England has Part R. Europe has the Gigabit Infrastructure Act. What now?

A building has to meet requirements for fire safety, ventilation, energy performance, electrical systems and structural integrity. These requirements have become self-evident. Nobody delivers an office or residential building without having these elements assessed. But what about digital infrastructure?

At a time when organisations depend on cloud software, video calling, AI, IoT, smart building technology, access control, data platforms and real-time monitoring, digital connectivity has become just as essential as electricity. Yet the digital delivery level of real estate is still only made structurally visible to a limited extent.

That raises a simple but uncomfortable question: why do we check whether a building is energy efficient, but not, as a matter of course, what it can digitally handle? England has partly answered that question with a specific part of its building regulations, and Europe now does so as well. In this article we look at Part R, at the European rules, at what the Netherlands can learn from them, and at the step that follows.

What is Part R, explained simply?

The British Building Regulations include a separate part on Infrastructure for electronic communications. This part is called Part R and is elaborated in the accompanying Approved Document R, published on GOV.UK. It focuses on the physical infrastructure needed to enable fast electronic communication networks in buildings.

Concretely, this involves facilities that prepare the building for fast connections, such as:

• conduit routes for telecom and data;
• physical infrastructure through which cables can be pulled;
• connection points where networks enter the building;
• facilities that enable high-speed or gigabit connectivity.

Since 26 December 2022, Part R goes one step further. New homes get not only gigabit-ready infrastructure, but also a working gigabit connection, with a cost cap of £2,000 per home.

With Part R, England has taken an important step: digital infrastructure becomes part of the built reality. It is no longer something arranged only after delivery, but a basic facility incorporated into the construction. In other words, a building's digital connection no longer begins only when the tenant takes out an internet subscription. The foundation must already be present in the building.

An important nuance: Part R is not the same as the IT-Label

It is tempting to read Part R as a complete answer to the digital question. It is not, and it does not need to be. Part R primarily safeguards an important physical foundation for electronic communication. It ensures that the digital highway can reach the building. What happens inside the building after that remains largely out of view.

This is exactly where the difference with the IT-Label lies. Where Part R checks whether connectivity is possible, the IT-Label looks at the actual digital delivery level of an existing or new building. The question is therefore not only whether fibre or fast internet can reach the building, but also what actually comes in and what the building does with it.

Consider questions such as:

• What capacity actually enters the building?
• Is there redundancy in the connections?
• How is the internal cabling structured?
• What is the quality of the MER and SER rooms?
• How is the Wi-Fi organised and how is coverage arranged?
• Are networks segmented?
• How is physical access to digital infrastructure arranged?
• Are systems monitored and are responsibilities documented?
• Is the building suitable for IoT and future data consumption?
• Is the building prepared for AI applications?

The core can be captured in one sentence: Part R checks whether the digital highway can reach the building, the IT-Label checks what happens inside the building after that.

A building can be technically ready for fibre and still be barely usable digitally. Preparation is not the same as performance.

Europe also has rules

The United Kingdom did not introduce these rules out of nowhere. The first version of Part R, from 2017, was the British implementation of a European directive. Since 2017, Directive 2014/61/EU has already required high-speed-ready in-building infrastructure in new and extensively renovated buildings. Since 12 February 2026, the Gigabit Infrastructure Act (EU) 2024/1309 applies. Under Article 10, new and extensively renovated buildings must be fibre-ready. In the Netherlands, this has been laid down since 27 March 2026 in Article 4.245 of the Besluit bouwwerken leefomgeving (Bbl). Read more in our article about the Gigabit Infrastructure Act and the fibre-ready building.

But here a commercial nuance matters. Regulation does not automatically say anything about the actual digital delivery level of an individual building. The Gigabit Infrastructure Act also mainly regulates preparation: the building must be fibre-ready. It does not measure how well it works, and nothing applies to existing buildings without a major renovation. What happens in a specific building's wall, patch cabinet or server room remains out of view.

A building can be technically prepared for fibre while at the same time relying on outdated CAT cabling, poor patch cabinets, insufficient Wi-Fi, no redundancy, poorly secured server rooms, unknown external connections, missing documentation and unclear responsibilities. This is precisely where the added value of an objective assessment of the digital delivery level arises.

The comparison with the energy label

The energy label taught real estate professionals to make energy performance objectively visible. What used to be a vague impression is now a classification everyone understands and takes into account in a transaction. The IT-Label does the same for digital infrastructure.

