Mandatory display and submission of Energy Performance Certificates

FEDHASA would like to draw attention to the mandatory display and submission of Energy Performance Certificates (EPC) that may possibly have an effect on the restaurant sector, starting 8 December 2022.

The Regulation entitled “Mandatory Display and Submission of Energy Performance Certificates for Buildings” states that the owner of a building, other than that owned, operated or occupied by an organ of state must within two years of these Regulations coming into effect (published 8th December 2020), publically display an energy performance certificate at the entrance of that building provided that the building –

(a) has a dominant occupancy classification in terms of Regulation A20 of the National Building Regulations as Al (Entertainment and public assembly – see classification categories below), A2 (Theatrical and indoor sport), A3 (Places of instruction), or G1 (Offices);

(b) is in operation to meet a particular need associated with the use of the building for a period of two years or longer, and which has not been subject to a major renovation within the past two years of operation; and

(c) has a total net floor area of over 2000 m2.

In addition, the owner of a building other than those owned, operated or occupied by an organ of state must submit a certified copy of the energy performance certificate to SANEDI in respect of every building contemplated in the regulation within three calendar months of the date of issue of the certificate.

National Building Regulations –

See table – A20 Classification and Designation of Occupancies

The occupancy of any building shall be classified and designated according to the appropriate occupancy class given in column 1 of Table 1 and such classification shall reflect the primary function of such building: Provided that, in any building divided into two or more areas not having the same primary function, the occupancy of each such area shall be separately classified.

A1 – Entertainment and public assembly – occupancy where persons gather to eat, drink, dance or participate in other recreation.

A2 – Theatrical and indoor sport – occupancy where persons gather for the viewing of theatrical, operatic, orchestral, choral, cinematographical or sports performances

A3 – Places of instruction – occupancy where school children, students or other persons assemble for the purpose of tuition or learning.

G1 – Offices – occupancy comprising offices, banks, consulting rooms and other similar usages.

NB – Classification H1 Hotel (Occupancy where persons rent furnished rooms, not being dwelling units) and classification H5 Hospitality (Occupancy where unrelated persons rent furnished rooms on a transient basis within a dwelling house or domestic residence with sleeping accommodation for not more than 16 persons within a dwelling unit) do not require an Energy Performance Certificate. However, in the case of a building with mixed occupancy, the occupancy of each such area shall be separately classified. (see comments re mixed occupancy buildings below)

Mixed occupancy buildings

When assessing a mixed occupancy building you need to consider the following three questions –

  • Is the occupancy class of the building that needs an EPC greater than the minimum size threshold (e.g., 2000m2 for privately owned buildings)?
  • Is this occupancy class distinct, in other words, can a clear boundary be drawn around it?
  • Does this occupancy class consume more than 10% of the total building’s energy consumption?

If the answer to all three questions is yes, then this portion of the building would most likely need to be certified.

How to apply for an EPC
The owner of a building as contemplated in the Regulations will need to acquire the services of a SANAS accredited inspection body to do the assessment of a building or buildings and after the assessment, a certificate will be issued. The following link provides a list SANAS accredited inspection bodies –

Who to contact if you have any questions or queries

If you are unsure as to whether or not your building will require an Energy Performance Certificate it is suggested that you contact SANEDI [] or Mr Frikkie Malan at RMS, (Remote Metering Solutions a listed SANAS accredited inspection body) who would be happy to take your call – 012 001 3600 (Ask to speak to Mr Malan)

View the EPC article written by Mr Frikkie Malan


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