Understanding the impact of the amendment Energy Performance Certificate regulations
By Frikkie Malan, head of sustainability at Remote Metering Solutions
On 25 November last year, the Department of Mineral Resources (DMRE) gazetted the amendment Energy Performance Certificate regulations for the mandatory and compulsory display and submission of energy performance certificates (EPCs) for buildings. These changes are of significant interest to property owners, building managers, and other stakeholders.
Amongst other things, the energy performance certificate regulations provide a deadline extension for the mandatory display of EPCs for the requisite buildings. Originally, these certificates would have had to be displayed by 8 December last year. Thanks to the extension, this has been postponed to 7 December 2025. While many have lauded the news, there is still significant work to be done to ensure compliance.
Furthermore, property owners must register the type, size, and energy performance for those buildings requiring EPCs on the National Building Energy Performance Register (NBEPR) by 25 November 2023. It is easy to overlook the November date given the deadline extension. However, this could result in organisations still falling foul of the legislation.
The devil’s in the details
Many have questioned how the energy performance of a building can be submitted by November this year if the EPC is only due in December 2025. This year’s submission to SANEDI does not ask for a comprehensive EPC. It is only the energy performance of a building that must be submitted and not the certificate. As such, this performance can be based on a preliminary energy performance calculation.
The initial energy performance calculation therefore does not need to be based on the outcome of a building inspection. It also does not require review and sign-off by a technical signatory from an accredited inspection body.
The preliminary calculation would involve analysis of electricity bills, diesel and gas invoices, solar PV metering reports, occupancy schedules, list of loads in the energy exclusions, energy exports, and floor plans (or any document showing the floor area).
Influencing factors
The preliminary energy performance would be determined by several factors. As a first step, the company must summate the energy consumption of the building for a year. The calculation is based on the reported figures of the electricity bills, diesel and gas invoices (a calorific conversion would be needed for this), and solar PV metering.
Secondly, the energy exclusions and exports must be subtracted. The energy exclusions would be calculated using the rated power and running times of the loads outside the building, in the basement parking, and in the storerooms (these loads mostly pertain to lighting). Exports would be determined based on what is exported (solar PV output fed to the grid, etc.).
Thirdly, the organisation must divide the net energy by the net floor area. A reasonable estimate of the net floor area can be obtained using the GLA of the building or by analysing building floor plans.
A competitive advantage
The RMS EPC Inspection Body is experienced in assisting building owners get the required EPC for their relevant properties. As part of its value proposition, it advises that companies should submit their building and its energy performance to the SANEDI according to the amended regulations.
Regardless the Inspection Body used, companies must agree on fair commercial terms between themselves and the Inspection Body so that the work done this year is credited against the final cost of issuing the certificate whenever this occurs. The Inspection Body will assist the organisation in ensuring the data and documents gathered for the preliminary submission are stored securely so that these records are available for final certification.
For our part, RMS will have certified more than 800 buildings by February this year. RMS offers its proficient EPC inspection team and our hard-won experience in delivering energy performance certificates at scale to property owners who still need to get their buildings certified.