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Commercial · Compliance

TM44 Air Conditioning Inspections Explained

If your building's air conditioning adds up to more than 12 kW, the law requires an accredited energy assessor to inspect it at least every five years and lodge the report on the national register. This guide explains who the duty falls on, what the threshold means, who may do the inspection, what the report covers, the penalties, and how TM44 fits alongside your maintenance contract. We match businesses with vetted, F-Gas certified contractors, many of whom can arrange an accredited assessor.

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The 12 kW threshold and who carries the duty

The threshold is the combined effective rated output of all air conditioning in the building under one person's control, not the size of any one unit. The duty falls on whoever controls the technical functioning of the system — normally the landlord for landlord-provided plant, the tenant where the tenant installed it.

ScenarioCombined outputTM44 required?Duty holder
Small shop with two 3.5 kW wall splits7 kWNo
Office with five 3.5 kW splits under one occupier17.5 kWYesOccupier who controls them
Multi-tenant building, landlord VRF serving all floorsTypically 50–250 kWYesLandlord / managing agent
Tenant-installed system in a leased unitAbove 12 kWYesTenant

Effective rated output is the manufacturer's cooling capacity under standard conditions. Comfort cooling, including the cooling side of air-to-air heat pumps, counts; dedicated process cooling and refrigeration generally do not.

Every five years — and when the clock starts

Existing systems must hold a report no more than five years old; a new system above 12 kW must be inspected within five years of being put into service. On sale or letting the current report passes to the new controller — if none exists, they must arrange one within three months — and the enforcing authority can demand it within seven days. There is no grace period at expiry, so diarise renewal a few months ahead; assessor availability tightens in summer.

Accredited energy assessors only

The inspection must be carried out by an air conditioning energy assessor registered with a government-approved accreditation scheme: Level 3 for simple packaged and split systems (typically no single unit over 12 kW), Level 4 for complex and centralised systems — VRF/VRV, chilled water, large ducted plant. Most commercial buildings need Level 4. A service engineer's F-Gas certificate does not qualify them, though some contractors employ or partner with an assessor. Verify accreditation on the Energy Performance of Buildings Register before booking, and ask for the lodged report reference afterwards.

What a TM44 inspection covers

The assessor inspects the plant, reviews documentation and produces a report with an efficiency assessment and recommendations — a couple of hours for a simple site, a day or more for a large building.

AreaWhat the assessor looks at
InventoryEvery system, unit, capacity, refrigerant type and age — reusable for F-Gas and asset registers
SizingWhether installed capacity matches the cooling load; over-sized plant short-cycles and wastes energy
Condition and maintenanceFilters, coils, condensers, insulation, evidence of leaks, and whether maintenance and F-Gas records are in order
RecommendationsPractical improvements — controls, maintenance, refurbishment or replacement — with indicative payback where possible

Penalties and enforcement

Enforcement sits with local trading standards. Failing to hold a valid report, or to produce one within seven days when asked, attracts a fixed penalty — historically £300 per offence and repeatable while the breach continues; treat that as indicative and confirm the current amount. The sharper consequences are usually commercial: a due-diligence request on sale or letting, a lender or insurer condition, or a tenant dispute where a missing report is a visible gap in the compliance file. The report also earns its keep — an independent expert tells you whether your plant is the right size and whether a controls fix or a VRF replacement would pay back; the commercial cost guide helps budget that.

Sources & methodology

  • Energy Performance of Buildings (England and Wales) Regulations 2012 and government guidance "Air conditioning inspections for buildings".

FAQs

If the air conditioning in the building has a combined effective rated output of more than 12 kW, yes — in England and Wales, under the Energy Performance of Buildings Regulations 2012. The threshold is the total across all systems under one control, not per unit: five 3 kW wall units in one office add up to 15 kW and trigger the duty. Scotland and Northern Ireland have parallel rules.
At least every five years. A new system over 12 kW must have its first inspection within five years of being put into service, and each report runs for five years from the inspection date. If you buy or lease a building, ask for the current report; if there is none, the duty passes to you as the person who controls the system.
Only an accredited air conditioning energy assessor registered with a government-approved accreditation scheme — Level 3 for simple packaged or split systems, Level 4 for complex, centralised and VRF systems. Your maintenance engineer cannot produce a valid report unless they also hold that accreditation. Assessors can be checked on the Energy Performance of Buildings Register.
Local trading standards can issue a fixed penalty for failing to hold a valid report or to produce it within seven days of a request. The amount has long been cited at £300 per offence and can be repeated, but confirm the current figure with the enforcing authority. In practice the bigger risk is commercial: a buyer, tenant, lender or insurer asking for the report and finding none.
No. It is an energy-efficiency assessment: the assessor examines the system, its sizing, controls and maintenance records and recommends improvements. It does not clean filters, leak-test or repair anything. You still need a maintenance contract, and a well-kept service log makes the inspection quicker and its conclusions kinder.

Get your plant inspected and maintained

Tell us about your building and systems and we match you with vetted, F-Gas certified commercial contractors — many can arrange an accredited TM44 assessor alongside a maintenance contract. Free and without obligation.