2.IV.vii. Enforcement and impact assessment of inspections – OVERVIEW

Enforcement and penalties

For the enforcement of inspection laws, penalties are imposed under the relevant laws of some of the Austrian provinces²¹, but there are no statistical data indicating frequency and level of penalties, which have yet to be imposed.

Quality control of inspection reports

The Austrian provinces conduct quality controls of inspections reports regularly. Some of the Austrian provinces had combined the first full inspections of heating systems with an information and training for inspectors²², thus controlling the quality of inspections (mentioned above) and of the inspectors as well. These actions had been supervised by the administrations of the provinces. Results show that many installations had hydraulic problems or had inefficient pumps and/or oversized boilers.

Further information campaigns are based on the results of these actions. The process of quality control is still under development in Austria.

Impact assessment

There are no statistical data about the impact of the regular inspections of heating systems corresponding to the requirements of Article 14, but it can be asserted that the effect of the additional requirements is overestimated, and not as important as the savings potential which could already be earned by the emission limits and minimum performance requirements. Furthermore, Directive 2009/125/EG includes specific requirements for heating systems to guarantee the implementation of energy-efficient technologies.

Approximately 2,400 professionals carry out acts within the framework of the regulations on technical installations in Brussels; among them, 5,200 approvals have been processed (5 approvals possible per professional depending on the type of regulatory act; a professional can therefore achieve multiple approvals).

Out of an estimated 350,000 boilers in the Brussels-Capital Region (the precise number of water heaters is not known):

• Approximately 5,000 heating systems are subject each year to a control after installation or replacement of a boiler, which means that these systems are efficient (estimated at 80% efficiency calculated on the higher heating value – also known as gross calorific value – taking into account losses linked to production, distribution, heat emission and regulation).
• From 1 January 2020, all attestations of periodic inspections are processed by the administration. This will soon allow the assessment of the impact of such a control system.

Theoretically, 10% of the boilers and water heaters should be declared non-compliant and therefore adapted or replaced by more efficient systems (see point on the control after placement or replacement of a boiler).

Enforcement and penalties

Municipal supervisors and supervisors of the police zones may sanction the owner or user of a heating or AC system when a mandatory inspection has not been carried out. A list of possible sanctions is included in the decree of 5 April 1995 concerning general provisions relating to environmental policy (e.g., a fine that depends on the kind of infraction). There are no statistics available on the use of these sanctions.

Quality control of inspection reports

The number of technicians recognised to inspect liquid or gaseous fuels exceeds 5,000 and 8,000, respectively. Over the years, hundreds of randomly selected recognised technicians as well as technicians against whom complaints had been made were subject to quality control by an accredited inspection body, which is appointed by the government. If quality requirements are not met, the technician will be warned, fined or prosecuted and/or the recognition can be suspended or withdrawn. Non-recognised technicians performing any of the aforementioned mandatory inspections that are reported to the government are prosecuted as well.

Around 250 AC-energy experts have been accredited. Recognised AC-energy experts must provide information on all inspections conducted in the last three (3) years to the supervising government upon request. The government can suspend or withdraw the recognition in specific cases. A statistically significant number of issued reports will be subject to quality control by (an independent accredited inspection body appointed by) the government. No penalties have been levied yet.

Impact assessment

No impact assessment has been performed.

a. Enforcement and penalties

According to the Walloon Environmental Code¹⁶, compliance control in accordance with the relevant executive orders is the responsibility of the Department of Environmental Police and Controls of the Walloon Region. This decree also defines the penalties that may be imposed on persons violating these regulations.

The owner of a boiler is punishable for not performing inspections. The category of the infraction is set in the 'Loi relative à la lutte contre la pollution atmosphérique'¹⁷ (Federal Law of 28 December 1964). Sanctions are provided in the Environmental Code¹⁸ Decree of 27 May 2004 and Executive Order of 17 March 2005. The associated penalties are a fine ranging from 100 to 100,000 € or from 8 days to 6 months of imprisonment. The issuance of a statement for infringement is rare (about two (2) to three (3) statements per year).

