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Issue 23 | 2026 www.elmhurstenergy.co.uk

The Home Energy Model: Where Are We Now?

EPCs Set to Play a Key Role in Future Home Buying and Selling Reforms

Scottish Government Sets Out Autumn 2029 Timeline for New Energy Standards

Qualifying Is Just the Beginning: The Growing Importance of CPD

A Magazine for Energy, Retrofit and Property Professionals

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Hello and welcome to the latest edition of Energy Matters. As always, I would like to start by thanking our contributors, members, partners and colleagues across the industry who continue to share their knowledge and expertise. This magazine provides an important opportunity to look beyond individual policy announcements and consider how the wider energy assessment sector is developing, as well as the role competence will play in that future. Competence is a particularly strong theme throughout this edition. Across energy assessment, retrofit and the wider built environment, expectations continue to increase. Clients, building owners, landlords and consumers need confidence that the assessors they appoint have the knowledge, skills and oversight required to carry out their work accurately and consistently. This is why competency schemes, quality assurance and continuing professional development are so important. Accreditation should represent more than simply meeting an entry requirement. It provides an ongoing framework through which standards can be maintained, work can be independently audited, and assessors can demonstrate that they remain competent as methodologies, regulations and industry expectations change. We explore this in more detail through our articles on competency schemes and the importance of CPD and upskilling. We also look at our Damp & Mould Competency Scheme and the growing importance of competent assessment in supporting

There is also a focus on the significant changes coming for Energy Performance Certificates. Proposals to reform the home buying and selling process could place the EPC in an increasingly important position, helping buyers understand the energy performance of a property much earlier in the transaction. At the same time, work continues around the Home Energy Model, which will ultimately change how the energy performance of homes is calculated. In this edition, we take a closer look at these developments and at how Elmhurst is preparing through our Design HEM software. Change is taking place across the nations too. Scotland continues to develop its approach to higher energy standards for new buildings, and we examine the revised timeline set out through its Stage 2 building regulations consultation. As standards become more ambitious, it will be increasingly important that the industry is given sufficient clarity, preparation time and access to the right tools and training. Consumer protection is another area receiving renewed attention. Almost ten years on from the Each Home Counts review, questions remain around how we create a system that protects consumers while remaining clear, proportionate and practical for the professionals delivering work. Strong consumer protection is essential, but it must be supported by clear accountability, competent people and robust assessment rather than unnecessary duplication and complexity. For our non-domestic members, this edition also provides an update on the Energy Savings Opportunity Scheme. With Phase 4 underway, organisations and Lead Assessors need to understand the key requirements and prepare well ahead of the next compliance deadline.

These topics demonstrate just how broad the role of today’s energy professional has become. Technical knowledge remains fundamental, but so too does the ability to adapt, maintain competence and respond confidently to changing standards and client expectations. Elmhurst will continue to support members through that change with training, software, technical guidance, quality assurance and opportunities to develop their knowledge. Our role is to help our members understand what is coming and prepare for it. I hope you enjoy this edition of Energy Matters and find plenty within it to support your work and professional development.

Stuart Fairlie Managing Director, Elmhurst Energy

Contact us for the latest news and updates Elmhurst Energy, 16 St Johns Business Park, Lutterworth, LE17 4HB 01455 883 250 enquiries@elmhurstenergy.co.uk www.elmhurstenergy.co.uk ElmhurstEnergy ElmhurstEnergy Elmhurst-Energy-Systems-Limited

energymatters | Issue 23 | 2026

Contributors 14 Stuart Fairlie Managing Director

Amo Sihra Commercial & Operations Director

Simon Flint Retrofit Scheme Manager

Contents 05

Elmhurst’s Damp & Mould Competency Scheme: Raising Standards in Housing Assessments

Home Energy Model: Where Are We Now?

EPCs Set to Play a Key Role in Future Home Buying and Selling Reforms

Scottish Government Sets Out Autumn 2029 Timeline for New Energy Standards

Qualifying Is Just the Beginning: The Growing Importance of CPD

Ten Years On, Each Home Still Counts: Rethinking Consumer Protection for Retrofit

Your 2026 Guide to the UK Energy Savings Opportunity Scheme

Strengthening Client Confidence Through Competency Schemes

Market Data

Training Update

Jason Hewins New Build Dwellings Manager Josh Wakeling Head of Training

Caroline Postles Existing Dwellings Manager

Dominic Reed Head of Commercial

Stephen Windmill Non-Domestic Technical Consultant

Jennifer Hartley Airtightness Team Leader

Elmhurst’s Damp & Mould Competency Scheme: Raising Standards in Housing Assessments compliance with evolving legislative requirements. The scheme is supported by purposebuilt reporting software, helping assessors capture evidence and maintain a consistent approach across every assessment.

