Compliance & Regulation 10 min read

Energy Performance Certificates: the deadline has passed, and enforcement has started moving.

If you own or run a qualifying building and don't have an EPC, you are no longer approaching a deadline — you are inside an enforcement programme. Here is what the rules actually say, and what is worth doing this quarter.

By Frank Guo · Technology & Product Leadership, addanode

TL;DR — South Africa's EPC regulations became mandatory in December 2020 and, after a three-year extension, the compliance deadline fell on 7 December 2025. They cover public buildings over 1,000 m² and privately owned buildings over 2,000 m² net floor area in occupancy classes A1, A2, A3 and G1 (public assembly, indoor sports and theatres, places of instruction, offices). The certificate is issued only by a SANAS-accredited inspection body, follows SANS 1544:2014, rates the building A–G on kWh per m² of net floor area per year, is valid for five years, and must be lodged with SANEDI for the National Building Energy Performance Register. Compliance has been very low. The Department has outlined — as reported in trade press in July 2026 — a graduated enforcement framework over twelve months — non-compliance notices, compulsory compliance plans, municipal inspections, public listing, and prosecution where necessary — with National Energy Act penalties of up to R5 million, five years' imprisonment, or both. The practical blocker for most owners is not the certificate; it is that the building has one municipal bill and no measured breakdown behind it.

Does this apply to your building?

Two tests have to be met together — size and use.

Test	Threshold
Size — net floor area	Over 1,000 m² if owned, operated or occupied by an organ of state. Over 2,000 m² for privately owned buildings.
Use — occupancy classification	A1 entertainment and public assembly · A2 theatrical and indoor sport · A3 places of instruction · G1 offices

That scope catches a great deal of the country's office stock, schools, colleges, university buildings, municipal offices, community halls, cinemas and sports venues. It does not, on its face, catch shopping centres, warehouses, hospitals or hotels as such — a point worth checking carefully against your building's actual classification rather than its everyday description, because a mixed-use property can contain a qualifying G1 component. Where classification is genuinely unclear, that is a question for your accredited inspection body, not for a website.

What the certificate actually is

A measured rating, not a design rating. It expresses the building's energy use as kilowatt-hours per square metre of net floor area per annum, calculated in accordance with SANS 1544:2014, and grades it from A (very efficient) to G (not efficient).
Issued only by a SANAS-accredited inspection body. This is not something an owner, a consultant or a service provider can self-certify. SANEDI publishes the list of accredited bodies, which has grown but remains finite — which matters for timing, below.
Valid for five years, then repeated.
Displayed and lodged. The certificate must be displayed in the building, and the certificate together with the data used to determine it is submitted to SANEDI and carried on the National Building Energy Performance Register. Registration of building type and size on that register was itself a requirement following the August 2023 amendment.

Where we actually are: the deadline passed, and the next phase began

The original compliance date was December 2022; a three-year extension moved it to 7 December 2025. That date has now passed, and it is not being extended again in the way the first one was. Instead, the Department has moved to implementation: an EPC compliance monitoring, verification and enforcement framework, applied in a graduated sequence across roughly a twelve-month period:

Non-compliance notices issued to building owners.
Acknowledgement required from the owner.
A compulsory EPC compliance plan — in other words, being late stops being passive and becomes a documented commitment with dates.
Municipal partnerships for inspection and monitoring.
Public listing of persistent non-compliance.
Prosecution under the National Energy Act where necessary, carrying penalties of up to R5 million, up to five years' imprisonment, or both.

For most owners the meaningful item on that list is not the criminal penalty at the end — it is the public listing in the middle, and what a compulsory compliance plan does to a portfolio's due-diligence position when a building is sold, refinanced or let to a tenant with its own reporting obligations.

The graduated sequence described above, in order. The step that matters to most owners is not the one at the end — a public listing and a compulsory dated plan both land in a due-diligence file when a building is sold, refinanced or let.

Why compliance has been so low

Reporting around the deadline put certification at a small fraction of eligible buildings — in July 2025 the department reported 3,884 certificates registered against a registration target of 60,000. The public sector has been notably slow: in Limpopo, according to a SALGA letter reported in June 2026, as of May 2026 — five months after the deadline — nine of the province's twenty-seven municipalities had registered buildings on the register, four had obtained certificates, and five certificates in total had been issued across the province.