Due to a lack of human resources, controls operated by the pollution repression unit of the Walloon Region up until now mainly occur in response to complaints.

b. Quality control of inspection reports

For heating, as regards inspections on specific energy aspects, no inspection reports have yet been validated.

Quality assurance for AC will be the same as for heating systems, but inspections have not yet begun (see section 2.IV.v., above).

c. Impact assessment

No impact assessment has been made for heating inspections. The goal for Wallonia is to perform such an assessment when the new systematic electronic data input for inspection reports is operational.

No energy impact evaluation can be made regarding AC system inspections as inspections have not yet begun.

Enforcement and penalties

Control over the activity of the inspectors is undertaken by means of checks. On the basis of the results of the check, the SEDA may:

• issue mandatory requests to the inspectors, to eliminate any violations ascertained, accompanied by a time limit for compliance with the requests;

• draw up written statements recording administrative violations.

Any inspectors who fail to comply with the mandatory requests shall be liable to a fine of BGN 2,000-5,000 or to a penalty of BGN 10,000-30,000.

Up to the end of 2016, no fines/penalties have been imposed by the SEDA.

Quality control of inspection reports

The verification of inspection reports is performed by the SEDA by systematic or random sampling of all the inspection reports issued annually.

The total number of inspection reports issued in 2015 and 2016 amounts respectively to 337 and 182 (Table 4). An independent random control was carried out by the SEDA on all these inspection reports.

Impact assessment, costs and benefits

Currently, no impact assessment has been made.

So far, there have been no studies comparing the costs and benefits of inspections of heating, AC and ventilation systems. Based on the feedback received from the inspection companies, it is estimated that only a fraction of the inspections results in measures undertaken to lower the energy consumption.

Enforcement and penalties

Regular inspections of heating and cooling/AC systems of a building must be performed by authorised personnel. Authorisation is granted by the Ministry for an indefinite period but with the obligation of professional training at least once every two years.

Enforcement and penalties for the owner of a building are the same as for the EPC. No fine has yet been issued.

Quality control of inspection reports

The quality control of inspection reports is performed by the legal personnel authorised to carry out control checks. Quality control shall be carried out on reports that are randomly selected and based on complaints. The authorised personnel check the completeness of the report and the proposed measures to improve energy efficiency.

The report on the regular inspection of heating and cooling/AC systems of a building is declared invalid if the control determines that the report contains less than 30% of the required data and there is no justification for this in the report. Authorised personnel who issue invalid reports shall be sanctioned by means of fines and annulment of authorisation in the case of three (3) or more reports being invalid.

So far, 94 reports on regular inspections of heating systems in buildings were issued and two (2) for cooling/AC systems, all as part of the report on building audits that were performed for the purpose of issuing EPCs. Up until now no inspection reports have been controlled.

Impact assessment, costs and benefits

Since regular inspections of heating and cooling/AC systems started recently and due to the small number of issued reports, no control has yet been performed and no assessments of impacts have been carried out.

Enforcement and penalties

A fine of up to 30,000 € can be implemented in the case of a central heating system not being inspected. However, no fine has been implemented so far. At this stage efforts are focused on informing the public about the benefits of inspections.

Quality control of inspection reports

At the end of each year, the MECI requires all inspectors to submit the reports they conducted during the year. The reports are then checked to see if they have been completed appropriately and include recommendations. Between 2016 and 2019, 5% of the annual AC and heating systems inspection reports were quality checked without significant observations. 

Impact assessment, costs and benefits

It is estimated that a heating system inspection in a house requires three (3) working hours, and the inspection of a heating or AC system in a medium-sized commercial building a whole working day. Benefits for the owner occur when they apply the recommendations suggested by the inspector in the inspection report, which can either be of no cost, e.g., correctly setting a thermostat, or of a larger cost, e.g., replacing the boiler. The owner has the right to decide whether or not to apply the recommendations and when to do so if they choose to. It is estimated that the application of inspections may result in a total energy savings potential in buildings of around 10%.

