2.III.ii. Quality Assurance of EPCs – OVERVIEW

The Austrian provinces regularly conduct random automated EPC controls. EPCs issued for receiving subsidies or for building permits are checked by the authorities in detail as part of the subsidy approval process. If major errors are identified, the EPC is sent back for corrections.

Control on the quality of EPCs in the first six (6) years of implementing the regulation showed that despite communication around frequently made mistakes and modifications carried out on the software, there was no dramatic improvement to EPC quality for dwellings.

A mandatory refresher training to update knowledge has therefore been planned for experts already accredited. They were given a time window of 15 months to attend this refresher training and to pass the subsequent examination before mid-2018 in order to keep their accreditation. In early 2018, as a result of requests from some experts, working groups for some accredited experts were organised to review the terms as well as the contents of the tools of the refresher training.

By the end of 2019, only 345 out of 1,249 accredited experts chose to take the exam, of which 138 were successful (a success rate of 40%).

Those that do not pass the exam lose – in most cases temporarily – their accreditation and get a final chance to take the exam. By the end of 2020, we expect between 150 and 200 experts to remain accredited for residential buildings. Meanwhile, new experts take courses in order to receive the accreditation. This dramatic reduction is worrying; however, the quality of the EPC data is becoming more and more important, as it will trigger huge compulsory investments. While the remaining experts have important work to do, new experts will be motivated and training centers are getting ready for it.

In addition to the checks on new buildings, the Flemish Energy Agency executes a quality check on the work of a number of qualified experts, based on the detection of inconsistent data and on random checks. Each month, a sample of EPCs issued in the previous month is extracted and checked by means of desk controls.

In addition, the Flemish Energy Agency also handles complaints regarding the quality of EPCs. In case of a complaint, quality checks often involve on-site investigations.

In 2018, 216 EPCs were checked using the random sampling method and 16 EPCs by targeted control. After checking, 207 EPCs were evaluated as adequate (though some experts received a warning). The quality of 25 EPCs was considered insufficient. The experts responsible for those EPCs had to pay a fine. In addition, six (6) experts were suspended.

Further to the above, there were 14 complaints and nine (9) of the qualified experts had to pay a fine. As these statistics are based on targeted controls, they cannot lead to any conclusions on the overall quality of EPCs.

Since December 2015, the minimum fine for the issuance of an invalid EPC is reduced. Experts now risk a fine which ranges between 250 € and 5,000 € if the control shows that the certificates issued are invalid.

In order to further improve the quality of the EPCs, as from January 2017, experts must attend continuous education.

A 'Control web' application is used to automatically screen all the EPCs submitted to the database by flagging inconsistent data or values and selecting a statistically representative number of EPCs to be manually controlled.

Its main functionalities are:

• screening of suspicious EPC data (based on improved data analysis feedback) and identifying the problematic certificates;
• randomly selecting EPCs to be checked so that each qualified expert gets regularly controlled;
• providing an interface for exchange between qualified experts and controllers;
• archiving control documents related to assessors.

The controller has access to a summary panel where information on each qualified expert can be found, e.g., the total number of EPCs submitted, the EPCs with inconsistencies and the EPCs selected for random control. The controller also has access to the EPC details and the list of inconsistencies.

If the investigation concludes that a control procedure should be launched, for example, due to frequently occurring errors, the controller notifies the qualified expert of their errors and requests that supporting documentary evidence are provided. If necessary, wrong EPCs are corrected. Table 7 shows the number of EPCs selected by the control web application and the total EPCs available in the database, per year. Table 8 presents the number of EPCs checked by the administration.

Whether the qualified expert receives a sanction or not depends on the frequency, quantity and type of errors, as well as on their impact on the EPC outcome, particularly on the label of the building. The sanctions range from a simple warning to withdrawal of accreditation:

• ‘Simple’ warning: the rules are recalled to the expert during the hearing.
• Warning + mandatory training: the expert may continue to work but has some time to follow the mandatory training again (without having to pass the examination again). Training attendance is compulsory. If this is not done by the end of the allotted time, its approval is suspended (see below).
• Suspension of accreditation: the software account of the expert is partially blocked until he performs the mandatory training again (+ examination). The suspended expert may only finish the certificates already in progress and may not initiate new ones.
• Withdrawal of accreditation: the software account of the expert is fully blocked. He can no longer act as an EPB expert and must wait three (3) years before being allowed to retake the mandatory training.
  