SIMON FLINT Retrofit Scheme Manager The management of damp and mould has become one of the most important challenges facing the UK housing sector. Following the introduction of Awaab’s Law in England and increasing regulatory expectations on landlords, there is a growing need for competent professionals who can assess damp and mould issues accurately, consistently and efficiently. This demand is being seen across both the social and private housing sectors. In Scotland, new requirements for social and private landlords come into force from 6th October 2026, introducing set timescales for investigating reports of damp and mould and beginning any necessary repairs. In England, Awaab’s Law already requires social landlords to investigate and address significant damp and mould hazards within specified timescales, while legislation also provides for these requirements to be extended to the private rented sector. In response to this demand, Elmhurst Energy has launched

its Damp & Mould Assessor Competency Scheme, providing a practical framework for developing and recognising professional competence in this specialist area. The scheme has been designed to address a recognised skills gap within the housing sector. As landlords face tighter requirements around investigating and resolving damp and mould hazards, access to trained assessors is becoming increasingly important. Elmhurst’s training programme equips professionals with the knowledge needed to understand the relationship between moisture, ventilation, building fabric, heating systems and occupant behaviour, ensuring assessments consider the root causes of problems rather than simply the visible symptoms. A key strength of the scheme is its focus on consistency and evidence-based reporting. Assessors are trained to follow a structured methodology that enables them to gather information, record observations and produce clear, auditable reports. This helps landlords make informed decisions about remedial actions and supports

Elmhurst also recognises the valuable role that Domestic Energy Assessors (DEAs), retrofit professionals, surveyors and housing practitioners can play in damp and mould investigations. Their existing understanding of building performance, insulation and ventilation places them in a strong position to undertake this work, provided they receive the appropriate training and competency recognition. Importantly, the competency scheme is not intended to replace specialist damp surveyors. Instead, it provides landlords with access to trained professionals who can carry out non-intrusive, evidence-based assessments, helping to identify risk factors and determine whether more specialist investigation is required. This allows landlords to respond quickly, prioritise resources effectively and create a clear audit trail of decision-making.

Elmhurst’s Damp & Mould Competency Scheme offers a practical solution for improving standards, supporting compliance and helping to create safer, healthier homes for residents.

Find out more

energymatters | Issue 23 | 2026

Home Energy Model: Where Are We Now? JASON HEWINS New Build Dwellings Manager It has been six months since the release of the Future Homes Standard (FHS) and the associated SAP 10.3 methodology. This article looks at the latest on the delivery of the Home Energy Model (HEM) for the Future Homes Standard (HEM: FHS) and what we know so far.

What is the Home Energy Model?

What is the latest on HEM: FHS?

The Home Energy Model is a full replacement for the current Standard Assessment Procedure (SAP). Developed using modern industry standards and validated against real-world performance data, it represents a step change in how the energy performance of homes is assessed.

The UK Government is broadly satisfied that the version of the model and FHS wrapper that will be used to calculate compliance with the Future Homes Standard are complete. The model and wrapper are being implemented into the Government’s Energy Calculations as a Service (ECaaS) facility, which only accreditation schemes can connect to in order to generate compliance results and Building Regulations England Part L (BREL) reports.

Like SAP, the Home Energy Model will sit at the heart of a wide range of government policies, making it a critical tool for delivering the UK’s housing and climate ambitions. As the government consultation put it, it is “a new name for a new methodology”. Its first official use will be to calculate compliance with the Future Homes Standard, where the model and FHS wrapper will be known as HEM: FHS. It is also expected to be used to calculate EPC ratings for new and existing homes as part of the wider reform to EPCs in the autumn of 2027 in England and Wales.

The focus is now shifting to what is needed for the industry to be ready for the release of HEM: FHS. Of critical importance is the need for comprehensive training materials, clear competency requirements and conventions for HEM to be deployed successfully. The Government is currently liaising with accreditation schemes to undertake this work.

New Build Dwellings Manager, Jason Hewins, commented:

When can we expect HEM: FHS to be released? Officially, there is no fixed date for when HEM: FHS will be released to demonstrate compliance with the Future Homes Standard. Elmhurst is working closely with Government to ensure all crucial steps are completed before HEM: FHS can be successfully deployed to the industry.

What about Elmhurst’s Design HEM application? Elmhurst’s application for HEM, known as Design HEM, continues to be developed. Over the past few months, the Government has achieved some important milestones to aid this, such as completion of the HEM version used at ECaaS and the FHS wrapper contents. As we get nearer to the release of Design HEM, we will share more details of our application, with beta testing opportunities for those

members who registered for this earlier this year. Find out more about Design HEM

Will existing OCDEAs need to retrain to use HEM? Whilst the On-Construction Domestic Energy Assessor (OCDEA) qualification is methodologyagnostic, HEM is a brand-new methodology with some very significant differences to SAP. Elmhurst believes that, for an OCDEA to use HEM competently to issue compliance reports, Predicted Energy Assessments (PEAs) and EPCs, they should undergo a form of upskilling. Elmhurst is liaising with Government on this subject, and more details will be released in due course.