Enforcement and penalties

Both the inspection and the inspection report can be issued only by energy specialists licensed to perform heating systems and thermal energy distribution or AC systems inspections. The report must be objective, complete and correct. If the inspection report is improperly processed, a penalty of up to 185,000 € can be imposed by the State Energy Inspection.

Quality control of inspection reports

The State Energy Inspection checked 74 heating and AC systems inspection reports. The control revealed 32 erroneously processed reports. Also, 28 energy specialists were subject to control. The total amount of penalties imposed was 3,200 €. This figure does not include penalties from ongoing court proceedings.

It is the responsibility of the owner of an AC installation to get the required inspections to confirm whether conditions are met. If the mandatory energy measurement or inspections are not carried out, the owner of the AC may face fines.

In 2013 (latest figures), 131 inspections of AC and ventilation systems were carried out and reported. Of those, 27 inspection reports were controlled by the Danish Accreditation and Metrology Fund.

Since August 2020, the 'Requirements for evaluating energy efficiency of building technical systems that considerably affect building energy efficiency and data requirements to be presented to Building Register' regulation¹² describes and enforces actions to assess energy efficiency through inspections of systems with a rated heating or cooling capacity of over 70 kW. This also includes systems to be installed, replaced or renovated in existing buildings.

No impact study/data/statistics are available yet.

Not applicable in Finland as option B is used.

Enforcement and penalties

Penalties are set in the regulation (Art L.226-2 et L.226-8 of the environment code). Controls can be performed by officers of the General Directorate for Competition Policy, Consumer Affairs and Fraud Control. If the regulation has not been properly adhered to, the relevant authority can apply several types of measures:

• carry out a new inspection of the AC system at the owner’s expense;

• oblige the owner to deposit the equivalent of the inspection cost as a guarantee until compliance is achieved, whereby the sum is returned;

• oblige the owner to pay a fine;

• force the owner to disconnect from the AC system.

Impact assessment, costs and benefits

AC inspection reports are not collected in a central database so it is challenging to assess precisely the impact of the inspection scheme. The extent of energy savings after an inspection may vary, depending firstly on the decision of the owner to do something or not, and secondly on the extent of the work performed.

Concerning cost-effectiveness of the inspections, an expert, needs one day to perform an inspection, which costs 600 €. Given that inspections occur every five years, this is equivalent to 120 €/year.

Enforcement and penalties

The person or entity in charge of operating an AC system can be fined up to 5,000 € if the inspection is not commissioned in time or not at all. A person who performs an inspection without being entitled to do so (i.e., without having the required professional education and experience) can be fined with such a penalty as well. Since the local authorities are in charge of the penalty system, there are no general numbers indicating the activities for Germany as a whole.

Quality control of inspection reports

The control system for inspection reports for AC systems was launched on 1 May 2014. In 2017, 2018 and 2019, a total of 11,372 new inspection reports were registered. The Federal States have established their individual system of authorities or entities in charge of the sample controls. It is their responsibility to define the samples. The registration authority DIBt provides the control authorities with the addresses of the experts whose inspection reports are drawn as samples. Since the start of the system, 940 reports were subject to control. As a result of a common project, the Federal States have introduced an electronic tool to support the control process in order to get comprehensive and comparable results. Reports by the Federal States about the results of the sample controls are due every three (3) years, the first of which was due in March 2017.

Impact assessment

The requirements for new Buildings in the Energy Act for Buildings (GEG) are going to be reviewed in 2023. Depending on the results of the review, a legislative proposal for further development of the requirements for buildings will be submitted. The affordability of building and living remains a key objective.

Enforcement and penalties

The control and monitoring of the process and the quality of inspection reports on heating and AC systems, fall under the jurisdiction of the Directorate of Environment, Construction, Energy and Mines Inspections of the YPEN. The Directorate is also the authority responsible for controlling the performance of the functions of the energy inspectors and the compliance and application of the related provisions.

Checks are performed automatically and are randomly sampled at a rate of at least 5% or after complaints of an inspection report. They consist of: 

• checking the validity and accuracy of input data submitted by an electronic data form file on the archive of inspection reports, including recommendations; 
• on-site inspection of the building to verify the correctness of the inspection reports.