  

Table 9 shows the number of sanctions applied over the years.

Table 7. Number of EPCs selected by the Control web application and the total EPCs available in the database, per year.

Table 8. Number of EPCs checked by the administration, per year.

Table 9. Number of hearings of EPC experts and number of sanctions applied, per year.

The verification of energy audits is performed by the SEDA through systematic or random sampling of the audited buildings. Control over the activity of the energy auditors is exercised by means of:

• checking the validity of the input data of the building used to issue the EPC, as well as the results stated in the certificate;

• checking the input data entered in the EPC and verifying the results, including the recommendations made for energy efficiency improvement;

• a full check of data, results and measures prescribed for energy efficiency improvement by an on-site visit in order to verify the validity between the data stated in the EPC and the certified building.

The total number of EPCs issued in 2017, 2018, and 2019 amounts respectively to 1057, 1086, and 1067, and an independent random control was carried out by the SEDA on all these EPCs.

Up to the end of 2019, no fines/penalties had been imposed.

All issued EPCs undergo administrative control during their entry into the database. Detailed quality control is carried out on EPCs that are randomly selected and/or based on complaints.

So far, 510 out of about 228,902 EPCs in total were checked in detail, 236 of which were declared invalid. Detailed control includes checks of the content of the report on the energy audit of the building, the validity and completeness of the input data, the accuracy of the EPC and the calculated and proposed measures to improve the energy performance of the building.

An EPC is declared invalid only if it contains calculation results, input data or proposed measures with significant (more than 30%) deviation and if the result causes a change of one or more energy classes.

Authorised persons shall be sanctioned by means of a fine or by annulment of authorisation in the case of three (3) or more invalid EPCs.

Figure 3. Screenshot of the electronic data base.

The MECI is checking compliance with national law through inspectors appointed by the Minister. The appointed experts are doing on-site sample checks to verify if EPC input data comply with actual building data. The sample comes from the building permits frequently provided by building permit authorities. Targeted on-site checks are also performed. This usually has to do with EPCs issued as a prerequisite of a financial incentive. Desk checks are performed when an assessor submits their first EPC and when an EPC has to be further investigated after an on-site inspection. If input parameters of the EPC are different from the real building data or have been miscalculated by the Qualified Expert, the EPC is cancelled. In that case, the Qualified Expert has to issue a new, corrected EPC by a specific deadline. If the EPC is not issued, then the building permit authority is notified in order to take measures within its jurisdiction.

In 2019, the State Energy Inspection performed 215 controls of energy specialists from a total of 1,331 energy specialists (16% of energy specialists controlled). These controls covered 998 EPCs to verify whether they were processed objectively, truthfully and completely, as the Energy Management Act requires. The controls identified several law violations, and penalties of up to 76,300 € have so far been imposed. This amount does not include penalties from ongoing court proceedings.

State Energy Inspection also performs a quality check of all EPCs intended for construction of a new building or major renovation of an existing building with a total energy reference floor area greater than 350 m².

In 2019, the quality assessment of EPCs in Denmark transitioned from a random selection methodology to a risk-based methodology. The risk-based methodology utilises the data collected by the assessors and stored in the database, by detecting the possible faulty EPCs based on the input parameters. In addition, the Danish Energy Agency conducts quality controls based on complaints received from owners.
Annually, the Danish Energy Agency reviews approximately 200 EPCs.

In Denmark, the assessors can receive different levels of penalties when violating the rules regarding EPC issuing:

1. In case of error, companies must correct the certificate.
2. In case of serious errors, the company will get a warning notice and the certifying accreditation agency is informed.
3. In cases where errors are serious and/or repeated, a public notice will be made available online as an additional sanction. The certifying accreditation agency is informed and is able to suspend the certification of the company if they find it appropriate. Companies must carry out their own quality control according to DS/EN ISO 9001.

