Green Key, the eco-label run by the Foundation for Environmental Education (FEE), has changed how hotels are certified. From 1 October 2026 the programme is operating under new criteria for 2026 to 2031, a new certification process and a separate certification body. In a statement published on 2 October, Green Key said the changes were designed to align the scheme with the European Union’s Empowering Consumers for the Green Transition Directive, known as EmpCo.

EU member states have had to apply the measures implementing Directive (EU) 2024/825 since 27 September 2026.

What changed on 1 October

FEE remains the scheme owner and continues to write the criteria. Certification decisions have moved to Audit Independer Group, which FEE appointed as Green Key’s independent certification body with effect from 1 October. Audit Independer now handles agreements with third-party auditors and their assignment, certification decisions, surveillance, suspension and withdrawal, and appeals and complaints.

The directive tightens the rules on environmental claims made to consumers. Green Key says its scheme is open on transparent and non-discriminatory terms, has criteria developed with experts and stakeholders, has procedures for suspension or withdrawal, and is monitored by third-party auditors. FEE submitted the scheme to DANAK, the Danish national accreditation body, and says it received confirmation on 25 September 2026 that the scheme is aligned with ISO/IEC 17065:2012 and suitable for accreditation.

What a hotel now has to do

The published certification process has five steps: application, on-site audit, certification decision, ongoing conformity and renewal. The details that matter at property level are these:

  • Certificates are valid for two years, up from 12 months.
  • The on-site audit typically lasts two to six hours, depending on the size of the property and its headcount.
  • An audit with one to five non-conformities gives the hotel two months to supply further evidence. More than five triggers a follow-up on-site audit, with the extra audit and travel costs paid by the hotel.
  • A surveillance check takes place 8 to 14 months after certification. It is document-based and covers criteria selected by Green Key.
  • Hotels pay a Green Key levy at application and annually, an annual certification body fee, and the auditor’s costs. Green Key does not publish amounts on its process page.

The new catalogue covers six categories of establishment, including hotels and hostels, small accommodations, conference centres and restaurants, across seven criteria areas. Applicants must meet every imperative criterion plus a share of guideline criteria that rises with each certification period.

Transition to the end of 2027

All new applicants are assessed against the 2026 to 2031 criteria from 1 October. Properties certified under the 2022 to 2026 criteria stay on them until they apply for re-certification, and the transition closes no later than 31 December 2027. National operators set country-specific timelines.

During the transition the guideline threshold is eased to the next lower percentage in the new system. Green Key’s example is a property entering its fourth year, which would have needed 15% of guideline criteria under the old rules and needs at least 10% in transition. Re-applicants must supply at least six months of data during the transition. After it, evidence must cover the last two full calendar years where required. A hotel that cannot reach the required percentage can apply for a dispensation for one certification period, which the certification body must confirm.

THD’s reading

  • THD analysis, for operators: the two-year cycle lowers audit frequency but raises the evidence burden. Two full calendar years of energy, water and waste data will be expected once the transition ends, so metering and record keeping need to be in order now, not in the month before the audit.
  • THD analysis, for owners and brands selling into the EU: EmpCo makes the standing of the scheme behind a label a legal question, not only a marketing one. Green Key has set out its case for conformity. Hotels using other labels, or in-house badges, should ask their scheme owner for the equivalent statement.
  • THD analysis, for budgets: there are now three cost lines, the levy, the certification body fee and the auditor, and none is published centrally. Ask the national operator for a full quote, including the cost of a failed first audit.
  • THD analysis, on timing: DANAK’s confirmation says the scheme is suitable for accreditation. Green Key’s statement does not say accreditation has been granted, and that distinction is worth watching.