Energy inspectors as well as owners, managers or tenants of the buildings must provide all necessary information, access to the building and its facilities, and any other possible assistance for carrying out the inspections; otherwise, they shall receive a fine (Law 4122/2013, Article 20).

By the end of 2019, no penalties were issued regarding the inspection reports, and no statistics are available.

Quality control of inspection reports

The Departments of Energy Inspection of Northern and Southern Greece are responsible for the operation of the inspection scheme and the quality control of inspection reports. However, since the official launch of the inspection scheme (at the beginning of 2016), a very small number of inspection reports have been registered and, as a result, no quality control checks have been carried out yet.

Impact assessment, costs and benefits

Regarding the impact assessment of the heating and AC system inspections, since very little data exists after the scheme was put into operation, no study on the impact has been performed so far. Additionally, no studies are available related to the cost and benefit of the operation of the scheme.

As mentioned above, Hungary has adopted alternative measures for the inspection of heating and AC systems. Therefore, the issue of enforcement and penalties is not relevant.

Three per cent (3%) of the 1.2 million boilers operating in Hungary have capacities below 20 kW, 80% have capacities between 20 and 30 kW, and 17% have capacities above 30 kW. Overall, 1,116 million boilers are affected by the EPBD requirement for on‑site inspections. The share of household boilers is 90%, while the share of boilers in commercial and public institutions is 10%.

In 2018, the Ministry for Innovation and Technology sent the report on relevance of equivalent measures to the European Commission. The evaluation of this report is still ongoing.

In opting for the alternative approach set out in Article 15(4) of Directive 2010/31/EU, the proposed approach is to deliver an effective communications campaign coupled with other support actions that will encourage regular inspection of AC systems with associated maintenance, modification and replacement of inefficient installations. The focus is on establishing a well-structured set of initiatives, led by Governmental bodies, aligning with business interests of energy efficiency products and service providers, especially key influencers, in the AC systems sector. This approach is likely to achieve greater energy efficiency improvements when compared to an inspection regime. Ireland has opted for alternative measures for Directive 2010/31/EU Articles 14 and 15. Consequently, enforcement, penalties and quality control of inspection reports do not arise. The impact assessment of the alternative measures is quantified in the reports submitted to the European Commission.

Enforcement and penalties

The enforcement of maintenance established penalties for users in terms of payment of the control(s) and fines. Sanctions for the inspection reports consist of suspension or removal of inspectors from the register.

Quality control of inspection reports

The national register of thermal plants is in progress and in the next years it is expected to hold all data for all regions and autonomous provinces, including the quality control of inspection reports. In the meantime, it is difficult to collect all data, as inspection activities fall under the responsibility of single provinces; thus, data is not centralised.

Impact assessment

To date, no assessment study of the impact of technical building systems inspections has been carried out.

The Ministry of Economics aims to revise the current inspection scheme before the new EPBD transposition deadline.

Enforcement and penalties

With respect to heating systems, non-compliance with the regulatory requirements can be penalised. If a craftsman fails to follow the reception procedure, or if an owner fails to do an inspection, sanctions (penalties of up to 25,000 € and imprisonment of two (2) months) could be applied. The relevant ministries regularly remind owners to meet their obligations and the Chamber of Skilled Trades and Crafts (Chambre des Métiers) regularly exhorts its members to respect the legal procedures. There are no records on levied penalties.

For AC systems, sanctions for non-compliance with existing European and national legal requirements can be inflicted, e.g., by cancelling an authorisation, by fines of up to 500,000 € and/or imprisonment of up to one (1) year, depending on the kind and severity of the infringement.

Quality control of inspection reports

Reception and inspection reports are randomly checked and centrally registered. Inspection reports are controlled with respect to their conformity and in case of non-conformity, sanctions (penalties) can be imposed or administrative procedures can be initiated.

Enforcement and penalties

The new legal notice, 47 of 2018, addresses issues which were not addressed before. It provides clearer definitions and describes responsibilities for both the inspectors and the owners of AC systems, which will enable the Building and Construction Authority to step up the enforcement of inspections and better administer penalties.