Three causes, in rising order of how much they should worry you:

Awareness. A significant number of owners still do not know the obligation attaches to them, particularly where a building is managed by an agent and the obligation sits with the owner.
Assessor capacity. A finite number of accredited bodies now faces a backlog created by years of deferral. Queueing is a real risk, and it lengthens as the enforcement notices go out.
Data. This is the one that quietly delays projects. An assessment needs a defensible twelve-month record of energy consumption together with an accurate net floor area. Many buildings have one municipal account, estimated readings in some months, a generator whose fuel is bought but not metered, and tenants whose consumption is apportioned by area rather than measured. The certificate can still be produced, but the process becomes slow, contested and expensive — and the resulting rating is a number the owner cannot do anything with.

What to do this quarter

Establish whether each building qualifies — size and occupancy class, per building, not per portfolio. Mixed-use properties need this done properly.
Register on the National Building Energy Performance Register if you have not. Registration is separate from certification, and it is the cheapest thing on this list.
Get into an accredited body's queue now. Capacity, not paperwork, is the binding constraint for many owners this year.
Assemble twelve months of consumption data and confirm your net floor area figure. Find the gaps early: estimated readings, unmetered generator fuel, sub-tenant supplies, and any shared or landlord-recovered accounts.
Decide whether you only want a certificate, or also want a better one next time. These are different projects. The first needs a year of totals. The second needs to know where the kWh actually go.

Where addanode fits — and where we don't: we do not issue Energy Performance Certificates and cannot; that is the accredited inspection body's role under SANS 1544, and it is right that it stays independent of anyone selling equipment. What we do is the measurement layer underneath: submetering by floor, tenant, plant and end-use, water alongside energy, continuous and exportable in full. That is what turns an assessment from an archaeology exercise into a data pull — and, more usefully, what makes the rating something you can improve before the five years are up. Our LoRaWAN building management system exists largely because retrofitting that measurement into an occupied building used to cost more than it was worth.

The part worth saying out loud

An EPC is a compliance obligation, and most owners will treat it as one — get the certificate, display it, move on. That is a defensible response to a rule. But the metric behind it, kWh per square metre per year, happens to be the single most useful number a building owner can have, and almost none of them have it today. A building that measures its own consumption by floor and by system finds things worth money in the first month: the floor conditioned all weekend, the plant that never shut down after a setpoint change, the tenant whose apportioned share bears no relationship to their actual use. The certificate is the deadline. The measurement is the point.

FAQ

South African EPCs — common questions

Which buildings need an Energy Performance Certificate in South Africa?

Buildings that meet both a size and a use test: net floor area over 1,000 m² if owned, operated or occupied by an organ of state, or over 2,000 m² if privately owned; and an occupancy classification of A1 (entertainment and public assembly), A2 (theatrical and indoor sport), A3 (places of instruction) or G1 (offices). Check your building's formal classification rather than its everyday description — mixed-use properties can contain a qualifying component.

What was the EPC deadline, and has it been extended again?

The regulations became mandatory in December 2020 and the deadline was extended once, by three years, to 7 December 2025. That date has passed. Rather than a further extension, the Department has moved into a graduated compliance and enforcement framework implemented over about twelve months — beginning with non-compliance notices and compulsory compliance plans, and escalating through municipal inspection and public listing to prosecution where necessary.

Who can issue an EPC?

Only a SANAS-accredited inspection body, working to SANS 1544. SANEDI publishes the list. Neither the building owner nor a supplier of energy equipment can self-certify, and you should be cautious of anyone offering a certificate as part of an equipment package — the independence of the assessment is the point of it.

What data does the assessment need?

Broadly: a defensible twelve-month record of the building's energy consumption, an accurate net floor area, and the occupancy and operational information needed to apply SANS 1544. The usual problems are estimated meter readings, generator fuel that is bought but never metered as energy, sub-tenant supplies that are apportioned rather than measured, and floor-area figures that have drifted from reality after fit-outs.

What are the penalties for not having an EPC?

Contraventions under the National Energy Act carry penalties of up to R5 million, up to five years' imprisonment, or both. In practice the earlier stages of the enforcement framework will bite first: notices, a compulsory compliance plan with dates, municipal inspection and public listing of persistent non-compliance — which is the consequence most likely to surface in a sale, a refinancing or a tenant's own reporting.

How long is an EPC valid?

Five years, after which the assessment is repeated. That interval is worth planning around: a building that starts measuring its consumption properly now has a realistic chance of presenting a better rating at renewal, whereas one that only assembles bills for each assessment will present roughly the same rating every five years.

Primary sources

Get the measurement right, and the certificate stops being archaeology.

Submetering by floor, tenant and system — retrofitted into occupied buildings without cable runs, so the next rating is something you can influence.

Scope a Building LoRaWAN BMS →