Why PAS 2038 Matters: The Standard Driving Energy Efficiency in Commercial Buildings!
The built environment contributes nearly 40% of global carbon emissions, and within the UK, non-domestic buildings account for a significant share of total energy consumption. Offices, retail spaces, warehouses, hospitals, and educational facilities are all under increasing scrutiny to meet the UK’s net zero targets by 2050.
As the drive toward decarbonisation intensifies, the focus has shifted from new builds to retrofitting existing structures — improving their energy performance without full redevelopment. For this transformation to succeed, however, there must be a consistent, regulated standard that ensures quality, safety, and compliance. This is precisely where PAS 2038 comes into play.
Introduced by the British Standards Institution (BSI) in 2021, PAS 2038 establishes a systematic framework for the retrofit of non-domestic buildings across England and Wales. It ensures that projects are professionally assessed, designed, and executed with measurable energy performance improvements.
While its domestic counterpart, PAS 2035, governs residential retrofits, PAS 2038 focuses specifically on commercial and public-sector buildings, filling a critical gap in the UK’s retrofit ecosystem. Its structured approach helps property owners, facility managers, and retrofit contractors reduce energy waste, enhance operational efficiency, and align with the UK’s carbon reduction strategy.
For companies like ECMC, PAS 2038 represents more than compliance — it defines the quality benchmark for sustainable building upgrades.
Understanding PAS 2038: Framework and Purpose
PAS 2038 (Publicly Available Specification 2038) provides a technical and procedural foundation for improving the energy performance of non-domestic buildings. It defines how retrofits should be planned, executed, and verified to achieve long-term carbon and cost savings.
The standard was introduced in recognition of a key challenge: while many commercial buildings underwent ad hoc upgrades — such as lighting replacements or HVAC improvements — few followed an integrated process that considered building performance holistically. PAS 2038 corrects this by introducing a whole-building retrofit methodology.
The standard requires that retrofit decisions be guided by evidence-based assessments, considering:
- The current energy performance and operational usage of the building.
- The condition of structural and mechanical systems.
- External and internal constraints, including planning permissions and conservation requirements.
- The financial and technical feasibility of proposed improvements.
The goal is to create retrofit strategies that are balanced, cost-effective, and future-ready — addressing both immediate performance goals and long-term decarbonisation needs.
In practice, PAS 2038 supports a “fabric-first” approach: improving insulation, glazing, and air-tightness before implementing system-level interventions such as renewable integration or advanced energy management systems.
By formalising this process, PAS 2038 transforms retrofitting from reactive upgrades into strategic building performance optimisation.
Why PAS 2038 Matters: The Case for Standardized Retrofitting
The importance of PAS 2038 lies in its ability to standardize retrofit quality across the UK’s vast commercial property sector. Unlike residential retrofits, which have benefitted from national schemes under PAS 2035, non-domestic buildings vary widely in size, function, and energy intensity — from data centers and hospitals to high-street shops and office towers.
PAS 2038 establishes a common quality benchmark that ensures consistency and compliance regardless of building type or project scale.
Key benefits of adopting PAS 2038 include:
- Quality Assurance and Compliance
Projects conducted under PAS 2038 follow documented procedures and technical standards verified by qualified professionals. This not only assures performance but also reduces post-installation risks and liability exposure.
- Energy and Carbon Savings
A structured retrofit approach ensures interventions achieve measurable reductions in both energy demand and greenhouse gas emissions — directly contributing to the UK’s net zero strategy.
- Operational Efficiency and Cost Reduction
Improved energy performance translates into lower utility costs, enhanced asset value, and increased tenant satisfaction.
- Investor and Regulatory Confidence
PAS 2038 compliance demonstrates due diligence in sustainability performance, strengthening access to green finance, ESG-linked investment, and public procurement opportunities.
- Future-Proofing Against Regulation
As environmental reporting obligations expand under frameworks like SECR (Streamlined Energy and Carbon Reporting) and ESOS Phase 3, PAS 2038 provides a ready foundation for compliance.
By aligning non-domestic retrofits with this standard, the UK is effectively bridging the gap between policy ambition and real-world implementation.
