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D.M. 24/11/2025

The new building CAM: the minimum environmental criteria in force from 2026

In forceAmbiente & SostenibilitàAppalti & Contratti pubbliciLegge/DecretoCogente● Verified

Summary

TAV. 00

The Minimum Environmental Criteria for awarding design services and building works, adopted by decree of the Italian Ministry of the Environment and Energy Security on 24 November 2025 and published in Official Gazette no. 281 of 3 December 2025. They wholly replace the 2022 edition (Ministerial Decree no. 256 of 23 June 2022) and absorb its corrective decree of 5 August 2024. In force since 2 February 2026, they are mandatory in public procurement under art. 57 of Legislative Decree 36/2023.

Scope of application

TAV. 01

They apply to public awards of design and works-supervision services, maintenance services and the execution of works for building interventions: new construction, renovation, maintenance and upgrading. Compared with the 2022 edition the scope is wider: maintenance services and joint design-and-build awards are explicitly included. The earlier regime remained applicable only to integrated contracts and to works based on designs validated under it, and only where the tender notice was published within three months of validation: a window now closed.

In depth

TAV. A

They are not an environmental checklist

The word 'minimum' misleads. Minimum environmental criteria are not a level of good intentions below which it would be unseemly to fall: they are tender clauses. Article 57 of the Public Contracts Code requires their application in public procurement, and that turns them from an objective into a requirement — a bid that fails them is not a less green bid, it is a non-compliant one.

Everything else follows from this, including why they concern the designer before the contractor. A substantial part of the criteria is either met or lost at design stage: if the design does not prescribe what is needed, and does not set out how it will be demonstrated, there is no recovering it on site — one can only observe that the requirement is not verifiable.

Where they enter the procurement cycle
  1. 01
    In the tender documentsThe contracting authority invokes them: from that moment they are contract content, not a recommendation. The designer drafting the specification is writing the bid-admissibility criteria.
  2. 02
    In the designThe choices the criteria govern — materials, performance, disassemblability, waste management — must be made here. It is the stage where they cost little and after which they can no longer be made.
  3. 03
    In the assessment of bidsThe operator demonstrates compliance with the documentation required. A criterion written without stating which document proves it is a criterion that will generate disputes.
  4. 04
    In execution and handoverThe criteria follow the site through to delivery: the products actually installed must be those declared, and waste traceability must be documented as it happens, not reconstructed at the end.

What changes from the 2022 edition

The previous edition — Ministerial Decree 256/2022, with its corrective of 5 August 2024 — is replaced in full, and the new text absorbs that corrective rather than layering over it. The most visible change is breadth: maintenance services and joint design-and-build awards are explicitly included, two cases that in practice cover much of the work on existing building stock.

The main shifts
FrontDirection of change
ScopeFrom design and works to design, works, maintenance and joint awards.
Legal alignmentAligned with the 2023 Public Contracts Code, which did not yet exist in 2022.
Construction productsGreater weight on environmental product declarations and on their verifiability.
End of lifeConstruction and demolition waste management treated as a documentary requirement, not an intention.
Social criteriaSite personnel conditions and ESG profiles enter the criteria alongside the environmental ones.
Editorial summary of the framework: for the precise content of each criterion the decree and its annexes govern.
UPDATE

The transitional window is closed. The 2022 regime remained applicable only to integrated contracts and to works based on designs validated under it, and only where the tender notice was published within three months of validation. Anyone setting up a tender today works on the 2025 text.

The point that gets underestimated: the proof

The CAM do not merely ask that something be true; they ask that it be demonstrable with a defined document. This is where the real problems concentrate: a material can be excellent and still be unusable for the tender because the manufacturer has no environmental product declaration, or has one drawn up under different product category rules than those required.

Environmental product declarations are drawn up under the rules of UNI EN 15804, which sets what an EPD must contain and how it must be calculated so that two products are comparable. That link is what makes the CAM verifiable rather than declaratory, and it is also where they connect to the EU Taxonomy and to the construction products regulation: the same declaration serves several regimes.

Where a criterion is lost without anyone noticing

A specification prescribes an insulant with a minimum recycled content and refers generically to 'manufacturer documentation'. Three bids arrive: one with an EPD compliant with the product category rules required, one with a self-declaration, one with a recycled-content certification from a different scheme. The contracting authority has no written criterion for deciding which counts, and the tender stalls. The defect was not born in the tender: it was born in the specification, the day the requirement was written without writing the proof.

Key points

TAV. K
  • They wholly replace the building CAM of Ministerial Decree no. 256 of 23 June 2022, repealed from 2 February 2026.
  • Mandatory in public procurement: art. 57 of Legislative Decree 36/2023 requires their application, so failing them means failing the tender.
  • Wider scope: alongside design and works, maintenance services and joint design-and-build awards are now included.
  • Aligned with the 2023 Public Contracts Code, with changes on design, construction products, waste management, ESG criteria and site personnel.
  • The life-cycle logic remains the pivot: they rest on EPDs to UNI EN 15804 and connect to the EU Taxonomy and the new CPR.

Frequently asked questions

TAV. Q
From when do the new CAM apply?

From 2 February 2026, sixty days after publication in the Official Gazette of 3 December 2025. The earlier rules remained applicable only to integrated contracts and to works based on designs validated under the old regime, with the tender notice published within three months of validation: a window that is now closed.

What happens if a design still follows the 2022 CAM?

Outside the transitional regime, it does not comply with the CAM in force. Since art. 57 of Legislative Decree 36/2023 requires their application in public procurement, the practical effect is failure to meet the tender requirements. It is the costliest mistake to make with this decree, and an easy one, because many guides and specifications still in circulation carry the 2022 edition.

Do the CAM apply to private building too?

Not directly: they are an instrument of public contracting. They do become relevant, however, for private works accessing incentives or financial instruments that refer to them, and they are by now a recognised benchmark outside procurement too for setting a threshold of environmental quality.

Where can the detailed criteria be read?

In the text of the decree and its annexes, published in the Official Gazette and freely available at the source given in this entry. It is a ministerial decree, therefore a freely reproducible text: it may be cited and summarised without restriction, unlike the UNI standards it refers to.

Details

Body
Ministero dell'Ambiente e della Sicurezza Energetica (MASE)
Type
Legge/Decreto
Binding
Cogente
Level
Nazionale
Year
2025
In force
2 Feb 2026
Read the official text (free) ↗
gazzettaufficiale.it ›
Last verified: 12 Aug 2026
Editorial status: Verified
Chronology
ReplacesD.M. 23/06/2022Minimum Environmental Criteria for construction (CAM)
Related regulations
ImplementsD.Lgs. 36/2023Public Contracts Codeart. 57: the article that makes the CAM mandatory in procurementRefers toUNI EN 15804UNI EN 15804: the rules for Environmental Product Declarations (EPD)product EPDs are drawn up to this standard

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