Besides this risk-based methodology, validation of input parameters in the software for EPC issuing has been developed and is being continuously implemented from 2019 on. This initiative will prevent the entering of incorrect and unlikely values when preparing the EPC. Based on the results from the risk-based quality assessment, further validations to the input parameters will be implemented. 

The Danish Energy Agency has systematically worked on increasing the overall quality of the EPCs, with the aim of making more effective use of energy labels. A series of meetings with stakeholders who have special knowledge of the scheme have been conducted. Based on these expert inputs and analyses made by the Danish Energy Agency, a number of concrete measures will be implemented to ensure energy labelling which promotes an energy-efficient building stock in Denmark.

This means that the energy labelling scheme will try to take into account the different needs of building types by dividing them into three categories, which are: smaller existing buildings, larger existing buildings and new buildings.

Initiatives aimed at improving the quality and promoting the use of energy labels are initiated for each category, e.g.:

• Conduct behavioural experiments with user-driven design and interactive dissemination of the energy labelling report;
• Make building data from energy labelling more accessible to owners of large buildings in relation to operation, maintenance and energy optimisation;
• Clarify the role of energy labelling companies to ensure that energy labelling is an independent control of the building's energy performance.

CPTRA makes random checks on EPCs and deals with complaints. Since 2016, the value of checks has been rising; in the year 2020, more than 600 EPCs were checked.

The most common error made on calculated EPCs (for building permits) is a difference in source data through the project (for example U-values, window areas, thermal bridges, etc). To be more specific, calculated EPC is based on the preliminary design stage of the building. However, some data might be different throughout the project (e.g. U-values in construction part vs. HVAC part). Such mistakes must be corrected for the building permit to be issued by the local municipality.

Errors made on EPCs based on energy consumption calculations are mostly minor (for example, weighting factor) and are expected to be eliminated once the move towards a more dynamic EPC, where the energy class will be displayed live and visible on a 3D-Twins platform, is completed. In these situations, the utility consumption values will be automatically fed into the platform. Also, the weighting factors of different energy carriers will be assigned automatically. When completed, individually creating an EPC will only require checking the automatic values and verifying the automatic data input, to the best of one's judgement.

So far, no penalty has been imposed. A penalty can be as high as 64,000 € for a company, or 6,400 € for individual experts, if the shortcomings are not corrected.

The ARA is the administrative authority ensuring the quality of EPCs and qualified experts, and the appropriate preparation and use of the certificates. The ARA controls EPCs based on the EPBD, Article 18, Appendix II, and partly checks the input of the building information data, the accuracy of the presented calculations, and the appropriateness of the suggestions given for improving energy efficiency.

Additionally, the ARA can initiate enforcement measures in case of negligence on the part of the building owner or the qualified expert. Measures are administrative, not penal, and include requests, warnings, orders, conditional fines, and suspension of the qualified expert. The conditional fines are set according to building type, and for public buildings (for municipalities) the size of the fine is also related to the size of the municipality (number of inhabitants).

The national database for EPCs was established on 1 May 2015 and has been used to control certificates ever since. All EPCs are produced and electronically signed through the database, which automatically checks the input data to ensure the quality of the EPCs produced.

Experts who want to become ‘diagnosticians’ (experts qualified and certified to issue EPCs) much justify theoretical knowledge of buildings, go through a 2 to 3 days training and pass a final exam. Once accredited, the expert has the right to deliver EPCs for a period of seven years. According to a regulatory requirement, the work of each qualified expert must be checked on a continuous basis.

The certifying body must verify that each point of the regulation is abided by and can withdraw the expert’s certification, either temporarily or permanently, in case some fields in the EPC are not properly filled.

The EPC database is also a useful tool for landlords, allowing them to check the accuracy of their EPC.
Finally, there is a directory of qualified experts available, so landlords can check that the qualified expert is certified.

