CEE schemes and lighting: what can still be funded in 2026

Funding a lighting project through Energy Savings Certificates (CEE) changed in nature in February 2026. Three standardised schemes that covered the replacement of luminaires with LED modules were removed. Other operations remain available, but with narrower scopes and stricter evidence requirements. For a maintenance manager, an industrial site director or an elected official preparing a renovation, the question is no longer just how much a file can bring in, but by which route it can still be put together. This article sets out how the scheme works, the schemes still usable, the rule of the active and incentive role, the timetable to follow and the documents required.

The CEE mechanism in a few lines

The Energy Savings Certificates scheme is based on an obligation imposed by the French State on energy sellers, known as the obligated parties. Each obligated party must justify, over a given period, a volume of energy savings expressed in kWh cumac, that is, in kilowatt-hours cumulated and discounted over the conventional lifetime of the equipment installed. To meet this obligation, the obligated parties fund works carried out by third parties: companies, local authorities, industrial firms, farms.

Two routes coexist. The first goes through the standardised operation schemes, reference documents published by order that describe a standard operation, its technical conditions and its flat-rate savings. The second, the specific operation, applies to projects that fit no scheme and must then be calculated case by case.

The sixth period of the scheme covers 1 January 2026 to 31 December 2030, set by decree no. 2025-1048 of 30 October 2025 and implemented by the order of 21 December 2025. It comes with tighter controls and a stricter doctrine on the creation and maintenance of schemes, which largely explains the changes described below.

What changed for indoor lighting in February 2026

The order of 23 February 2026 removes three standardised operation schemes dedicated to luminaires with LED modules:

• BAT-EQ-127 · Luminaire with LED modules, commercial sector
• IND-BA-116 · Luminaires with LED modules, industrial sector
• BAR-EQ-110 · Luminaire with LED modules with a control device for common areas, residential sector

The removal takes effect the day after publication in the Official Journal. In practice, an operation committed from that date no longer falls under these schemes. The reason given by the administration lies in the many reports of abuses and suspected fraudulent practices on quotations and invoices: oversized power ratings, equipment delivered without installation, old luminaires not removed.

The text provides for a strict transitional mechanism. Applicants had to submit the list of operations already committed under these schemes within ten calendar days of publication, extended to twenty-one calendar days for operations concerning the State, local authorities, their groupings and their public bodies. The old schemes continue to apply only to the operations appearing in these lists.

In other words, for a relamping project in offices, a workshop or a warehouse launched today, there is no longer a standardised scheme dedicated to the replacement of luminaires. This does not mean the project loses all economic interest: the performance of current equipment, around 170 lm/W for a GALAXY HP linear luminaire, produces a gain that shows directly on the bill. We detail the real significance of this indicator in our article on the luminous efficacy of a 200 lm/W luminaire.

The schemes still available for a lighting project

RES-EC-104 · renovation of outdoor lighting

This scheme covers the removal of existing luminaires and their replacement with new luminaires with LED modules, or the refitting of existing luminaires with an LED module and auxiliary gear assembly. It was substantially revised by the order of 24 November 2025, applicable to operations committed from the day after its publication in the Official Journal.

Two major restrictions follow. The beneficiary must now be the State or one of its public bodies, or a local authority, a grouping of local authorities or an attached public body. The scope is limited to public lighting. Decorative illuminations and the lighting of sports grounds remain excluded.

The technical conditions concern a closed optical assembly with a minimum ingress protection rating of IP 65, luminous efficacy and upward flux thresholds defined by the version of the scheme in force, an automatic device preventing daytime switching on, night-time dimming, and compliance with the requirements of the NF EN 13201 series of standards. Proof of collection and treatment of the removed luminaires is required, and the operation is subject to inspection by an accredited body. The luminaires for traffic routes in the Rexylum catalogue are designed for this regulatory framework. The method for running such a project is described in our article on LED public lighting renovation in municipalities.

RES-EC-103 · power variation in outdoor lighting

Entitled "Installation of a power variation system in outdoor lighting", this scheme rewards adding a dimming function to an existing installation, with centralised control from the cabinet or decentralised point-by-point control. Its conventional lifetime is twelve years. As with RES-EC-104, sports lighting and decorative illuminations are outside its scope. The proof of completion must state the regulated installed power, the make and reference of the system, the precise address of the works and the age of the installation.

BAT-TH-116 · BMS, when lighting becomes a controlled package

The title of this scheme explicitly mentions lighting: "Building management system for heating, domestic hot water, cooling/air conditioning, lighting and auxiliaries". It applies to existing commercial buildings and requires the installed system to reach class A or B within the meaning of the NF EN ISO 52120-1 standard. Its conventional lifetime is fifteen years.