“Since the release of the Future Homes Standard, assessors have been using SAP 10.3 to assess the impact on designs of the new regulations. However, many parts of the industry are awaiting the release of HEM: FHS in order to compare compliance standards with SAP 10.3. Many stakeholders are concerned that HEM: FHS will provide different performance standards for compliance from SAP, and we know the Government has undertaken work to ensure this risk is reduced as much as possible. To deliver a smooth transition to HEM, it’s vital the model and its surrounding ecosystem are fully completed. We are in regular meetings with Government and will continue to ensure our members are updated on progress where possible. Regarding Elmhurst’s Design HEM application, our software teams are working hard on development and making good progress, and we are looking forward to sharing more details on the application soon.”

23 | 2026 energymatters | Issue 20 2025

EPCs Set to Play a Key Role in Future Home Buying and Selling Reforms CAROLINE POSTLES Existing Dwellings Manager The Government’s latest roadmap for reforming the home buying and selling process has signalled an important shift for the property sector, with Energy Performance Certificates (EPCs) set to play a more prominent role than ever before. The Government anticipates that the majority of these measures will apply in England, Wales and Northern Ireland. Due to Scotland’s distinct framework, it does not currently expect the reforms to apply there. Published by the Ministry of Housing, Communities and Local Government following its Home Buying and Selling Reform consultation, the roadmap outlines plans to make property transactions faster, more transparent and less likely to fall through. Central to these ambitions is the provision of more 08

comprehensive information at the start of the sales process, helping buyers make informed decisions and reducing delays later in the transaction.

EPCs to be included in future sales packs One of the most significant developments for the energy assessment industry is the inclusion of EPC ratings within the Government’s indicative list of information expected to form part of future property sales packs. These packs, which the Government intends to make mandatory before a property is listed for sale, are expected to contain key details such as tenure information, title documents, searches, property condition reports and floor plans, alongside EPC data. For many within the sector, this represents growing recognition that

energy performance is no longer a secondary consideration for homebuyers. Rising energy costs, increased awareness of carbon emissions and a greater focus on retrofit have all contributed to buyers placing more importance on understanding a property’s energy efficiency before committing to a purchase.

Elmhurst welcomes the inclusion of EPCs in sales packs Elmhurst Energy has welcomed the announcement, having strongly advocated throughout the consultation process for EPCs to be recognised as mandatory material information. The organisation argued that EPCs should be available at the point of listing, accurately reflect the property being marketed and be linked directly to the official EPC register to improve transparency and consumer confidence.

Transitioning to digital property records The roadmap also highlights the Government’s intention to support the wider adoption of digital property logbooks. These digital records will provide homeowners and prospective buyers with secure access to important property information throughout the life of a building. As EPC ratings are expected to form part of the standardised information set contained within future sales packs, there is a clear opportunity for energy performance data to become more accessible, consistent and integrated within the wider property information landscape. Beyond EPCs, the reforms propose several other changes aimed at improving the transaction process. These include greater use of digital identity verification, qualified electronic signatures, stronger professional standards across the property sector and efforts to reduce duplication in anti-money laundering checks. The Government

has also confirmed its intention to introduce legislation requiring binding conditional contracts between buyers and sellers once the new sales pack process becomes established.

What this means for energy assessors For energy assessors and accreditation schemes, the reforms could have significant implications. As EPCs become more prominent within property transactions, there may be increased scrutiny around certificate quality, accuracy and consistency. Assessors may also find themselves playing a more visible role in supporting estate agents, homeowners and prospective buyers with reliable information about a property’s energy performance and potential improvement measures.

The future role of EPCs in property transactions While many of the proposals remain subject to future legislation

and detailed consultation, the intended outcome is clear. Property transactions are expected to become increasingly digital, informationrich and consumer-focused. The growing prominence of EPCs within this framework demonstrates the important role energy performance information will play in helping buyers understand the efficiency, running costs and future potential of a property. For the EPC industry, the Government’s roadmap represents both an opportunity and a challenge. As energy performance data becomes a more integral part of the home buying process, maintaining high standards of quality and compliance will be essential. If successfully implemented, these reforms could help place EPCs at the centre of a more transparent, efficient and informed property market for years to come. Read the consultation outcome here:

energymatters | Issue 23 | 2026

Scottish Government Sets Out Autumn 2029 Timeline for New Energy Standards proposals in the consultation below: JASON HEWINS New Build Dwellings Manager On 24th July 2026, the Scottish Government published its Stage 2 consultation on the next revision to Scotland’s energy standards. The proposals form part of its ongoing work to introduce a ‘Passivhaus equivalent’ standard for new homes through the Scottish Building Regulations. The consultation follows the Part 2 response to the Stage 1 consultation, published in December 2025. That response indicated that the new standards would be introduced from 31st March 2028. However, following a review of the programme and the additional time needed to develop the supporting guidance, assessment methodologies and software tools, the proposed implementation date has now moved to autumn 2029.

