Energy Performance of Buildings regime reform under consultation
Changes to Energy Performance Certificates, Display Energy Certificates and Air Conditioning Inspection Reports are under consultation.
The government seeks views on changes to Energy Performance Certificates, Display Energy Certificates and Air Conditioning Inspection Reports.
What is the context?
The Energy Performance of Buildings (EPB) Framework was introduced in phases from 2007 to support decarbonisation of existing homes and buildings by encouraging take-up of energy efficiency measures.
The key elements of the framework are energy certificates: Energy Performance Certificates (EPCs), Display Energy Certificates (DECs) and Air Conditioning Inspection Reports (ACIRs).
This consultation covers England and Wales. Responsibility for energy certificates is devolved to the Scottish Parliament and Northern Ireland Assembly.
What are Energy Performance Certificates (EPCs)?
EPCs have become a key measurement tool for assessing the performance of buildings and is now widely used beyond its original scope.
For example, EPC ratings are used as the basis for energy efficiency targets for regulatory requirements such as minimum energy efficiency standards (MEES) for the private rented sector and as an eligibility requirement for funding, such as in the Warm Homes: Social Housing Fund.
What are Display Energy Certificates (DECs)?
Public buildings with a greater total floor area than 250m² are required to showcase their energy use with a DEC and have a DEC recommendation report.
If the useful floor area is 1,000m² or less, the DEC and recommendation report are valid for 10 years, and if greater than 1,000m², the DEC is valid for one year, with the recommendation report valid for 7 years.
What are Air Conditioning Inspection Reports (ACIRs)?
ACIRs are mandatory inspections, carried out by accredited air conditioning energy assessors at regular intervals not exceeding five years, for all air conditioning systems with an effective rated output of more than 12kW, including those which control ventilation, humidity and air cleanliness.
What is this consultation about?
The proposals in this consultation will, if agreed, be implemented by changes to the Energy Performance of Buildings Regulations, guidance, methodologies and other aspects of the framework such as Accreditation Scheme Operating Requirements.
Although the government outlines progress has already been made in improving the overall Energy Performance of Buildings Framework, wider reform is needed to improve EPCs, DECs and ACIRs.
To achieve this, the consultation includes proposed reforms to enhance the regime in five areas:
Updating what EPCs measure through additional metrics
The government is proposing using multiple metrics on EPCs to provide a more complete representation of building energy performance.
The following potential metrics are being considered:
- Energy cost: Helping individuals understand the financial implications of a building’s energy efficiency and make informed decisions about potential improvements.
- Carbon: An estimate of the carbon emissions arising from the energy used in the building.
- Energy use: Offering insights into overall energy consumption and identifying areas for energy efficiency improvements .
- Fabric performance: Assessing the thermal performance of a building’s envelope and promoting the importance of ‘well-insulated, comfortable and energy-efficient’ spaces.
- Smart readiness: Assessing a building’s potential to integrate smart technologies that can optimise energy consumption and the ability of consumers to benefit from smart tariffs.
Updating when energy certificates are required by refining the rules for obtaining EPCs and DECs
At present, an EPC is valid for 10 years. According to the consultation document, reducing the validity period of EPCs could allow building upgrades, such as fabric changes, to be captured more frequently.
The government’s preference is to allow all existing EPCs to remain valid until the end of their existing validity period and apply any new validity period to new EPCs.
In terms of DECs, one of the government considerations the consultation document outlines is reducing the validity period of DECs and DEC recommendation reports from 10 years to 7 years for buildings between 250-1,000m², and the validity period of DEC recommendation reports from 7 years to 5 years for buildings over 1,000m².
Managing energy certificate quality
The government acknowledges there is scope to increase stakeholders’ trust in the accuracy and reliability of EPCs and thereby increase trust and implementation of the associated recommendations.
The government is proposing giving Accreditation Schemes more control to oversee energy assessor training, or possibly sole responsibility to provide training.
Proposals also include identifying areas where additional training would be of use and to assess the value of providing energy assessors optional training for specialisms such as the energy assessment of heritage buildings.
Improving the accessibility of building performance data
The government is proposing removing certificates marked as cancelled or not for issue from the EPB Register after two years.
Other proposals include removing the option for a building owner to opt-out their EPC from public access through the public address search on the EPB Register website and removing the general prohibition on sharing data gathered under the EPB Regulations and replace it with a Secretary of State discretion about when, how and with whom to share the data.
Strengthening the quality of air conditioning inspection reports
Currently the penalties are £300 for failure to ensure a system has been inspected at regular intervals not exceeding five years and £200 for failure to produce a valid ACIR within seven days of it being requested by a Trading Standards Officer.
As the average cost of an ACIR is higher than these charges at present, the consultation document outlines that these penalties may not sufficiently encourage compliance by system operators.
The government proposes to increase the penalty charge for non-compliance with the requirement to have an ACIR for systems over 12kW to £800 and maintain the £200 penalty charge for failure to produce a valid ACIR within seven days of it being requested.
Other proposals include simplifying and redesigning the structure of ACIRs, for example to include information such as Consideration of the capabilities of the system to optimise its performance under typical operating conditions.
What happens next?
This consultation accepts contributions until 26 February 2025. Pending the outcome, the government envisages publishing a response in 2025, with changes coming into effect after this.
The proposed EPB Regulations are planned to come into force from 2026 and any changes to the EPC metrics are anticipated to be introduced in the second half of 2026.
Where can I find more information?
More information about this consultation and how to take part is available on the gov.uk website.
How can Inspired help?
Although the impacts of this consultation remain to be seen, working with an expert partner helps to ensure your portfolio is compliant with the Energy Performance of Buildings regime.
Whether you require certification or renewals, our accredited assessors can carry out site surveys, issuing certifications and recommendations. We can also help you act on any recommendations to improve the energy efficiency of your building, reduce your carbon footprint and cut down your costs.
If you would like to discuss how Inspired can support you, please call 01772 689250 or email us at [email protected]