Quality control of inspection reports

The quality of heating and AC system inspection reports to date is very good, since the competence level of registered inspectors is very high. The inspection reports submitted for registration have all been reviewed, and any identified deficiencies in reporting were referred back to the respective inspectors to be addressed and resolved, thereby contributing to an improved quality standard of inspection reports.

The Building and Construction Authority has secured the services of Malta Competition and Consumer Affairs Authority for the quality control of inspection reports.

Impact assessment, costs and benefits

The Building and Construction Authority has collected feedback from heating and AC inspectors on the current situation regarding inspections. It appears that the most crucial and demanding element of the first inspection is the gathering of documentation of the systems installed within a building. It also appears that building users are usually not aware of the systems installed in their buildings and lack information on how to best operate such systems. Therefore, the most cost-effective recommendations to achieve energy efficiency are mostly related to the proper upkeep and maintenance of systems, usually requiring minimal interventions on the installed equipment.

As of 10 March 2020, inspections have to be registered in an inspection register. As of the same date, municipalities and Environmental Services are responsible for enforcement of inspections. Enforcement of heating inspections was already carried out by municipalities, whereas enforcement of air conditioning inspections previously lay with the ILT. Municipalities and Environmental Services have access to the inspection register.

Procedures for control and sanctions on inspections are the same as those for energy certification. Control on inspection takes place simultaneously with control on energy performance certification.

Enforcement and penalties

Failure to carry out an inspection may result in a fine for the owner or manager of the building, in accordance with Article 93 point 8 of the Construction Act. Currently, there is no data concerning penalties issued by construction supervision authorities. Judgement on the issues shall be made on the basis of the provisions of the code of conduct in misdemeanour cases. The fine is up to PLN 500 (around 120 €) and is imposed by construction supervision authorities.

From 9 March 2015, in accordance with the Act on the Energy Performance of Buildings, failing to perform an inspection process or carrying out the inspection without qualifications will result in a fine for the owner, the manager of the building, or the expert. The verification of inspection outcomes is made ex officio or by request of the building owner/manager.

Quality control of inspection reports

An ordinance of the Minister of Infrastructure and Development, dated 17 February 2015, on the model protocols of inspection of a heating or AC system specifies that inspections:

• apply not just to the technical condition and energy efficiency of boilers, but to the whole heating system;
• must contain more than a statement concerning proper functioning.

There is a fixed detailed audit scope, including measurements as well as testing and control, which concludes with a five (5)-page inspection report.

The protocols of the inspection of a heating or AC system shall be submitted using the communication system, which is in the central register of the energy performance of buildings.

The person conducting the inspection shall provide a printed report with a reference number given by the ICT system to the person ordering the control.

Impact assessment, costs and benefits

The price for inspection is not fixed. The cost depends on the area of the building, where 1 m² corresponds to around PLN 1 (about 0.22 €).

In accordance with the Construction Act, the protocol of inspections of heating and AC systems should be included in the construction site book, both for existing and new buildings. The authority in charge of the database with inspection protocols is the Ministry of Development.

The reports are registered in the relevant database of the central register and they are randomly drawn for verification.

Enforcement and penalties

No specific action has occurred regarding this topic.

Quality control of inspection reports

No specific action has occurred regarding this topic.

Impact assessment, costs and benefits

No specific action has occurred regarding this topic.

Enforcement and penalties

For the purposes of monitoring, once a year, at the latest by 31 January, licensed bodies are required to send an electronic copy of all inspection reports produced in the previous year to the SIEA (on behalf of the Ministry). The owner or administrator of a building or system may be fined if he/she: does not arrange an inspection before the date set (Tables 4 and 7); does not keep the inspection report until receipt of the report from the next periodic inspection; does not submit a report from the last inspection to a new owner; or does not provide a certified copy of the report from the last inspection to a tenant. Owners, however, are not fined for a negative inspection result. The owner (or administrator) is not required to implement the recommendations that the qualified expert includes in the inspection report.

