Government responds to the Consultation: ‘Review of energy assessor accreditation scheme operations’

As the largest Accreditation scheme in the UK, Elmhurst Energy welcomes the response from DCLG today on this important consultation.

We welcome the open approach of Government in attempting to make improvement to the current systems and processes. We agree with all the results of the responses, in fact we at Elmhurst noted that in all questions we sided with the majority of the decisions in all responses to the consultation

As they say the devil is in the detail and as such we go through each question, giving the Industries responses, the Government response, as well as giving our considered interpretation.

Each Question from the Consultation in order:

Question 1

Do you consider that smart auditing would improve quality assurance procedures for energy certificates, particularly in relation to consumer protection and prevention and detection of fraud?

“85% of respondents were in favour of changing the current approach to quality assurance from random to smart auditing. Many considered that smart auditing would enable schemes to improve the overall reputation of the industry by identifying and removing the worst performing energy assessors. They also felt that allowing schemes to target known risk factors such as improbable values, data items that impact on eligibility for grant funding programmes and multiple energy performance certificates entered onto the Register for the same property, would be an improvement on the existing system. The proposal would also enable schemes to reduce the number of audits on competent energy assessors, making better use of their resources.”

Government Response:

“The Government has therefore decided to adopt the smart auditing approach to quality assuring energy certificates and will work with industry to incorporate this into a revised set of Scheme Operating Requirements.”

Elmhurst Response:

We welcome smart auditing; we very much participated in the trial and are involved in ensuring that the new SORs include smart auditing at the heart of it. The impact will be that risky Energy Certificates are audited, and therefore good assessors will have lower levels of auditing and riskier assessors have more. It must be an outcome based approach and not processed based, “is the EPC correct?” is the most important question, not whether a photo exists of an LEL.

Question 2

Should error margins, be tightened? E.g. existing dwellings + or – 5 SAP Points

“62% of respondents were in favour of retaining the current error margins. Most felt that tightening the error margins would not necessarily improve the quality of energy performance certificates.

21% of respondents felt that the current error margin should be tightened. Some felt that, since energy performance certificates have been required since 2007, the permissible error margin could be reduced from 5% to 3% or lower.”

Government response

“No clear evidence was provided in any of the responses that tightening error margins would deliver any meaningful benefits or lead to a significant improvement in the robustness of energy performance certificate assessments. The Government is therefore minded to retain the error margins currently in place.”

Elmhurst Response:

Elmhurst agree with this outcome, the levels are correct, there is no evidence to suggest otherwise. We believe that ‘Smart Auditing’ will get to the heart of the issue over quality of EPCs.

Question 3

Will allocating each energy assessor a unique identification number help to provide safeguards against abuse of Accreditation Scheme systems?

“67% of respondents were in favour of having a unique identification system for individual energy assessors, because it would allow all energy certificates connected with an individual to be traced back to that individual irrespective of the scheme through which they may have entered them onto the Register.”

Government Response

“The Government has carefully considered responses and is minded to work with industry and the operator of the Energy Performance of Buildings Register to introduce a system of unique energy assessor identification numbers going forward.”

Elmhurst Response:

We agree with this, the system should have been set up with this in the first place; a simple system has been suggested and should be implemented. Ultimately this is just about stopping fraudulent and dishonest assessors’ scheme hopping to avoid detection. This is a good idea in order to protect good assessors.

Question 4

If you consider that a unique identifier does not provide sufficient safeguards, should individual energy assessors be limited to one scheme membership for each type of certificate that they produce?

“57% of respondents were against the idea of individual energy assessors being limited to one scheme membership for each type of certificate that they produce. Many respondents felt this to be impractical as many of the organisations with whom they have contracts, or which commission them to carry out energy assessments, require them to lodge energy certificates through a specific scheme. They also felt that restricting assessors to membership of a single scheme would lessen competition in the energy performance certificate market place.”

“The main argument put forward by the 18% of respondents in favour of restricting the number of scheme memberships was that it would help accreditation schemes to accurately monitor the performance of assessors and ensure any imposed sanctions are enforced without the risk of an assessor continuing to operate under an alternative accreditation scheme.”

Government Response

“Government is not minded to introduce a limit on the number of schemes an energy assessor can be a member of at any given time. The arguments that it would be anti-competitive and unduly limit the ability of individual energy assessors to work for clients who will only commission work from assessors who are members of a particular scheme were particularly persuasive factors in reaching this conclusion.”

Elmhurst Response

We agree; a Unique Identifier is absolutely sufficient if enacted correctly. It is anti competitive to suggest that assessors can’t join more than one scheme. For many genuine reasons some assessors need to be in different schemes. Also to get this to work a unique identifier is required, if one can be created then it doesn’t matter where the assessor lodges the central register and schemes can prevent lodgements.

