How to handle the overheating risk in energy performance calculations

An energy performance regulation has to consider not only energy, but -either explicitly or implicitly- also the relevant comfort aspects: indoor air quality (IAQ), lighting level, humidity level, temperatures (summer, winter) and hot tap water availability.
After all, the easiest way to minimize energy consumption is to switch off heating, ventilation, lighting, hot tap water, ...
What is the relation with the EPBD requirements on energy performance? Is there a potential conflict? Is there a need for additional minimum comfort requirements?
There are five possible choices how to deal with each of the comfort items in the EP regulations:
ignore comfort level, fixed comfort level, neutralise comfort level, penalty for bad comfort or a prescriptive requirement.
Depending on the comfort aspect, a chosen solution may lead to unwanted consequences, such as risk of under-provision or over-provision; stimulation of low comfort levels, none or a bad relation between EP and real comfort level and system sizing and operation), loss of integrated approach.
This paper discusses the consequences more in detail, as a basis for proper choice and further thought, focussing on space heating and cooling.
Also the relation is shown with the main relevant CEN standards on the EPBD, being developed under the EU Mandate 343.