The independent control system works efficiently and allows keeping both efforts and costs as low as possible. It works without general data storage in a central database. A commissioned and authorised body ('Deutsches Institut für Bautechnik – DIBt') holds a central EPC register without generally collecting the contents of the issued EPCs. The register collects data from the assessor concerning the type of EPC issued and the location of the building. Each EPC receives an individual registration number and is part of the random quality checks. The contents of the EPC and additional input data are only collected for EPCs that are drawn as part of the random samples. For the purpose of later long-time storage in a database, and after all the checks are done, the datasets have to be anonymised to secure data privacy for property owners, which is held in high esteem in Germany.

The first step of plausibility checks is carried out automatically by DIBt on behalf of the local authorities. The current Energy Saving Ordinance came into force on 1 May 2014 and introduced the registration of EPCs. So far, 2,984,254 registration numbers were allocated, out of which 5-6% got into the random first step check. The results are communicated to the local authorities (location of the building) and the assessor. Further and more detailed controls (2^nd and 3^rd level check) are the responsibility of local authorities, as they are also responsible for imposing fines in case of breaches of the regulations, e.g., incorrect issuing of EPCs, refusal to issue or to submit an EPC, or deliberately including incorrect information in EPCs.

The Departments of Energy Inspection are responsible for carrying out random EPC control checks and checks on specific EPCs after complaints.

The checks include:

1. control of the data inputted into the electronic database used for the EPC calculations;
2. on-site inspection of the building in order to verify the data used for the EPC.

The quality check procedure utilises a tolerance of 5% from the total primary energy consumption of the existing building or a variation of more than one energy class. Penalties to energy auditors are calculated according to a specially developed algorithm from the Departments of Energy Inspection of the YPEN, and covers all types of issued penalties (according to Law 4409/2016, Article 56).

The penalties foreseen in case of non-compliance remain the same since 2013, and include fines and temporary or permanent suspension or permanent exclusion of the auditor, depending on the severity of the violation, the consequences, the building floor area and the possibility of reoccurrence. Law 4409/2016 (Article 49, paragraph 4) introduced a new range for the fines, amounting from 200 € to 10,000 €, instead of the previously defined (by Law 4122/2013) range of 1,000 € to 10,000 €.

From 2011 until the end of 2019, there were 43,846 EPCs randomly checked, of which 277 were checked on-site. These figures do not yet include 2019 figures from the Department of Northern Greece, as the relevant annual report of the Inspection Bodies has not yet been issued.

Until the end of 2019, 138 penalties were issued to energy auditors (a combination of fines and yearly suspensions).

An EPC electronic registration system has been in operation since 2013. An EPC is only valid after upload into the online system. Roughly, 150,000 EPCs are issued annually.

The online system also serves as a first level of quality control: first, it automatically checks the permit of the energy expert. Following this step, the system checks for unrealistic figures.

The second and third control levels are performed by the Hungarian Chamber of Engineers. Randomly selected, 2.5% of the EPCs are verified by an office check and 0.5% (20% of the 2.5%) are verified on-site. Both controls are carried out by independent experts and all control results are registered in an electronic database. From the beginning of 2017, targeted controls are also possible.

If the quality control detects a miscalculation leading to a difference of more than two energy classes, the expert loses his licence for 3 years. Since 2017, further sanctions can be applied, including fines and penalties.

The selection of EPCs for audit is carried out on both a targeted and a random basis with due consideration for risks associated with the EPC assessment processes. SEAI randomly selects a statistically significant percentage of all the EPCs issued annually and subjects those certificates to verification. Routine follow up audits identify if findings from previous audits have been adequately resolved. In addition, SEAI may, under its Quality Assurance System and Disciplinary Procedures, require EPC Assessors to participate in mentoring visits arranged by its auditors to facilitate further training.

SEAI publishes a detailed Code of Practice and Quality Assurance and Disciplinary Procedure. The impact of errors is sized to determine the audit outcome: compliance, severity 3, severity 2 and severity 1. Findings of non-compliance may lead to the accumulation of penalty points and/or revocation of the EPC data file(s) as follows:

Table 12: Classification system for audit findings of non-compliance.

Suspension or termination of registration of an EPC assessor may result where 10 penalty points or more are accumulated within the previous 2-year period.

