The UK’s Energy Performance of Buildings regime is currently under review with a much stronger focus on supporting net zero targets and improving the way building energy data is recorded and used.
For many years TM44 inspection requirements have been a familiar part of commercial building compliance to help ensure air conditioning systems are operational, safe and appropriately maintained.
Following the consultation in 2025, the government has proposed changes which could reshape the structure and purpose of the TM44 report. The proposals aim to make inspections more data driven and focused on future performance.
Research has suggested that when recommendations from a TM44 survey are fully implemented, energy savings of up to 40% can be achieved. This highlights the growing strategic value of this assessment.
What are the proposed TM44 changes and what do they mean?
- TM44 inspections are likely to become more data-led, with information centralised to help building owners track system performance across portfolios rather than viewing reports in isolation.
- The updated TM44 survey is expected to place greater focus on likely efficiency, system sizing and whether maintenance schedules still reflect how buildings are actually used.
- Stronger enforcement and more regular reporting could mean TM44 data plays a bigger role in energy planning and not just to meet minimum compliance requirements.
Understanding the Proposed Report Redesign
One of the most important changes proposed for TM44 reporting is the move towards centralising inspection data within a national register. This change will allow building owners and facilities managers to track performance far easier across large or complex property portfolios, rather than simply viewing reports in isolation.
The redesigned TM44 inspection is also expected to place greater emphasis on projected or ‘likely’ efficiency which will offer clearer insights into how systems should perform under normal operating conditions. Alongside this, assessors would be required to take a closer look at whether existing maintenance schedules remain appropriate, rather than just confirming that servicing is taking place.
Another key proposal is a much stronger focus on system sizing. With many buildings having changed how they are used over time and the updated TM44 survey framework, it would encourage assessors to confirm whether cooling systems are still correctly sized for current occupancy levels and usage patterns.
Navigating the New Compliance Environment
Building owners will have to adapt to a more structured and data-led compliance environment as the proposed reforms progress.
While TM44 inspection requirements are already well established, the government’s proposals suggest that a more rigorous approach to enforcement and reporting is required. One recommendation contained in the proposal includes increasing penalties for non-compliance. It has been suggested that fines could rise from £300 to £800. This reflects the growing recognition that accurate energy oversight is not just a technical requirement but rather an essential part of responsible building management.
There have also been discussions around introducing more frequent reporting triggers, particularly where buildings are sold, let or significantly altered. Under this approach TM44 data would remain current and meaningful for tenants, buyers and investors as opposed to becoming outdated shortly after issue.
A well-structured TM44 survey could therefore play a more active role in supporting transparency across the commercial property market.
How ACI Reports Supports the Transition
At ACI Reports, we work with clients to help them understand their existing TM44 inspection results while preparing for the direction of future standards. As reporting becomes more detailed and complex, interpretation of the data is crucial and as important as carrying out the inspection itself.
Our expert team provide targeted health checks that assess how current cooling performance compares with the proposed 2030 EPC ‘C’ targets. This allows our clients to identify practical steps early rather than rerating to regulatory changes later.
As TM44 reports become more data-heavy, the role of an impartial and accredited assessor becomes increasingly important. At ACI Reports, we ensure that each TM44 survey delivers clear, reliable insight, turning what was once a mandatory check into a practical energy roadmap that supports long-term planning.