The Slovak Trade Inspection is responsible for compliance checking for both inspection systems. In case it is found during the check that the inspections carried out by certain qualified experts were not undertaken in accordance with the regulations, the ministry is allowed to remove that particular qualified expert from the register. So far, only one expert has been removed from the list of qualified experts in 2013, but this was for reasons other than shortcomings identified by supervisors. If a licensed body fails to send the report from the inspection to the ministry, it can be fined up to 200 €.

Quality control of inspection reports

All inspection reports are registered in the monitoring system administered by the SIEA. The ministry (or the SIEA on behalf of the ministry) checks a statistically significant percentage of inspection reports received every year, and at least one inspection report submitted by each licensed body is inspected. Quality control is similar for both inspection systems and is focused on both formal fulfilment of the legislative requirements and the content, and in particular the calculation procedure and the final results written in the particular report. Key findings are subsequently followed up in the training process. In 2019, nine licensed bodies produced 118 AC system inspection reports, from which nine reports were checked for quality. Regarding the heating system inspections, 37 licensed bodies sent 600 inspection reports, and 37 of those reports were quality checked.

Impact assessment, costs and benefits

The findings of quality checks carried out on inspection reports were incorporated in improvements to the training process and were communicated during the regular professional re-training (42 qualified experts for inspection of heating systems, and 11 qualified experts for inspection of AC systems in 2019). Key findings and recommendations based on the analysis of regular inspection reports were communicated during information activities, meetings and conferences featuring state authorities, public bodies and municipalities and were taken into account in the preparation of the training process for professionals provided by the SIEA.

Enforcement and penalties

According to Article 65 of the Act on Energy Efficiency, a fine of 1,000 € to 10,000 € shall be imposed for a misdemeanour on a legal person, being the owner of the building or its individual part in which the AC system is installed, if they do not provide for a regular inspection of the AC system.

• A fine of 1,000 € to 10,000 € shall be imposed on a sole proprietor or an individual who carries out an activity independently for the same offense.
• Additionally, a fine of 100 € to 500 € shall be imposed on the responsible person of a legal person, the responsible person of a sole proprietor, the responsible person of a self-employed individual or a responsible person in a state body or self-governing local community.

The same penalties are foreseen for failing to provide for regular inspections of heating systems.

Quality control of inspection reports

Article 46 of the Act on Energy Efficiency prescribes that expert supervision over inspection reports is carried out by the Ministry. Every year, the Ministry supervises a randomly selected, at least statistically significant share of all annual reports on the inspection of AC and heating systems and verifies these reports. If, in the process of expert supervision, the Ministry doubts the correctness of the inspection report, it shall inform the competent inspectorate of the findings.

The first formal quality controls of AC inspection reports based on the Energy Act were performed in 2016.

Impact assessment, costs and benefits

Impact assessment is not yet available at this stage.

Enforcement and penalties

There is no specific registry that holds the aggregate information of the nineteen (19) national inspection bodies.

Quality control of inspection reports

A number of explanatory and consultation guides have been developed to support specialised technicians in providing higher quality AC systems. The guides are published on the official website of the Regulation of Thermal Installations of buildings:

https://energia.gob.es/desarrollo/EficienciaEnergetica/RITE/Reconocidos/Paginas/IndexDocumentosReconocidos.aspx

The guides are summarised in Table 2.

Table 2. Published guides on control, design and inspection.

Impact assessment / Costs and benefits

There is no economic analysis and impact on that matter.

Boverket is responsible for supervision and validity control (see also 2.III.ii) of EPCs and inspections.

As stated in Article 18 of the EPBD, EU Member States shall ensure that independent control systems for energy performance certificates and reports on the inspections of heating and AC systems are established. In Sweden, this is the responsibility of Boverket, that a validity check on data used for the preparation of energy performance certificates as well as on the results stated in the energy performance certificates is carried out yearly. As of 2021, this validity check also includes inspections of heating and AC systems.

The impact assessment BFS 2021:3 (BED 11)¹⁵ estimates there are approximately 75,000 apartment buildings and 65,000 non-residential buildings that have a heating system with an effective rated power above 70 kW (see Figure 2 and Figure 3 below). In addition, approximately 50,000 buildings are potentially subject to a requirement for the inspection of AC systems (see Figure 4). Many buildings may fall under both categories and thus be included in both Figure 2 and Figure 4, as well as in both Figure 3 and Figure 4.