Why has the implementation timeline been pushed back? The next update to Scotland’s energy standards was originally expected to come into force on 31st March 2028. However, the Scottish Government has confirmed that more time is needed to develop the Stage 2 proposals, supporting guidance and assessment tools. It now intends to publish the guidance and approved assessment methodologies for Standard 6.1 in autumn 2027, with the new requirements expected to take effect in autumn 2029. This Stage 2 consultation seeks views on proposed energy and environmental performance targets for the new standard and is due to close on 16th October 2026. We cover some of the main

Proposed uplift over current energy standards The consultation sets out three options for the future energy performance requirements for new homes in Scotland: Option 1 – Good Practice: Equivalent to a 6% reduction in carbon emissions compared with the current 2023 energy standards. Option 2 – Best Practice: Equivalent to a 37% reduction in carbon emissions compared with the current standards. Option 3 – Current Standard: Retain the existing 2023 energy performance requirements for new homes, with no additional uplift. Both the Good Practice and Best Practice options would strengthen aspects of fabric performance, although the proposed roof U-values represent a relaxation compared with the current standards. The Best Practice option would introduce more demanding requirements, including mechanical ventilation with heat recovery (MVHR) and, where a heat pump is installed, photovoltaic panels. Compliance metrics It was confirmed that delivered energy would remain the main compliance metric for Standard 6.1, while a target space heating rate would be introduced as a secondary metric to support compliance with Standard 6.2. Delivered Energy Rate: This will measure the energy delivered to the home and will be calculated in the same way as under the current Standard 6.1. It will not include unregulated energy use or any energy exported to the electricity grid.

Space Heat Demand Rate: This will measure the amount of energy needed to heat the home. It will be determined by the building’s fabric performance, including insulation levels, thermal bridging and airtightness. Setting performance standards Under the current approach, compliance targets are calculated in SAP 10.2 using a notional dwelling defined within the Building Standards. The consultation proposes replacing this method with a series of target performance tables. The relevant target range would be selected based on the following factors: • • • •

Location Dwelling type Orientation Heating system

These characteristics would match those of the actual home when establishing its Target Delivered Energy Rate. All other features of the notional dwelling would be based on fixed specifications, regardless of the materials, systems or construction details used in the proposed home. This approach is intended to provide clearer and more consistent performance targets while still accounting for the main factors that influence a home’s energy use. Calculation methodologies As confirmed in the Stage 1 consultation, Standard 6.1 will be based on the use of the Home Energy Model with a Scottish wrapper. This is currently a work in progress, but a consultation version of HEM with the Scottish wrapper was made available alongside the Stage 2 consultation. It was also proposed that a modified version of the Passivhaus Planning Package (PHPP) will be developed and adopted as an approved compliance methodology for Standard 6.1.

New Build Dwellings Manager, Jason Hewins, commented:

“We are pleased to see the Scottish Government issue this key consultation on the next revision to energy standards for new buildings. There are some significant changes proposed here such as revised metrics, setting of performance standards and national calculation methodologies that will need to be analysed in detail. Elmhurst will provide further detailed analysis of the changes in due course.”

Read the full consultation here:

energymatters | Issue 23 | 2026

Qualifying Is Just the Beginning: The Growing Importance of CPD JOSH WAKELING Head of Training The energy assessment and retrofit sector has changed more in the last three years than in the previous ten: Reduced Data Standard Assessment Procedure (RdSAP) 10, Minimum Energy Efficiency Standards (MEES) reform, the Future Homes Standard, PAS 2035 revisions, retrofit competency frameworks. The pace of regulatory and technical change shows no sign of slowing. In that environment, Continuing Professional Development (CPD) has become increasingly important in helping assessors maintain their knowledge, build confidence and support their ongoing development.

From compliance to competence

Keeping up with industry changes

Every Elmhurst member is required to complete a minimum of 10 hours of CPD per year as a condition of their membership*. For many, CPD may be something that is completed towards the end of the year, rather than something built into day-to-day working life. That’s understandable; everyone is busy and CPD can sometimes feel like another administrative task alongside the demands of the job.

Passing a qualification demonstrates that you met the required standard at that point in your career. CPD helps you build on that foundation and keep pace as standards, methodologies and requirements evolve. With RdSAP 10 changing how airtightness and other inputs are assessed, and MEES reshaping compliance requirements and deadlines for landlords in the private and social rented sectors, keeping knowledge current is becoming increasingly important.

However, CPD can offer much more than simply meeting an annual requirement. Keeping a regular record of learning and development helps build a clear picture of growing expertise. Uploading evidence as it happens – a webinar attended, a new standard studied or a new qualification added – can create a richer, more complete record of professional development. It can also make keeping CPD records up to date much easier throughout the year.

Retrofit adds another layer. As standards like PAS 2035 and BS 40104 continue to evolve, and new and proposed requirements for EPC C or equivalent by 2030 place pressure on the market, energy and retrofit professionals need structured CPD to stay informed and support the clients and organisations relying on their judgement. Competence, in other words, is something that continues to develop throughout a professional career.