What Buildings and Professionals Does PAS 2038 Cover?
PAS 2038 applies to all non-domestic buildings in England and Wales — including commercial, industrial, and public sector facilities. These encompass:
- Offices and corporate premises.
- Retail outlets and shopping centres.
- Warehouses and logistics centres.
- Educational, healthcare, and hospitality buildings.
However, smaller commercial buildings below 500 m² in floor area that share similar construction and building services characteristics with homes may follow PAS 2035 instead.
The standard also outlines specific professional roles required to deliver compliant projects:
Lead Professional (or Lead Assessor)
Equivalent to the Retrofit Coordinator under PAS 2035, this individual manages the entire retrofit process — from initial assessment to verification. The Lead Professional must ensure compliance with the PAS 2038 framework, balancing performance outcomes with regulatory, financial, and operational constraints.
Qualified Non-Domestic Energy Assessors (NDEAs)
Level 4 and Level 5 NDEAs play a central role in assessing baseline energy performance, identifying inefficiencies, and quantifying projected improvements.
Specialist Retrofit Professionals
Depending on project scope, other accredited experts such as Building Services Engineers, Chartered Energy Managers, and Environmental Consultants contribute to the design and validation of retrofit measures.
Display Energy Certificate (DEC) Assessors
DEC professionals can support post-retrofit verification, ensuring actual performance aligns with expected outcomes.
Together, these roles create a multi-disciplinary framework that supports holistic, compliant, and evidence-backed retrofit delivery — a model ECMC implements on every accredited project.
PAS 2038 in Practice: A Strategic Framework for Retrofit Delivery
PAS 2038 mandates a process-driven methodology divided into sequential phases that ensure both quality and accountability. Each phase corresponds to measurable outcomes and documentation requirements.
Step 1: Assessment and Planning
A comprehensive evaluation of the building’s condition, systems, and energy profile. The Lead Professional defines objectives, constraints, and expected results.
Step 2: Design and Specification
Energy-saving measures are identified, designed, and prioritised for cost-effectiveness and carbon impact. The principle of fabric-first remains central.
Step 3: Implementation and Quality Control
Retrofit works are executed according to the defined plan, with clear roles, documented materials, and adherence to technical specifications.
Step 4: Verification and Handover
Upon completion, the project is verified against PAS 2038 performance criteria, including energy efficiency, indoor environment quality, and compliance documentation.
Step 5: Monitoring and Continuous Improvement
Performance data is collected post-retrofit to validate improvements, ensure persistence of energy savings, and inform future retrofit planning.
This structured lifecycle ensures that every retrofit project delivers not only compliance but also long-term operational and environmental value.
The Opportunity for Retrofit Professionals
For Non-Domestic Energy Assessors (NDEAs) and Display Energy Certificate (DEC) Assessors, PAS 2038 represents a major opportunity to expand their professional portfolio.
By qualifying under PAS 2038, assessors gain the ability to work on commercial retrofit projects that demand higher technical expertise and compliance oversight. This includes the preparation of energy models, decarbonisation roadmaps, and performance verification reports.
For Retrofit Coordinators qualified under PAS 2035, the transition into PAS 2038 projects opens new markets in the commercial and industrial retrofit domain, particularly for buildings that share hybrid residential-commercial characteristics.
In a market where non-domestic energy efficiency is becoming mandatory, PAS 2038 certification differentiates professionals who are ready to deliver verified, compliant, and value-driven retrofit outcomes.
Moving Forward: Making Energy Efficiency Actionable
As the UK accelerates its decarbonisation agenda, PAS 2038 stands as a vital enabler of practical, measurable, and high-quality retrofitting across non-domestic buildings. It bridges the policy–practice gap by offering a clear roadmap that organisations can follow to enhance building performance, reduce operational emissions, and future-proof their assets.
At ECMC, we see PAS 2038 not as a regulatory checkbox but as a strategic framework for action. Our focus is on helping building owners, developers, and facility managers understand where energy losses occur, how to prioritise improvements, and how to turn compliance into measurable savings.
