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PAS 2038:2021 released by British Standards Institution (BSI)


The long awaited Publicly Available Specification (PAS) 2038 has been published for improving energy efficiency of non-domestic building.  

Many will already be aware of PAS 2035, the domestic retrofit specification which was published by British Standards Institution (BSI) back in 2019. The obvious next step was for BSI to consider commercial buildings and we have now received the first draft of PAS 2038, “Retrofitting non-domestic buildings for improved energy efficiency – Specification”.

What is a PAS?

A PAS (Publicly Available Specification) is a sponsored, fast-track, consensus-building informal standard that is produced by the UK national standards body, BSI Standards Limited. PAS 2038 has been sponsored by the Department for Business, Energy & Industrial Strategy (BEIS).


This PAS covers the energy retrofit of non-domestic buildings in England and Wales, including offices, shops, factories, workshops, warehouses, storage areas and even multi-residential buildings which have communal areas (hotels, guest houses etc.). The aim of PAS 2038 is to reduce energy demand, improve the energy efficiency of our existing building stock and decarbonise building services in supporting the county’s commitment to reducing carbon emissions.

Elmhurst has undertaken a quick review of the current document and has provide a small overview below:

  • It is broadly similar to its domestic counterpart as it uses a “whole building approach” to the retrofit process, which considers the building as a system of elements.
  • It covers the management of the retrofit process from inception to completion
  • The PAS can be applied to non-domestic retrofit activities that are initiated, procured, funded and delivered by national or local government schemes.
  • Retrofit projects compliant with PAS 2038 will be led by a Retrofit Lead Professional who will identify objectives, possible outcomes, and oversee the project from inception to completion – similar to that of the Retrofit Coordinator in PAS 2035.
  • The choice of Retrofit Lead Professional is dependent on the complexity and nature of the project i.e. a building requiring significant building services work, may be overseen by a building services engineer and a building requiring significant work to the buildings fabric may be overseen by a structural engineer, architect etc.
  • An assessment of the building will be required prior to retrofit by a suitably qualified person, known as the assessor. In instances where there are more than one assessor, a Lead Assessor shall be appointed.
  • The assessment will cover four main areas: the context, condition, occupancy, and energy performance of the building.
  • Qualifications of project team members will depend on the complexity and nature of the project, however, those qualified as Non-Domestic Energy Assessors (L4 and 5) or Display Energy Certificate (DEC) Assessors can have an active and important role within the framework from assessment of buildings, to development of an improvement plan.
  • Smaller non-domestic buildings (floor area below 500m2) may need to be overseen by Retrofit Coordinators qualified as NDEAs, and will need to adhere to the requirements of PAS 2035:2019.

Elmhurst will now be taking the time to review this document in full to determine the requirements, and process which is outlined, as well as the potential opportunities which are available for members. Following the model applied in the domestic sector it is probable that future government support to assist businesses in reducing energy consumption will require the use of PAS 2038, which means that this could be an excellent opportunity for Elmhurst members. 

You can purchase a copy of PAS 2038 from the BSI Website: https://www.bsigroup.com/en-GB/standards/pas-20382021/