In the past, Sweden applied municipal or regional energy and climate advice instead of inspections. The impact of the advisory measures has been reported to the European Commission in equivalence reports for the alternative measures in 2014 (dnr N/2014/2681/E) and 2017 (dnr M2017/ 01474/Ee). However, there have been difficulties in sufficiently and properly demonstrating to the Commission that the advice has the same effect as inspections would have. In light of this, the government decided in 2020 that advice is no longer an option and inspections are therefore introduced into law, as of 2021.

Enforcement and penalties

Local Weights and Measures Authorities through their Trading Standard Officers (TSOs) are responsible for ensuring that owners of AC systems (>12 kW) possess a valid inspection report. The penalty for non-compliance is £300 (~348 €).

TSOs are required to record any enforcement action and may publish a report annually.

Quality control of inspection reports

Over 95,600 AC inspection reports are lodged on the England and Wales register. It is difficult to estimate how many reports were produced before mandatory registration came into effect.

Impact assessment.

The original 2007 impact assessment forecasted a cost for AC inspection in England & Wales of ~£149 million (~173 M€) and benefits (improved performance, reduced operating costs, added stimulus for improvements) of ~£213 million (~247 M€). The net benefit is ~£64 million (~74 M€), with CO₂ savings in the year 2020 at ~0.08 million tonnes.

Enforcement and penalties

 See England report for details.

Quality control of inspection reports

 See England report for details.

Impact assessment

See England report for details.

Enforcement and penalties

District Councils are responsible for ensuring that owners of AC systems (>12 kW) possess a valid inspection report, except for their own buildings for which the Department of Finance of Northern Ireland (DoF) is the enforcement authority. The penalty for failing to possess a valid inspection report is £300 (~349 €).

District Councils have a three‐stage enforcement process: first a letter to encourage compliance, followed by a stronger “enforcement letter”, and then a penalty charge notice. Although 211 “enforcement letters” have been issued in 2018/19, DoF is only aware of one penalty charge notice of £300 (~349 €) issued for non‐compliance since the coming into force of the AC requirements.

Quality control of inspection reports

See England report for details.

Impact assessment.

Two Regulatory Impact Assessments (RIA) were undertaken. The costs of mandatory inspections and reporting (every five years for systems >12 kW) were estimated at £600 (~699 €) for centralised systems and £100 (~116 €) for packaged units. Benefits were difficult to quantify and included reduced electricity consumption from improved efficiency (where recommendations were implemented) and from the replacement of older systems. Other benefits, e.g. improved workplace conditions were also expected.

Mandatory recording of AC inspection reports on the national register provides a central source of information, which aims to facilitate compliance checks and to inform policy making. Since 2018, the registration fee is £9.84 (~11.46 €) excluding the Accreditation Assessor’s fee.

Enforcement and penalties

Local Authorities ensure that building owners possess a valid inspection report or have commissioned an inspection. Local Authorities may serve enforcement notices and, if building owners do not comply, Local Authorities can undertake remediation work for compliance and recover expenses from building owners. There are no published records of enforcement notices imposed by Local Authorities for non‐compliance.

Quality control of inspection reports

The procedures for AC inspections are set out in the Technical Handbook which refers to industry guidance⁴³. An Operating Framework has been established for “Approved Organisations” to accredit AC inspectors⁴⁴. The Framework requires Approved Organisations to reference the UK National Occupational Standards for AC inspections, which set minimum competencies and skills. See England report for details.

The Operating Framework sets minimum requirements for the quality assurance of inspectors, and for the audit of Approved Organisations by the Government, including:

• at least 2% of all inspection reports are checked for accuracy;
• outputs from inspectors are checked at least every six months;
• Approved Organisations maintain records to allow Government compliance audits.

In 2019, 389 AC inspection reports were produced and 24 reports were checked, i.e., 6.1%. Note that due to the Scottish climate, there are few qualifying AC systems.

Impact assessment

Similar to England. See England report for details.