It is now the most direct route for funding a commercial lighting project, provided it is treated as a building management package and not as a simple equipment replacement. This requires a consistent control architecture, a subject we cover in our article on DALI and KNX control systems, and natively communicating luminaires such as the Vertigo Sensor panel. The rest of the Rexylum commercial range connects to these protocols.

The specific operation, the route outside the schemes

When no scheme fits, the project can be funded as a specific operation. The file is then based on an energy audit compliant with the NF EN 16247-1 standard, carried out less than four years before the operation is committed, and on a documented reference situation from which the savings are calculated. The file is submitted to the national Energy Savings Certificates office. This route is more demanding in engineering, but it remains open to large-scale lighting projects.

Who can benefit

Two roles must be distinguished. The beneficiary is the project owner who has the works carried out: commercial company, industrial firm, farm, local authority. The applicant is the obligated party, its delegate or its agent, the only party entitled to submit the certificate application. Since the revision of RES-EC-104, the status of the beneficiary determines access to this scheme: a private car park operator can no longer use it, whereas a municipality can, for its roads as well as for its sports facilities (gymnasiums, multi-sports halls), large consumers that are often eligible.

The active and incentive role, the rule that sinks files

The active and incentive role, often abbreviated RAI, is the condition most frequently found wanting during inspections. Article R. 221-22 of the French Energy Code provides that the applicant makes a direct contribution to the decision to undertake the works: grant, voucher, subsidised loan, audit or personalised advice.

The chronology is imperative. This contribution must take place before the operation is committed. The commitment date corresponds to the date on which the beneficiary accepts the works contract, in practice the signature of the quotation or purchase order. A tolerance of fourteen days after commitment exists, but it is reserved for private individuals and co-owners' associations: it applies neither to companies nor to local authorities. A quotation signed before the CEE offer makes the file unrecoverable, whatever the quality of the works carried out.

The timetable to follow

| Stage | Point to watch |

| --- | --- |

| 1. Diagnosis and photometric study | Establishes the reference situation and the expected gain |

| 2. Identification of the scheme or the specific route | Check the version in force at the commitment date |

| 3. CEE offer signed by the beneficiary | Materialises the RAI, must be dated and prior to the quotation |

| 4. Signature of the quotation | Sets the commitment date of the operation |

| 5. Works and invoice | Mandatory information to check before payment |

| 6. Sworn statement and submission | Signed by the beneficiary and the contractor |

Remember the simple rule: the file is put together before the works. No retroactive regularisation is allowed.

The documents required

• Proof of the active and incentive role, dated and signed by the beneficiary.
• The sworn statement complying with the scheme template, signed by the beneficiary and by the contractor who carried out the works.
• The detailed invoice, stating the nature of the operation, the quantities, the make and reference of the equipment, the precise address of the site and the dates.
• The manufacturer's technical documentation certifying the characteristics required by the scheme.
• For outdoor lighting, proof of collection and treatment of the removed luminaires.
• For a specific operation, the energy audit and the savings calculation note.

These documents are archived by the applicant and can be checked during an on-site inspection ordered by an accredited body. The ministry's official questions and answers specify the expected content of each application.

Starting from the real gain, not the flat rate

The disappearance of the indoor lighting schemes puts the energy calculation back at the centre. A project is no longer justified by a flat rate, but by a measured difference between an existing installation and a target installation: installed power, operating hours, real effect of presence detection and dimming, illuminance levels to be maintained. This is precisely the purpose of a photometric study carried out before purchase, which provides both regulatory compliance and a calculation basis that can be presented to a funder.

Frequently asked questions

Can relamping in a warehouse still obtain a CEE grant in 2026?

Not under a standardised scheme dedicated to luminaires, as scheme IND-BA-116 has been removed. Funding remains possible if the project is part of a wider package falling under another scheme, or through the specific operation route based on a compliant energy audit.

Can a municipality still fund the renovation of its public lighting through CEE?

Yes. Scheme RES-EC-104 remains open, and since its revision it is reserved for the State, its public bodies and local authorities. The technical conditions and traceability obligations are demanding, and the operation is subject to inspection by an accredited body.

Can a CEE file be submitted after the works are completed?

No, not if the active and incentive role was not formalised before the quotation was signed. Proof of the RAI must predate the commitment of the operation. A file put together after the event is rejected, even when the works are technically flawless.

Is the lighting of a sports ground eligible for a standardised scheme?

Schemes RES-EC-103 and RES-EC-104 explicitly exclude the lighting of sports grounds from their scope. A sports project must therefore be examined from the angle of a specific operation or another financing arrangement, according to the regulations in force at the time of commitment.

Having your project costed

Calculating an energy gain that can be presented to a funder and choosing the funding route are engineering work, not a spreadsheet exercise. Get in touch with our technical partner, the Luminance-Consulting agency, a lighting solutions consultancy since 2013. Its design office carries out the audits, the photometric studies in DIALux and the regulatory compliance checks needed to put a file together.

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