Question 5

Would the introduction of clearer rules about when it is both proportionate and reasonable for schemes to strike off energy assessors, in cases of persistent or serious misconduct or malpractice, help to improve professional standards in the energy assessment industry?

“70% respondents were in favour of clearer rules about when accreditation schemes can strike off energy assessors, especially in cases of persistent or serious misconduct or malpractice. Many felt this would help to improve professional standards in the energy assessment industry.

Clearer rules would also help to ensure that persistent offenders who are unable to address their shortcomings can be struck-off.”

Government Response

“Government has carefully considered responses and is minded to update the Scheme Operating Requirement to include clearer rules about when it is both proportionate and reasonable for accreditation schemes to strike off energy assessors, in cases of persistent or serious misconduct or malpractice. We consider that this will help to improve professional standards in the energy assessment industry.”

Elmhurst Response

We wholeheartedly agree with the outcome. The current SORs are far too prescriptive, with too many loops and inconsistencies. We at Elmhurst have assessors, who can fail the majority of their audits, and by following the current SORs, they simple keep going through loop after loop and whilst having a draconian audit regime placed on them, which still doesn’t get to the heart of the issue.

We think if an assessor deliberately misleads consumers and brings EPCs into disrepute – by acting fraudulently or malpractice – that we can revoke their membership. If another scheme wished to take these individuals on, then that is up to them. If all schemes place quality over quantity, then the assessors that want to bend and cheat the rules will be correctly removed from the industry.

QA should all be about educating and improving assessors, and not be draconian on honest mistakes. Its outcome should be about better quality EPCs for all.

Question 6

Should accreditation schemes have the right to charge for the cost of referring complaints to the independent third party in those cases that are not brought by the building owner or occupant and where the complaint is not upheld?

“The responses to this question were balanced, with 39% of respondents in agreement and 33% against. It was uncertain what view the remaining 28% took. The fact that the majority of respondents to this consultation were accreditation schemes and industry bodies, rather than consumers, should be borne in mind.

With the exception of all but one, schemes were in favour of charging. The main argument they put forward is that they already have rigorous procedures in place, and complaints already go through a number of internal appeals procedures before they are referred to third parties for adjudication.”

Government Response

“The Government is therefore not minded to change the current rules about the cost of referring complaints to an independent third party.”

Elmhurst Response

We at Elmhurst pride ourselves on the fact that we are open and honest and have many tiers internally for our members to appeal decisions – mostly on auditing. We have appropriate oversight and independence built in to listen to appeals and adequately deal with them in fair and professional manner. We have however had instances where people use the current SORs to claim a third party appeals process which is costly and in our opinion just vexatious. We would like clearer rules to allow appropriate appeals processes for all including members, stakeholders and consumers.

Question 7

For the specific purposes of preventing and detecting fraud should accreditation schemes:

  • have greater access to data stored on the Energy Performance of Buildings Registers?
  • be required to share data that might be indicative of fraud with Regulatory bodies such as Ofgem and Action Fraud?

“72% of respondents agreed that more data stored on the Energy Performance of Buildings Register should be shared with organisations such as Ofgem and Action Fraud in order to improve Government's ability to investigate and take appropriate action in cases of suspected fraud.”

Government Response

“Government has carefully considered the responses and is minded to extend the access that accreditation schemes have to data stored on the Energy Performance of Buildings Register. We are also minded to introduce a requirement for schemes to share data with Regulatory bodies.”

Elmhurst Response

We agree with this, we must continue to share data for the reason of quality EPCs. It is also vital that the other stakeholders share information with us, as it must be a two way street.

Question 8

Do you consider that the Department should place an express duty on accreditation schemes to ensure that data held by both them and their members are held securely and are retained or processed only for purposes specified by the Secretary of State?

“55% of respondents agreed with this proposal. Of the 17% against, some argued that energy performance certificates do not in their view contain personal data, and restricting use of data by both schemes and energy assessors could undermine some other Government programmes.”

Government Response

“Government has carefully considered the responses. No persuasive arguments were put forward as to why it would be inappropriate to put in place measures to ensure that data relating to the energy performance of buildings is managed appropriately.”

Elmhurst Response

Elmhurst hold all data in a secure way, our members sign a code of conduct which expressly requires them to do likewise. We have no issues with this.

What is Next?

“The Government will work with industry and the operator of the Energy Performance of Buildings Register to implement those measures that we are minded to take forward following this consultation. We will also revise all of the documentation relating to the Scheme Operating Requirements to take on board the changes set out above.”

We at Elmhurst believe that the outcome of this consultation and the changes to the processes will deliver better quality EPCs and a more professional industry that is good for us all. We welcome the opportunity to contribute, and we hope that our members see the benefit of these improvements suggested. We will work with Government and the Industry to ensure that EPCs are valued and built upon.

For full Consultation Response see here:

To see Elmhurst original Response to the Consultation see here:


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