from a qualified technical professional who inspects the property and files the certificate: a few days’ work and a few hundred euros.
If it is missing, it gets redone. There is nothing to regularise, nothing to ask the municipality, no risk that it cannot be done.
It is worth knowing that the EPC does not describe a state of compliance: a property rated G is perfectly legitimate, it just consumes a lot. Finding a low rating in the appraisal report is not a legal alarm bell; it is information about the costs you will have.
Whether the EPC must be attached to the transfer decree is a technical question best put to the delegate, because practice is not uniform. From the buyer’s point of view little changes: you need the certificate anyway to resell or let, and it can be redone.
Certificate of habitability: a different story altogether
Here things change completely.
The certificate of habitability (agibilità) — today a certified notification, once a habitability licence — certifies that the property meets the requirements to be used: ceiling heights, light and ventilation ratios, systems, healthiness. It is the document that says this is a place where people can live.
When you read in the appraisal report that there is no record of the certificate of habitability, there are three possibilities, and they are very different from one another.
It was never applied for, but the requirements are met. This happens with old properties, built when practice was less rigorous. The application is filed, a technical professional certifies it, and the matter is closed. It costs money, but it is a formality.
It is missing because the property does not meet the requirements. Insufficient ceiling heights, basement rooms used as living space, windows too small for the floor area. Here it cannot be obtained until work is done on the property, and in some cases it cannot be obtained at all.
It is missing because there is unauthorised work behind it. The certificate of habitability follows building compliance: if the work is not compliant, it does not come. This is the case where the problem is not the certificate but what lies beneath it.
The appraisal report does not say which of the three it is. A technical professional tells you, after accessing the records at the municipality.
Why it matters, in practice
The mortgage. Banks ask for the certificate of habitability in the loan application. Without it, processing gets complicated or stops — and if your plan involves a mortgage for the balance, this must be checked before bidding, not after the award.
Resale. Whoever buys from you will ask for the same documents you should have asked for. A property without a certificate of habitability does sell, but it sells for less, and to people who know what they are buying.
Use. A property that does not meet the requirements is not simply missing a piece of paper: it is a property that, on paper, is not fit to be lived in. The gap between this and “I’ll live there anyway” is a gap that can prove costly at the first inspection or the first insurance claim.
Letting. When you let the property, especially with registered contracts and for residential use, the missing certificate weighs heavily.
What to look for in the appraisal report
The section on documentation lists what the expert found and what they did not. Three things to pick out.
The exact wording. “Not found” and “not issued” are not synonyms: the first says the expert did not find it, the second that it does not exist. The difference is huge, and experts word it carefully.
The construction date. Properties built before 1934, or very old ones in general, are subject to different regimes, and the absence of the certificate may be entirely normal.
Whether the expert links the missing certificate to an irregularity. When the certificate is missing because there is unauthorised work, the expert almost always says so. That sentence is worth more than the rest of the paragraph.
How much it costs to sort out
Nobody can give you a figure before checking, but orders of magnitude help you decide whether to dig deeper.
An EPC is a few hundred euros. A habitability application for a property that meets the requirements is a few thousand, between the technical professional, fees and sworn certifications. A property that does not meet the requirements needs work, and at that point you leave the paperwork behind and enter the building site.
The only way to know beforehand is to have a technical professional look at the appraisal report and the permits. It costs a fraction of what it costs to find out afterwards.
Frequently asked questions
Can I buy a property without a certificate of habitability at auction? Yes. The transfer takes place regardless. The problem is not buying it; it is using it, mortgaging it and reselling it.
The EPC is missing: is that serious? No. A qualified technical professional can redo it in a few days.
Who pays to obtain the certificate of habitability? The buyer.
Is a missing certificate of habitability always visible in the appraisal report? Almost always, but it is not guaranteed: the analysis covers part of the catalogue and the appraisal report may be out of date. The absence of a warning is not confirmation of compliance.
If the property is lived in, does that mean it is habitable? No. The fact that someone lives there says nothing about the paperwork.
Data as at 15 September 2026, calculated on active properties with an analysis of the appraisal report available. The filter by appraisal tag returns “the lots where our analysis flagged the missing certificate”, not all the lots that are missing it: coverage is partial and high-precision. What emerges from the appraisal report and the documents always prevails.