Regions and autonomous provinces are responsible for the quality assurance of the EPCs. Some of them have started performing compliance checks on EPC reports, in numbers of a few hundred controls per year.

The national legislation requires 2% of all EPCs to be annually checked, starting from best classes. The regions may choose to bypass and/or adjust this rate following an analysis of reports, and to perform on-site checks only when strictly necessary.

The penalties applied by regions range from 300 € to a maximum of 10,000 €, according to the infringement. There is a gradual tolerance of errors depending on the number, type and repetition rate, as the system objective is to improve the quality of EPCs, considered quite low at present. The transposition of Directive 844/2018 introduced further quality checks on EPCs to increase the effectiveness of certificates themselves as well as the building stock analysis based on EPC register data. In the case of fraud, the penalty may have more severe legal consequences.

The Building Information System (BIS), which is an electronic system that brings together all the information about the construction process and the parties involved in a project, has been implemented since 2016. BIS includes a Register of Independent Experts in the Field of Energy Performance of Buildings and a Register of Certificates of Energy Performance of Buildings. The State Construction Control Office periodically selects documents of independent experts for random testing purposes and inspects the selected documents. Also, for every project supported by European Community funding, energy performance compliance is required. In any other building, if a complaint is received, the certification body must check the EPC, energy audit or inspection report received by the qualified experts. In case of a violation, the certification body can apply penalty points.

The Ministry of Energy and Spatial Planning organises random checks of EPCs in order to verify their compliance with the legal requirements. These controls comprise two levels. The first level consists of a plausibility check of the calculated values, whereas the second level is a deeper analysis of EPCs containing non-plausible elements. The control consists of a check of all data entered into the EPC. Penalties in the form of a time-limited suspension can be imposed on experts in case of deviations from the regulation.

To ensure a high quality of EPCs and to achieve a level of independence in the auditing process, the Independent Control System has been entrusted to the Malta Competition and Consumer Affairs Authority (MCCAA) by means of a contract of service, following a memorandum of understanding. The verification system devised in conjunction with MCCAA. The control system consists of a number of checks on a statistically significant sample of certificates. During the sampling process, at least one certificate from each active registered assessor is verified. Control is carried out on a yearly basis guided by Schedule II of the EPBD.

The main findings of the verification exercises indicated typical shortcomings in issued EPCs. The lack of information on the exact characteristics of the building fabric was the most common deficiency encountered. The root for this has been identified and training may be provided to assist and train assessors to be able to assess the existing building fabric more precisely.

Another shortcoming relates to the fact that the input of building characteristics and system data is mostly based on assumptions. Significant improvements to the provided training are needed in order to enhance the quality of EPCs.

Following the audit report, a notification letter highlighting all errors identified is sent to all assessors so that these may be avoided in the future. Whenever large discrepancies in EPCs are apparent, the assessor in question is asked to resubmit a new certificate addressing the identified issues, and pay the relevant resubmission fee.

For the ‘VEL’-system, running from 1 January 2015 to 1 January 2021, ’Recognised experts for energy labels in residential construction’ (‘Erkend Deskundige Energielabel Woningbouw’) must meet the requirements of the ‘Energy Index’-system or pass a new, simplified exam. The simplified exam is organised by ‘SVMNIVO’¹⁴, the exam centre for the real estate industry. In addition, experts must follow a training course from RVO to learn how to operate the web tool on the RVO website¹⁵.

Checks and sanctioning are part of the system that is operational since 1 January 2015 and carried out by the ILT.

In 2016, 1,571 EPCs were checked by the ILT. In 77 EPCs, the ILT found errors in the input data. More than 95% of the EPCs were correct. Recognised experts in whose EPCs errors have been detected have been checked again in early 2017.

Up to the end of 2019, over 6,000 EPCs have been checked. In 8% of these EPCs one or more mistakes were found. The experts in whose EPC(s) a mistake was encountered received a fine.

