German regulations for the thermal renovation of existing homes demand high thermal standards, which the government claims are technically and economically feasible. This paper examines existing data on 3400 German homes; their calculated energy performance ratings (EPR) are then plotted against the actual measured consumption. The results indicate that occupants consume, on average, 30% less heating energy than the calculated rating. This phenomenon is identified as the ‘prebound’ effect and increases with the calculated rating. The opposite phenomenon, the rebound effect, tends to occur for low-energy dwellings, where occupants consume more than the rating. A similar phenomenon has been recognized in recent Dutch, Belgian, French and UK studies, suggesting policy implications in two directions. Firstly, using a dwelling’s energy rating to predict fuel and CO2 savings through retrofits tends to overestimate savings, underestimate the payback time and possibly discourage cost-effective, incremental improvements. Secondly, the potential fuel and CO2 savings through non-technical measures such as occupant behaviour may well be far larger than is generally assumed in policies so policy-makers need a better understanding of what drives or inhibits occupants’ decisions.