EU legislation provides for extensive involvement of local governments (LGs) in the implementation of the "energy first" principle concerning buildings’ stock. LGs have a dual role. In the role of national government agents LGs co-financing is necessary for implementation of global goals. In the role of autonomous decision makers LGs are balancing various interests on behalf of local community. The aim of the research is to assess the characteristics of those interest groups that are short- and medium-term beneficiaries or losers from the EU recommendations and the risks arising from the choice of alternatives. Interests of groups are evaluated by the approximation of the Rational Choice Theory, considering diversity of competences division among national and subnational authorities. Evaluated alternatives: 1) security in the event of war versus voluntary initiatives for energy efficiency; 2) prolonging regeneration of woods’ biomass versus electrification of heating; 3) supporting entrepreneurship versus reduction of energy poverty; 4) individual or energy community solutions versus uniform treatment of all DHSs customers; 5) postponing versus acceleration of the electrification of transport; 6) re-municipalisation versus outsourcing buildings stock and its infrastructure renovation. Losers of energy performance policy should be compensated in the short and middle term, because possible future gains may be insufficient to maintain stability.