Quality assurance of EPCs takes place at three different levels:

• During registration, the energy certification system performs data validity checks, and there are strong restrictions on what data is eligible. Normally, the data has to be within a certain range, thus excluding typing errors and misunderstandings. Also, there are restrictions to avoid false values. Most important is that the grade A energy level cannot be achieved unless a building leakage test has been performed according to standard procedures and the date of the test has been registered.
  For the simple registration of houses or apartments, there are even stronger restrictions as to what types of data are allowed to be registered. Only experts who have the required professional knowledge and competence are allowed to assign and input data.
• The most important quality assurance is the control performed by the buyer who reads the EPC and demands that the data be correct. The EPC is designed to enable the reader to understand the main input data used. Sellers are in general well aware of the obligation to give correct information to the market.
• Independent control. The first controls by NVE (2011-2012) concentrated on the existence of the EPC and, if relevant, whether the EPC was presented to potential buyers, or in the case of large non-residential buildings, to the users of the building. During the control carried out in 2014, the sample in question was also controlled regarding the input values of the calculation of the energy label.

The first sanctions were issued in 2015 over the lack of a valid EPC or inspection report. Of a sample of 81 non-residential buildings, 61 building owners were addressed with sanctions warnings. In this first round, the owners were given ample time to conform to the requirements. Compulsory fines were handed down to eight (8) companies covering 13 buildings. All the cases were finalised in December 2015 with fines for five (5) companies covering seven (7) buildings.

During 2016 and 2017, a total of 96 non-residential buildings were controlled. Seventy-seven (77) of these checks aimed to verify the existence of an EPC. Thirty-seven (37) of these concerned new buildings. The remaining 19 buildings were subject to EPC control and on-site inspection, on account that they had top-tier classification (A or B). The EPCs of ten (10) buildings showed minor discrepancies, which was pointed out. In 32 cases, serious (or multiple) discrepancies were shown for which a sanctions warning had to be issued. This control round has also served as a basis for the identification of possible improvements during Enova’s evaluation of the present scheme.

In 2018, NVE controlled 69 non-residential buildings above 1,000 m² that were listed for sale or rent. Thirty-nine (39) of them had no EPC. They were issued with a sanctions warning. Deviations existed in more than 50% of the non-residential buildings used by commercial businesses; thus, there is a clear indication of negligence amongst building owners.

Due to a reorganisation of the control group and some backlogs from 2018, the focus of 2019 was on regrouping and planning for 2020. However, six buildings (above 1,000 m², for lease) were controlled. One of them had a compliant EPC, four had no EPC and one had a non-compliant EPC that was issued without following the dynamic calculation method.

In 2020, NVE controlled the existence and compliance of large (by number of students) middle schools of municipal ownership. Middle schools were chosen as subjects because they are frequented by the public and are often above 1,000 m² in size. The main goal of the control was to raise awareness about the EPC in the public sector. Out of 20 controlled buildings, nine (9) buildings had fully compliant EPCs, five buildings had non-compliant EPCs and six (6) buildings had no EPC. One sanctions warning has been issued.

Since March 2015, there is a direct mechanism of quality assurance of EPCs in Poland, which is based upon the central register for the energy performance of buildings. EPCs are quality controlled ex officio or by request. So far, less than 20 EPCs have been controlled upon a request. The number of EPCs controlled ex officio in the period 2015 - 2020 is 550. Following these controls, 30 qualified experts lost their authorisation. Comparatively, before 2015, three (3) qualified experts had lost their authorisation.

During control, checks are made, among other factors, on:

• calculation results;
• efficiency of technical building systems and U-values compared with requirements concerning thermal insulation of the building envelope components;
• energy demand indicators, energy consumption and categories of cost-effective recommendations, correctness of description, etc.

There are no penalties foreseen for minor faults. Fault tolerance may reach up to 10%, depending on where the error was made.

In cases of intentional adoption of incorrect technical assumptions (e.g., improving the indicators of energy demand) there is no tolerance of errors.

There are also penalties for drawing up EPCs without the necessary qualifications, or without liability insurance for damages caused in connection with the preparation of an EPC.

Moreover, according to the Act on the Energy Performance of Buildings as well as the civil law, an EPC containing false data on energy use is considered a product with a physical failure. Potential conflicts between the qualified expert and the client in this matter will be settled in court.