Top tips for building CPD into the working year Practically, that means treating CPD less like a one-off task and more like an ongoing habit: 1.

Log as you learn Upload evidence regularly rather than trying to reconstruct a year’s development from memory later.

Mix formal and informal learning Structured courses matter, but so do webinars, technical bulletins and software guides.

Target your development Use CPD deliberately to build knowledge in the areas most relevant to your day-to-day work – whether that’s a new methodology, a scheme change or an area identified through a recent audit.

Make it visible A well-maintained CPD record can also be a valuable professional asset, helping to demonstrate ongoing development to clients, employers and accreditation bodies.

The bigger picture None of this happens in isolation. The organisations and schemes that support assessors also have an important role to play in making CPD easy to record, relevant to real practice and clearly connected to professional development, rather than simply membership renewal. Providing accessible, useful learning opportunities can help professionals engage with CPD in a way that supports both their work and their longer-term development. The sector is being asked to deliver more accurate assessments, more credible retrofit advice and more consistent standards, all while the technical requirements continue to evolve. CPD helps individual assessors keep up with those changes and supports the profession in maintaining the knowledge, confidence and standards expected by clients and consumers. Find out about CPD requirements and upcoming training opportunities Speak to the training team on: 01455 555 216 or email training@elmhurstenergy.co.uk *Of the CPD completed each year, at least 50% must be certified CPD, with a further five hours required for each additional strand of accreditation.

energymatters | Issue 23 | 2026

Ten Years On, Each Home Still Counts: Rethinking Consumer Protection for Retrofit DOMINIC REED Head of Commercial The Department for Energy Security and Net Zero (DESNZ) has launched a consultation on major reforms to consumer protection for government-supported home upgrade schemes. The proposals follow serious concerns identified under Energy Company Obligation 4 (ECO4) and the Great British Insulation Scheme (GBIS), which include poor-quality installations, fragmented oversight and difficult routes to remediation. The consultation asks how the system can be made simpler, more accountable and better able to prevent poor outcomes before they occur.

But many of the issues being raised today are not new. In 2016, the independent Each Home Counts review set out a vision for a trusted, consumer-focused retrofit market. It called for clearer standards, competent professionals, better use of property data, consistent monitoring and a single route for consumers to obtain advice and redress. Its central message was straightforward: the right measures must be installed in the right homes, in the right way! Nearly ten years later, the latest consultation provides an opportunity to return to those principles, examine why they have not been

delivered consistently and ensure the next system works in practice.

What is the government proposing? At the centre of the consultation is a new, end-to-end consumer protection service for governmentsupported retrofit schemes. This service could become the main point of contact for consumers, providing impartial advice, managing complaints and coordinating remediation and redress. The wider proposals include: Greater oversight from DESNZ and the proposed Warm Homes Agency Stronger contractual agreements

with installers, certification bodies and retrofit professionals Clearer competence requirements A centralised data platform Intelligence-led, risk-based auditing Stronger enforcement where standards are not met An independent ombudsman for unresolved disputes The government is also considering whether parts of the system should be available to households paying for home improvements themselves, not just those using governmentsupported schemes.

Each Home Counts: the original ambition Each Home Counts was an independent review commissioned by government and chaired by Dr Peter Bonfield, former chief executive of the Building Research Establishment (BRE). It identified a market that was difficult for consumers to navigate, with multiple schemes, certification routes and organisations operating across different measures. The review proposed a more joined-up framework built around: • • • • • • • •

A recognisable quality mark A Code of Conduct Clear technical standards and Codes of Practice A Consumer Charter An impartial Information Hub A property-level Data Warehouse Nationally coordinated monitoring and enforcement A single point of contact for complaints and redress

Crucially, the review also called for a holistic, property-specific approach to retrofit. Rather than installing measures in isolation, each home should be considered as a complete system, taking account of its construction, condition, ventilation, moisture risks, occupancy and the way different improvement

measures interact. This recommendation helped shape the development of PAS 2035, which introduced a structured, wholehouse approach to domestic retrofit. The principles established through Each Home Counts and subsequently embedded within PAS 2035 remain highly relevant. The challenge is ensuring that these principles are applied consistently across schemes, organisations and the wider market.

accurate assessment and a clear understanding of the individual property. Stronger contracts, more data and tougher enforcement will only succeed if the right decisions are made before work begins. That means ensuring:

Elmhurst supports the government’s ambition to strengthen consumer protection and ensure that home upgrades are completed correctly first time. However, the success of the reforms will depend on the detail.

Consumers receive trusted and impartial advice Assessments are accurate and property-specific Measures are appropriate for the home Professionals are properly qualified and competent Responsibilities are clear throughout the supply chain Monitoring is proportionate and evidence-led Remediation and redress are straightforward

The new system must avoid creating further duplication between DESNZ, the Warm Homes Agency, TrustMark, Microgeneration Certification Scheme (MCS), United Kingdom Accreditation Service (UKAS), certification bodies, building control and other existing organisations.

