Aipedia: Energy assessors and retrofit coordinators

EPC and PAS 2035 rules that apply to AI use

Aipedia, by the Apex broking team · Last reviewed 2026-10-30

No regulator or scheme has issued AI guidance for energy assessors or retrofit coordinators, so the 2012 EPB Regulations, scheme rules and TrustMark requirements apply in full. Knowing which provisions bite helps assessors use AI without failing audits or weakening their PI position.

Part of: AI in energy assessors and retrofit coordinators

Who has published what on AI

The short answer is nobody, yet. As at October 2026, MHCLG, DESNZ, TrustMark and Elmhurst, an approved accreditation scheme, had published no AI-specific guidance. The TrustMark retrofit coordinator scheme requirements refer to recognised energy models such as RdSAP, SAP and PHPP and say nothing about AI. MHCLG's partial government response on EPC reform, published on 21 January 2026, does not mention AI, automation, remote or virtual assessments, or photos.

The practical question is how existing, binding rules apply to AI-assisted work. The table summarises the main sources.

The 2012 Regulations: scheme duties, related parties and care

Part 5 of the Energy Performance of Buildings (England and Wales) Regulations 2012 (SI 2012/3118) deals with energy assessors. Every energy assessor must be a member of an accreditation scheme approved by the Secretary of State (reg 22(1)). Before approving a scheme, the Secretary of State must be satisfied that it provides for its members to:

1. carry out consistent and accurate assessments independently (reg 22(3)(a));
2. be fit and proper and qualified (reg 22(3)(b));
3. use standard forms (reg 22(3)(c));
4. follow a published code of conduct (reg 22(3)(d));
5. have indemnity arrangements in relation to relevant persons and prospective or actual buyers or tenants (reg 22(3)(e));
6. be subject to complaints resolution (reg 22(3)(f));
7. lodge data on the Secretary of State's register under reg 27 (reg 22(3)(g)); and
8. appear on a membership register (reg 22(3)(h)).

Two points matter for AI. First, "consistent and accurate" and "independently" sit awkwardly with a tool that fills gaps with its own assumptions. An app-supplied value the assessor did not check is harder to defend at audit. Second, reg 22(3)(e) recognises that buyers and tenants, not just the client, rely on the certificate. That is why errors can produce claims from people the assessor never met.

Reg 23 requires related party disclosures on certificates and reports, which continue to apply when text is drafted with AI. Reg 24(1) requires energy assessors to carry out assessments "with reasonable care and skill". It sets no special standard for AI, so the test is whether a reasonably competent assessor would have relied on the output without the checks that were, or were not, made.

Scheme operating requirements

Accreditation schemes register assessors, lodge certificates and run quality assurance. Their operating requirements and codes of conduct translate the regulations into day-to-day rules on evidence, audit and insurance. The minimum PI level for energy assessors is set by scheme rules rather than by the regulations. Elmhurst, for example, requires accredited members to arrange their own PI and public liability insurance under its Scheme Operating Requirements and separately provides a policy covering lodgement of members' reports and certificates through its systems (page updated 30 June 2026).

For AI users, the practical consequence is that audit evidence must support each input. An AI floor plan or an image-recognition result is not, by itself, evidence of what was on site. See AI floor plans and measurements and AI photo evidence and site data capture.

TrustMark rules for retrofit coordinators

The TrustMark PAS 2035 Retrofit Coordinator Scheme Requirements (2022 edition, V1.3) govern coordinators registered through TrustMark scheme providers. The provisions that matter most for AI are:

• Competence: coordinators must show competence under Appendix 2, covering risk assessment, building physics, design, installation, and monitoring and evaluation, with at least 25 hours of evidence-based CPD a year.
• Records and lodgement: records must be kept as PAS 2035 specifies, minimum information lodged in the TrustMark Data Warehouse, and monitoring and evaluation outcomes recorded there.
• Audit: at least 2% of retrofit projects a year are audited (at least 1% per member), prioritising Risk Path C, then B, then A. Five minor non-conformities or any major non-conformity fails an audit.
• Conflicts: where a coordinator holds several roles, conflicts must be declared to the client and resolved, citing PAS 2035 6.1.5.
• Insurance: PI from a regulated insurer, no self-insurance, at a minimum of "£250k PI & PL per property, or as required by the client", with changes notified to the scheme provider.

The underlying process is set by PAS 2035:2023. Its steps apply whatever software is used. Our guides on risk paths and moisture risk and monitoring and lodgement go into the detail.

Reforms that raise the stakes

MHCLG's partial government response on EPC reform (21 January 2026, updated 9 March 2026) introduces new headline metrics and says government is working to deliver new EPCs from October 2026. It commits only to ensuring schemes and assessors are "equipped" for the new methodology and sets out no change to accreditation or PI. Separately, the private rented sector response sets EPC C for all tenancies by 1 October 2030. Neither addresses AI. Both increase reliance on accurate certificates.

What this means in practice and for PI

Without AI-specific rules, assessors and coordinators should treat every AI output as unverified input until they have checked it, and keep the evidence a scheme auditor would expect. For PI, the scheme or TrustMark minimum is a floor, not a recommendation. A claim arising from AI-assisted work will usually be handled as a negligence claim under the policy, subject to its terms, so the questions are whether the limit is adequate per property and in aggregate, and how software, data and property damage exclusions read. Our page Do energy assessors need PI insurance? explains the basics, and Apex can arrange cover through our energy consultants PI service, with a broker reviewing how your policy treats AI-assisted work. Return to the AI in energy assessment hub for all guides.

Sources

• Energy Performance of Buildings (England and Wales) Regulations 2012 (SI 2012/3118), Part 5
• TrustMark: PAS 2035 Retrofit Coordinator Scheme Requirements (V1.3)
• BSI: PAS 2035:2023 overview
• Elmhurst Energy: insurance for accredited members
• MHCLG: Reforms to the Energy Performance of Buildings regime, partial government response (January 2026)

Frequently asked

Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.