Proposals to improve the central register of EPCs are currently being prepared. Following their introduction, it will be possible to check the correctness of EPCs more quickly and easily.

In 2015, a specific regulation²² regarding quality assessment of EPCs came into force. This regulation clearly states the criteria, rules and error tolerance, as well as the criteria required to reissue the EPC.

Two types of EPC quality assessment exist: a short assessment, and a detailed assessment. The short quality assessment involves the qualified expert uploading all EPC-related documents and information into the database, whilst the detailed one is a complete duplication of the necessary calculations that support the EPC, including a second site-visit. The detailed assessment can be triggered at random or whenever needed to better support the quality assessment.

Tolerances and out-of-range values are defined in the regulation and are used to quantify the number and severity of errors or mistakes that can exist in an EPC. As a consequence of these analyses, and if the EPC is to be considered invalid based on deviations from a set of parameters, a reissue by the expert is necessary. Additional penalties might be applicable to the expert if no action is taken to minimise the impact of the errors made.

Since 2014, the Slovak Trade Inspection, has been responsible for the quality assurance of EPCs. It also has the right to act against the building owner and against the person authorised to issue the EPC. Random control is performed by means of central information system. The online web interface controls the data inputs for each individual EPC submitted, up to a certain level.

Control on technical quality is the responsibility of the Ministry of Infrastructure. First-level control is automatically performed by the EPC electronic registry, during the last step of the EPC entry. Validity and plausibility of data in an EPC are examined by validating the data against the EPC and other public real estate registers. If an EPC does not meet the check, it cannot be issued. Every year, the Ministry makes a random selection of all annually issued EPCs and supervises the selected ones. The sample must be sufficiently large to provide statistically significant conformity results. Second-level control is performed by the Inspectorate of the Republic of Slovenia on behalf of the Ministry of the Environment and Spatial Planning. Whenever a quality problem of an EPC is claimed, the inspectorate checks the status and the issued EPC and then declares its decision regarding the quality with a decision and, if relevant, a penalty. The penalty depends on the mistake, i.e., if necessary, one must correct the EPC as well as issue and store a new EPC in the register.

In addition to incorporating EPC information into their databases and issuing the registered energy performance label, the aforementioned Autonomous Communities registries are also responsible for control and inspection works.

Control and inspection of EPCs has been established in a differentiated manner in each region, while maintaining basic requirements, such as establishing a statistical control based on the obtained qualifications, as well as establishing mechanisms to prioritise some controls and carrying out inspections in several stages with several degrees of depth.

The current situation is that 100% of the certificates are automatically controlled, thanks to computer mechanisms that evaluate all the certificate data, and generate automatic notices about certificates that do not correspond with reasonable average parameters.

Additionally, a document control is carried out on nearly 50% of the certificates using complementary information.

There are also specific inspection mechanisms that reach 0.5% of the certificates in terms of information review and improvement measures, and a deep inspection system, with a visit to the building, which occurs 0.05% of the time.

The number of inspections and controls as of 2017 are given in Table 1.

Table 1. Number of inspections and controls as of 2017 in Spain.

Quality Assurance

Quality assurance is made through automatic controls in the electronic certification system for all EPCs. These controls include, e.g., the level of energy performance, the heated area, the real estate information and the climate data. Controls are complemented with analyses of the EPCs database. If a certified energy expert does not meet the requirements concerning competence, access to the register and the EPC’s issuing permit can be withdrawn.

The role of the independent energy expert

The EPC is issued by an independent certified energy expert on behalf of the building owner. First, an inspection is carried out, where an energy expert, preferably together with the building owner, walks through the building. The energy expert then prepares the EPC in Boverket’s EPC register. Once the EPC is registered, the energy expert submits it to the building owner. The energy expert is responsible for ensuring that the EPC is prepared correctly.

In order to issue EPCs, the energy expert must be approved and certified by an accredited certification body. The certification body assesses the expertise of the energy expert. This means that the energy expert must meet the requirements and qualifications regarding training, experience and suitability for assignment, which are regulated in Boverket’s regulations and general advice (2007:5) for the certification of energy experts (henceforth CEX).