The consultation should not be treated as a blank sheet of paper. It is an opportunity to build on the foundations established by Each Home Counts, learn from where implementation has fallen short and create a system that delivers the outcomes originally intended.

Responsibilities must also reflect the role each person or organisation performs. Assessors, coordinators, designers, installers and certification bodies have different responsibilities and different levels of control over project outcomes. They should not all be subject to the same obligations or sanctions.

Ten years on, each home still counts, and every household should be able to trust the advice, assessment and work carried out in its property.

Elmhurst’s initial view

Elmhurst supports better use of data and more intelligent, risk-based auditing. However, information used to assess the performance of professionals or businesses must be accurate, properly contextualised and open to challenge. Artificial intelligence (AI) may help identify patterns, fraud risks and emerging quality issues, but it should support professional judgement rather than replace it. Back to the fundamentals For Elmhurst, effective consumer protection starts with competence,

energymatters | Issue 23 | 2026

plan that were not implemented and explain why. ESOS compliance and enforcement Organisations that fail to complete a compliant ESOS assessment and submit a notification of compliance may face enforcement action and civil penalties. For example, failure to undertake an energy audit can result in a fixed penalty of up to £50,000, plus up to £500 for each working day the breach continues after a compliance notice, capped at 80 working days.

Your 2026 Guide to the UK Energy Savings Opportunity Scheme STEPHEN WINDMILL Non-Domestic Technical Consultant The Energy Savings Opportunity Scheme (ESOS) is a mandatory energy assessment scheme for large UK organisations. Introduced under the UK’s implementation of the EU Energy Efficiency Directive, it is designed to help qualifying organisations understand how they use energy across their buildings, industrial processes and transport activities, and identify practical opportunities to reduce energy use, carbon emissions and costs.

How ESOS works ESOS operates in four-year compliance periods. Phase 3 covered the period from 6th December 2019 to 5th December 2023.

Phase 4 is now underway Phase 4 covers 6th December 2023 to 5th December 2027. Its qualification date is 31st December 2026, and the compliance deadline is 5th December 2027. For Phase 4, qualifying participants will need to complete their assessment and submit their notification of compliance by 5th December 2027. They must then submit an action plan by 5th December 2028, followed by progress updates on 5th December 2029, 5th December 2030 and, under a new requirement, 5th December 2031. Phase 4 also introduces stronger reporting on implementation. The ESOS report and notification of compliance must include an action plan review, details of energy savings achieved during the compliance period and information about the measures implemented. Participants must also identify measures from the previous action

ESOS energy audits must be carried out by an approved ESOS Lead Assessor for organisations that qualify under the scheme. ESOS is administered by the Environment Agency, which is also responsible for auditing submissions, carrying out compliance checks and taking enforcement action where necessary.

Who needs to comply with ESOS? ESOS applies to large UK-based organisations and corporate groups if, on the qualification date, they meet either of the following conditions: They employ 250 or more people They have an annual turnover of more than £44 million and an annual balance sheet total of more than £38 million Corporate groups may also qualify where at least one of their UKbased subsidiaries meets the above qualification criteria. Organisations close to the thresholds, or those that have recently grown or reduced in size, should check the detailed rules because ESOS status may depend on whether the organisation has remained above or below the thresholds for two consecutive accounting periods.

What ESOS means for large organisations ESOS provides a structured

Daniel Pearson, Non-Domestic Team Leader at Elmhurst Energy, commented:

opportunity to review energy use and identify where practical improvements can be made. The assessment should identify tailored and cost-effective measures across buildings, industrial processes and transport. These measures can support lower energy costs, reduced carbon emissions, improved operational efficiency and longerterm decarbonisation plans. The ESOS report, notification of compliance, action plan and progress updates require directorlevel sign-off. Action plans and annual progress updates will be published by the Environment Agency, helping to increase transparency around the measures organisations intend to take and the progress they report.

“ESOS has evolved well beyond a periodic audit exercise. Phase 4 strengthens governance, transparency and accountability, making it an increasingly important driver of long-term energy performance improvement. When integrated into wider energy and retrofit strategies, ESOS can deliver meaningful cost savings, carbon reduction and future regulatory readiness.” Routes to compliance for ESOS participants ESOS participants must cover at least 95% of their total energy consumption through ESOS energy audits, ISO 50001 certification or a combination of eligible routes. From Phase 4, Display Energy Certificates (DEC) and Green Deal Assessments are no longer accepted as routes to compliance.

Participants that comply solely through ISO 50001 now have reduced obligations where the certification covers all their total energy consumption, or all significant energy consumption as applicable. In these circumstances, they do not need to produce a separate ESOS report or appoint an ESOS Lead Assessor, although they must still submit the required notification through the government’s online Manage your Energy Savings Opportunity Scheme Reporting (MESOS) system and meet the relevant sign-off requirements.

Opportunities for energy professionals As ESOS remains an important requirement for large UK organisations, there is ongoing demand for competent professionals who can provide high-quality assessment and advisory support. Energy professionals who want to expand their services in this area can develop the required expertise through ESOS Lead Assessor training.