The energy label tells you how energy efficient a building is. The IT-Label tells you what a building can digitally handle. We now accept that energy performance should be visible. Why would that be any different for digital performance? Anyone following the comparison between the energy label and the IT-Label sees that this is the same movement: making invisible quality measurable and comparable.

Moreover, the two worlds are becoming increasingly intertwined. Smart energy management increasingly relies on sensors, IoT, building management systems, real-time monitoring, data analysis and automatic control. Without reliable digital infrastructure these applications cannot function optimally. That is why the energy label and the digital delivery level increasingly go hand in hand.

From utility to digital utility

Digital connectivity has effectively become a modern utility. An office without water is unusable. An office without electricity is unusable. And for almost every modern organisation the same now applies: an office without reliable digital connection is unusable.

Seen this way, internet, data and digital connectivity increasingly form the fourth utility of commercial real estate. And as with the other three, quality varies from building to building and deserves to be made visible in advance. This is exactly why internet has become the lifeline of commercial real estate, no longer a side issue in the delivery file.

Smart buildings make this more urgent

Smart buildings can only function when the digital foundation is right. The chain is easy to follow: digital infrastructure leads to connectivity, connectivity produces data, data feeds IoT, IoT enables smart control and smart control makes a building genuinely smart. If that chain breaks at the start, the rest does not work.

At the same time, real estate produces and consumes increasing amounts of data. Not only do organisations use more data, buildings themselves are also becoming major data consumers. Think of sensors, cameras, access control, climate installations, charging infrastructure, energy monitoring, building management systems and AI applications. The concept of data consumption is thereby becoming just as relevant as the number of square metres.

The question that follows is confronting: is your building actually ready for the amount of data it will use in five or ten years? The digital lifespan of a building is shorter than its structural lifespan, and this difference is often overlooked at delivery.

Is your office AI-proof?

AI increases dependence on cloud infrastructure, internet connections, stable networks, data traffic and digital security. Applications that still seem experimental today will become part of daily work within a few years. This places higher demands on the digital foundation of the building in which that technology must run.

The question of whether an office is AI-proof is therefore not only about software or computers. It starts with the building. A stable, redundant and well-documented digital infrastructure determines whether AI applications can function reliably, or whether they repeatedly stall on a network that was not designed for it.

Where the IT-Label helps

The IT-Label makes the digital delivery level of commercial real estate understandable, with a classification ranging from IT5 SHELL for a building without digital infrastructure to IT1+ PREMIUM for an AI-ready building. This allows every party to see at a glance what a building can handle, without needing to be a technical specialist.

The IT-Label as a digital MOT

The IT-Label can be applied at the key moments in the life cycle of real estate: at letting, renting, purchase, sale, renovation, new construction, conversion and during a Digital Due Diligence. At each of these moments you want to know the digital reality before making a decision.

Think of it as the digital MOT of real estate. The aim is to make visible what is often only discovered after a tenant has already signed or a renovation has already started. Not discovering afterwards what is digitally missing, but knowing in advance what a building can handle.

In this way, the IT-Label is not an afterthought but a starting point. It gives owners, investors, agents, tenants and lawyers the same factual basis to discuss the digital quality of a building.

Will Europe get a mandatory digital label?

So Europe already has rules for the preparation of buildings. Does that also mean that Europe will soon require a digital label for buildings? That conclusion comes too quickly. The Gigabit Infrastructure Act does give member states room to introduce a voluntary label for fibre-ready buildings. But it is not a given that regulation will take the step to a mandatory label for the digital delivery level, and it is not necessary either, to recognise the value of digital insight.

What Part R and the Gigabit Infrastructure Act do show is a clear direction. Digital infrastructure is increasingly regarded as part of a modern building rather than as a separate service. If the physical foundation officially counts, it is logical that the actual digital delivery level will also become more important in transactions, valuation and use.

The market is often ahead of regulation here. Buyers and tenants are already asking questions about connectivity, redundancy and security. Whoever can answer those questions objectively is in a stronger position. That is why many professionals see the IT-Label as a logical next step in real estate, regardless of whether a mandate ever arrives.

Take the next step

With Part R, England shows that digital infrastructure is no longer solely the domain of the IT department. It is part of the building. But physical infrastructure alone is not enough. The next question is what the building can actually digitally handle. That is where the IT-Label begins.

Do you want to know how your building performs digitally before a tenant signs or an investment is made? Start with an IT-Label pre-inspection, a full IT-Label certification or a Digital Due Diligence, and gain insight into the digital delivery level of your real estate. More background on the methodology can be found on the page how the IT-Label works.

IT-Label. Together we make visible what is still invisible today. For more information, visit www.it-label.com.