To issue an EPC or inspection protocol, the energy expert must be independent in relation to the building owner. The expert shall make recommendations on cost-effective measures to improve the energy performance of the building. The recommendations shall be objective and adapted to the needs of the building. A building owner who has an independent expert employee may use him or her to issue an EPC or inspection protocol. This must then be stated in the EPC or inspection protocol.

Certification and accreditation bodies

A certification body tests and approves the person who wants to become a certified energy expert. The certification body ensures that the energy expert meets the requirements regulated in CEX. If the energy expert exhibits unsuitability for the task, the certification body may choose to revoke their certificate.

Swedac, (Swedish Board for Accreditation and Conformity Assessment) is a government authority for quality and safety. Their task is, among other things, to audit and approve certification bodies that issue certificates to energy experts. This is done on the basis of European and international standards.

Validity audit

In the Ordinance (2006:1592) on energy performance certificates, Boverket is required to conduct a yearly validity audit covering both input data and EPC results. The 2020 validity audit report concludes that the recently developed automatic user input validation function is effective in reducing unreasonable input values. The developed normalisation procedure in BEN, of the energy performance values in case with abnormal use, has also worked out with good results.

The Government introduced Scheme Operating Requirements (SORs) in 2010 to ensure all Accreditation Schemes achieve common minimum quality standards. The most recent update of the SORs took place in 2019⁴⁶.

SORs require Accreditation Schemes to quality assure the outputs produced by their accredited energy assessors. The Government carries out audits of the quality assurance systems implemented by Accreditation Schemes to monitor compliance with the SORs. These requirements ensure that a statistically significant percentage of certificates is checked.

In the most severe cases of malpractice the Government may suspend or revoke an Accreditation Scheme’s approval. To date, the Government has made limited use of these powers. Similarly, Accreditation Schemes may remove their members’ accreditation to operate as an Energy Assessor.

Compliance levels by sector

The Government is not responsible for enforcing compliance. Compliance is enforced by Local Weights and Measures Authorities, through Trading Standards, which may publish a compliance report.

Enforcement with building owners and real estate actors

Local Weights and Measures Authorities have the powers to require the “relevant person” (e.g., the seller, the prospective landlord or the person who constructed the building) to produce copies of the EPC for inspection. In 2012, these powers were extended to include persons acting on behalf of the “relevant person”, e.g., the Estate or Letting Agents.

It is the decision of the Local Weights and Measures Authority or its authorised officer to determine what action is appropriate when they find that breaches of the Regulations have been committed. It may be that providing advice and information is sufficient to ensure compliance. In some cases, educating the relevant person regarding the benefits of knowing the cost-effective energy efficiency improvements they could make may be all the encouragement needed to ensure compliance with the requirements. However, in some cases, it may be that only imposing a penalty will do. It is for the enforcement authority or its authorised officer to decide the appropriate course of action in these circumstances.

Penalties for non‐compliance vary depending on building types:

• for residential properties, the penalty is £200 (~232 €);
• for non‐residential properties, the penalty is 12.5% of the rateable value of the building, subject to a minimum of £500 (~580 €) and a maximum of £5,000 (~5,800 €).

Wales adopted the same approach as England. See England report for details.

English Accreditation Schemes are approved to operate in Northern Ireland. In 2020, there were no Accreditation Schemes approved to operate in Northern Ireland only. Therefore, the English Quality Assurance requirements apply in Northern Ireland. See England report for details.

Under the Operating Framework, Approved Organisations have Quality Assurance responsibilities. Since 2013, Approved Organisations must check a representative sample of EPCs, e.g., a minimum 2% of all EPCs produced must be checked. Checks repeat the EPC calculations using data on the register. In 2019, 246,727 EPCs were produced and 5,645 (2.29%) were checked. Most checks are desk-based. Assessors' outputs are checked every six months at the minimum. Poor performance can lead to targeted auditing, re-training, suspension, or being struck off.

The Government audits Approved Organisations to ensure compliance with the Operating Framework. Approved Organisations who fail to meet the terms of the Framework are subject to a schedule of corrective action and may have their agreement terminated.