Find out more about ESOS Lead Assessor training

energymatters | Issue 23 | 2026

Strengthening Client Confidence Through Competency Schemes JENNIFER HARTLEY Airtightness Team Leader When appointing an assessor, clients need confidence that the person carrying out the assessment has the right knowledge, skills and competence to apply them correctly. Qualifications and training provide an important starting point, but competence needs to be maintained throughout an assessor’s career as standards change, methods develop and new requirements are introduced. Keeping their knowledge up to date is an essential part of an assessor’s role.

Demonstrating ongoing competence Assessors are expected to demonstrate not only that they were competent when they first qualified, but that they remain competent as industry requirements change. A competency scheme provides the framework for maintaining standards through measures such as continuing professional development and technical guidance. Independent audits are an important part of this process. Auditors check that work is being carried out correctly, that suitable evidence is being recorded and that the required standards are being followed. For clients who may not have the technical knowledge to assess quality themselves, independent checks provide reassurance that assessors are maintaining reliable records, meeting recognised

standards and working within a consistent, accountable framework.

Putting competence into practice: airtightness testing Airtightness testing is just one example of why competence matters. An air pressure test measures how much air escapes through gaps and openings in a building’s fabric. Overstating or understating the airtightness of a building can affect the comfort of the occupants, the building’s running costs as well as the ventilation requirements. The result can also affect calculations used to assess the building’s overall energy performance, so it’s important that the test is carried out accurately and reported correctly. For new dwellings in England, Approved Document L states that an air pressure test should be carried out on every dwelling and that the person carrying out the test should have received appropriate training and be registered to test the relevant class of building. This is where a government-approved competent person scheme provides an extra level of assurance. The Elmhurst Airtightness Scheme (EAS) supports companies, sole traders and partnerships carrying out airtightness testing. Members work within a recognised framework that includes quality assurance and technical support, helping them demonstrate that their work meets the required standards.

Simon Drury, Owner of Simple Simon’s EPC Services, commented:

“As the owner of Simple Simon’s EPC Services, I believe accredited bodies and competent person schemes provide an important layer of protection for consumers. Being qualified is essential, but accreditation demonstrates that competence goes beyond simply holding a certificate. Independent auditing, recognised standards and ongoing quality assurance provide reassurance that professionals are working to the standards expected of them and remain accountable for the quality of their work. For my clients, this gives them greater confidence that they are not only choosing someone who is qualified, but someone who is competent, independently assessed and committed to maintaining high professional standards. My memberships with recognised schemes, including the Elmhurst Airtightness Scheme, help us demonstrate that commitment and gives my clients additional reassurance when choosing Simple Simon’s EPC Services.”

The importance of independent audits Assessors build their reputation by consistently delivering accurate work and a reliable service. Audits strengthen that reputation by providing independent evidence that recognised standards are being met, but can also highlight areas for improvement, help maintain consistency across the industry and provide guidance when requirements change. Wendy Macnaughton, Director of Alba Air Tightness Testing Ltd, commented:

“Being part of the Elmhurst Airtightness Scheme gives our clients confidence that their testing is being carried out to a high professional standard. The independent auditing and ongoing technical support via the helpline and email also help us maintain our own standards and ensure we continue to provide a reliable, professional service.” Competency schemes provide a practical way to demonstrate knowledge and confirm that standards are being maintained over time. For clients, it means

greater confidence in the person they appoint, and for assessors, it provides independent evidence of the quality and consistency behind the service they deliver.

Elmhurst competency scheme members all have access to Elmhurst accredited member logos, which can be used for marketing purposes and provide assurance that assessors are: Expertly trained and qualified Able to provide helpful information and advice Supported by the UK’s largest energy assessment accreditation scheme which provides dedicated technical support Audited to ensure ongoing competence in their work and compliance with the latest standards Fully insured to protect clients from accidental damage and rare cases of defective assessments

Want to become an Elmhurst accredited member? Scan the QR code to explore Elmhurst’s extensive range of competency schemes and find out how to become an accredited member.

energymatters | Issue 23 | 2026

Market Data AMO SIHRA, Commercial and Operations Director At Elmhurst, we collect and analyse data from a range of sources to help us make informed business decisions. Turning this data into clear, meaningful insights takes time and a deep understanding of the wider context.

In each edition of Energy Matters, we share a snapshot of this data alongside concise commentary that we hope you’ll find useful and thought-provoking as you plan for the future. Some datasets, particularly those relating to new build homes within the devolved nations, are periodically updated and may include estimates where the latest figures are not yet available.

EPC Lodgements vs House Sales – Market Snapshot

Housing Market Trends – Annual Starts vs Completions

EPC lodgements remain at historically strong levels, continuing to significantly outperform housing transaction volumes. Whilst activity has eased slightly from recent highs, recent months show a broadly stable trend, underlining the resilience of underlying demand.

