We presented the decree of July 13 on VAT at 5.5% for air/air PACs. A new decree of August 14, 2026, published in the Official Journal of September 9, modifies it by adding a single word.
There VAT at 5.5% on air/air heat pumps is changing barely two months after the publication of the first eligibility criteria. The new decree, signed on August 14 and published in the Official Journal on September 9, 2026, modifies the wording of the text concerning the minimum performance required for devices over 12 kW. A correction which, behind a single word, “except”, significantly changes the reading of the device.
An “except” that changes the rules for roof heat pumps
The text on VAT at 5.5% applicable to air/air PACs has just been modified. Article 1 of the new decree of August 24 indicates: in i of b of 1o bis of article 30-0 D ter of annex IV to the general tax code, introduced by article 1 of the aforementioned decree of July 13, 2026, after the word “cooling” is inserted the word “except”. Let us therefore refer to the text of the decree of July 13. He indicated about theminimum energy efficiency of air/air heat pumps with a power greater than 12 kW so that they are eligible for VAT at 5.5% : “145% for heating and 250% for cooling in the case of a roof air/air heat pump“. According to the new decree of August 24, it must now read “145% for heating and 250% for cooling, except in the case of a roof air/air heat pump“.
Which means, if we have understood correctly, that if the air/air heat pump of more than 12 kW is installed on the roofit is no longer subject to minimum performance requirements for benefit from the VAT rate of 5.5%.
The vagueness persists for multifunction heat pumps
On the other hand, the following paragraph of the July decree, still relating to air/air heat pump over 12 kW : “ii) 130% for heating and 150% for cooling in the case of a roof air/air heat pump integrating heating, cooling, ventilation, cooling by nighttime superventilation and filtration” is not modified.
Regarding the air/air heat pump over 12 kWtheir status vis-à-vis the VAT at 5.5% was not very clear before, it seems to me that it is even less clear now. The nonsense was just moved.
The text therefore maintains the special case of roof heat pumps integrating heating, cooling, ventilation, cooling by nighttime superventilation and filtrationto which the thresholds of 130% for heating and 150% for cooling remain applicable. The drafting therefore results in a situation that is, to say the least, singular: a Roof heat pump can escape the first level of performance, while remaining subject to a second level when it combines several functions.
The correction therefore clarifies a drafting point, but it does not remove the difficulty of interpretation for the Air/air heat pump over 12 kW. Between the exception introduced for roofing equipment and the maintenance of a specific threshold for multifunctional systems, the tax regime remains particularly difficult to read for professionals.
