Registering you Solar Thermal / Air or Ground Source Heating for RHI after purchasing the property

Purchased a property with solar thermal, air or ground sourced heating in the last 12 months? This document could make you money.

Having just brought a property with solar thermal panels on the roof, neither I nor my solicitor thought much about it. 8 months later, when I happened to be researching adding air or ground sourced heating the property, I realise that this had been a mistake.

The RHI scheme

The RHI scheme, or the Renewable Heat Incentive scheme, is a UK government subsidy scheme designed to pay domestic/non-domestic property owners for generating heat from renewable energy.

Note: A similar more well known scheme, called the Feed-in Tariff (FIT) exists for solar-electrical photovoltaic systems which pass electricity back to the national grid.  The information in this article applies to both the FIT and the RHI, but the contact information with the regulator and the burden of proof will be different.

In order to qualify for the RHI scheme, you must

  1. Have an up-to-date Energy Performance Certificate (EPC) for your property. These should be provided to you/your solicitor as part of the purchase and are required by law. You can download them from Landmark Registry for free, provided that you have the document number.
    View: Landmark Registry – EPC Registry
  2. Hold a valid Microgeneration Certificate from the Microgeneration Certification Scheme (MCS) for the solar thermal, air heat pump or ground heat pump that comes with your property. This confirms that it was installed by a regulated supplier, meets certain environmental standards and has been approved for use in the UK by OfGem, the relevant regulator.
  3. The property must have been de-registered by its previous owner as an obligation on the seller of the property.
  4. You, as the buyer must register on the RHI scheme as the new owner within 12 months from the completion date of the purchase of the property.

You could be missing out

The issue at the current time is that most solicitors do not know this. The percentage of RHI/FIT sales remains fairly small. Consequently, most solicitors on either the buyer or sellers do not know that their clients need to act both as a buyer and as a seller. Consequently, as a buyer you could be missing out on any RHI/FIT subsidy that should come with your house. Conversely, your seller could still be receiving subsidies for the property – which constitutes as fraud! Many sellers may assume that it is they who receive the subsidy: it is not. It is the house that does!

Unfortunately, in my case, the sellers, nor their solicitor left any documentation about the solar system. Once I realised that there was a process to follow. I wasted several days trying to wade through the process. My findings are as follows

What to do when buying a property

Ask your solicitor to:

  1. Obtain the EPC certificate document number so that you can retrieve the original yourself
  2. Ask the seller to supply the MCS certificate
  3. Ensure that the seller leaves the manuals, service history and other documentation for the system
  4. Identify the details of the company who installed the system from the seller
  5. Insist on written confirmation in the TA10 “fittings and fixtures” document that the property has a Solar Electric array/Solar Thermal array/Air source heat pump/Ground source heat pump plus specific details if available. This may be necessary documentary evidence for OfGem at a later date, so you should encourage your solicitor to ensure that TA10 is returned by the sellers with such statements included

If you have already purchased the property

Provided that the sellers have left documentation and have relinquished their registration, this should be a simply matter of contacting OfGem. Should the sellers not have contacted OfGem to relinquish their ownership of the property, you need to take-over the registration held with OfGem. If you do not have the MCS certificate or details of the installer, you are going to need to do some digging.
Note: The process will take longer. Please keep this in mind, especially if you are close to the 12 months limit for registration transfers.

The MCS Certificate

MCS is a government supported initiative run by The MCS Services Company Ltd. In order to qualify for RHI, your solar system must have a valid MCS certificate. If it does not, you will not qualify for any government subsidy as of the time of writing.

The MCS certificate can only be given to you by the installer. If like me, you do not know the installer, or you do not know whether your system has a MCS certificate. You can contact the MCS helpdesk on 0333 103 8130. If you provide them with your address, they should be able to give you a yes/no answer as to whether your property has a MCS certificate. They will also be able to tell you the name of the installer if it does. After that you must contact the original installer to request a copy of the certificate. MCS will however help you to obtain the certificate if your original installer is no longer legally trading.

Note: The original installer of my solar system had changed hands and the new owners had no details of my MCS registration. Consequently they initially told me that the house did not have one. I pushed and got them to log into the MCS suppliers portal, where they were able to retrieve my certificate.

Tip: My solar installer were also able to tell me the service history of the solar system. You should check this with your supplier. I was advised that Solar Thermal systems should be serviced every 3-4 years.

View: MCS Website

Contacting OfGem: updating your registration

Once you have your EPC and MCS certificates. You can update your registration. You will also need a copy of ONE of the following which can be provided by your solicitor:

  1. TR1 ‘Registered title(s): whole transfer’ form
  2. Copy of the title deed to the property showing the date of the transfer or ownership
  3. TA10 ‘Fitting and fixtures’ form, preferably showing the presence of the system during the sale
  4. A letter from your solicitor confirming the sale that includes the name(s) of the buyers, the full address of the property and the legal date of the transfer of ownership
    Note: I contacted OfGem who informed me that the letter does not need to be addressed to them. Your solicitor can address it to you, the property owner and it will be acceptable as long as it contains the requisite information.

Send the EPC, MCS and whichever one of the above you choose to send to the following email address

domesticrhi (#at#) ofgem.gov.uk

Include a cover letter in the email advising them that you are contacting them to change RHI registration on your property and (if applicable) that you do not believe that the previous owner has surrendered their registration. On receipt, you will receive an automatic response advising you that they will be in contact once your application has been reviewed ‘ordinarily within 10 days’.

OfGem informed me that if your seller has been falsely claiming subsidy, the account will be passed to a separate team who will seek repayment. They advised me that if recovered, it is likely – but not guaranteed – that OfGem will reimburse you for lost income from the date of your purchase.

Once your application has been processed. You will be given access to the RHI portal in which you will be able to submit your annual meter readings and input your subsidy payment details.

View: My RHI Portal

View: Domestic Renewable Heat Incentive Help sheet

Contacting OfGem

If you need to get in contact with OfGem about your application or have a question – they don’t really seem to want you do so! You can do so using the following:

For FIT and RHI enquiries call: 0207 907 7000

At the time of writing the menu system path to get to the RHI team was 2, 2, 2, 1, 5 (groan) and for the FIT team it was 2, 2, 2, 1, 1

Email: rhienquiries (#at#) ofgem.gov.uk

Please note however that their office hours are ONLY 9:30 am – 12:30 pm, Monday to Friday.

Conclusion

If you are a property owner, buyer or seller or a solicitor representing your clients. Hopefully, this article has been of some use to you.

See also

OfGem change of ownership guidance

OfGem MCS scheme information