Annual housing starts experienced a significant decline during 2024 before showing clear signs of recovery through 2025 and into early 2026. Recent months have seen a sustained upward trend, with starts rebounding from recent lows and indicating a gradual improvement in development activity.

House sales have recovered from the lows experienced during 2023 and early 2024, stabilising at around 1.2 million annualised transactions. Growth has become more measured in recent periods, with the market showing signs of settling into a steadier pattern of activity.

EPC demand continues to be driven by a wider range of market factors beyond property transactions alone, including rental activity, compliance requirements and retrofit programmes. This is helping to sustain assessment volumes even as the housing market remains below historic transaction peaks.

Completions have remained more resilient throughout the period, although they have eased from the peak levels recorded in 2022 and 2023. Recent data suggests completions have stabilised at around 170,000 annually, continuing to run ahead of starts but showing a flatter trend.

The recent recovery in starts is an encouraging sign for future housing supply. Whilst completions remain higher than starts, the gap has narrowed in recent months, suggesting improving developer confidence and the potential for stronger housing output over the medium term.

Elmhurst

New Build EPC Trends Over Time – On Construction EPCs

Non-Domestic EPCs vs NonDomestic Sales – Market Overview

On-construction EPC volumes continue to trend lower than historical peak levels, although the pace of decline has eased significantly over the last year. Recent months show activity stabilising within a narrower range, suggesting that the market may be reaching a more balanced position.

Non-domestic EPC volumes have remained broadly stable over the past year, holding close to the 100,000 annual mark. Following the declines seen from earlier highs, activity has settled into a relatively consistent pattern with limited short-term volatility.

While volumes remain below those recorded during the strongest periods of housebuilding activity, the market is no longer experiencing the sustained falls seen previously. This points towards a more stable level of construction-related assessment activity.

The sector appears to be transitioning from contraction to stabilisation. Although a full recovery has yet to emerge, the recent trend suggests a firmer base is developing for future new-build EPC demand.

t Insights

Sales activity within the non-domestic sector continues to outperform EPC volumes, remaining relatively steady in the mid-120,000 range. Recent trends indicate a stable transactional market, with no significant acceleration or deterioration in activity levels.

The non-domestic market continues to demonstrate resilience despite ongoing uncertainty around future regulation and investment decisions. EPC activity remains steady, although the absence of a major regulatory catalyst is limiting stronger growth in assessment volumes.

energymatters | Issue 22 | 2026

Training Update JOSH WAKELING Head of Training Elmhurst Energy offers diverse training options tailored to meet your needs. With over three decades of industry experience, we ensure an engaging and impactful learning experience. Our qualifications and Continuing Professional Development (CPD) courses cater to both beginners and seasoned professionals. Here’s a breakdown:

Classroom Training Regular sessions held in Lutterworth, with nationwide availability. Interact with expert tutors in person. Hands-on, practical learning approach. Personalised guidance and networking opportunities.

Remote Training Flexibility to learn online from anywhere with an internet connection. Live sessions with interactive features. Engage with instructors and peers via Zoom and Microsoft Teams.

On-Demand Training Access full qualification and CPD webinars anytime, anywhere. Study at your own pace to fit your schedule. Enjoy the convenience of learning on the go.

By offering these formats, we accommodate various preferences and schedules, ensuring the best learning experience for our customers.

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Trending Courses

Have Your Say on Future Training

In the dynamic world of energy efficiency, retrofitting, and sustainability, staying competitive and offering additional services is key. This section is dedicated to showcasing current trends and training opportunities. Discover the latest courses designed to meet evolving industry needs, whether you’re refining expertise or starting a career. Don’t miss out on these essential training and market opportunities!

We’re always looking for ways to make our training and CPD more useful to members. If there’s a topic you’d like us to cover, a skill you want to develop or an area you’d like to explore further, we’d like to hear from you. Scan the QR code to share your training suggestions.

Domestic MEES Masterclass (Remote) With Minimum Energy Efficiency Standards (MEES) continuing to shape the private and social rented sectors, this online masterclass helps Domestic Energy Assessors (DEAs) build the knowledge needed to support landlords and clients more confidently. Covering MEES requirements and exemptions, RdSAP data sensitivities, funding options and the Improvement Evaluator, it is ideal CPD for assessors looking to expand into MEES reporting and advisory services.

Understanding SAP 10.3 Designed to help energy professionals understand the key changes introduced by SAP 10.3, this concise online course explores the practical implications for energy assessments and compliance. Ideal for anyone looking to refresh their knowledge and prepare for future industry developments.

Understanding PAS 2038 Retrofitting Non-Domestic Buildings As demand for PAS 2038 expertise in the non-domestic sector increases, this course introduces the principles, requirements and practical application of the standard. Ideal for professionals looking to build their knowledge of commercial retrofit and understand their role in delivering quality PAS 2038 projects.

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* Vuabl LiDAR scanning is available with RdSAP Go iOS on compatible Apple devices. Usage fees apply. energymatters | Issue 23 | 2026