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SAP New Build Dwellings -
Photographic Evidence

Any new build dwellings approved since 15th June 2022 must now comply with new photographic evidence requirements, in accordance with the 2021 edition of Approved Document L. This means that for each new dwelling the energy assessor (and building control) have to be provided with images of details of the build, taken throughout the construction of the property.

The introduction of this requirement comes due to concern over a performance gap between expected performance and how new build properties actually perform in terms of energy rate, CO₂ emission rate and energy bills. Three factors have been identified as affecting the performance gap: build quality, limitations of energy models, and occupant behaviour. To address the build quality factor and increase the accuracy of energy calculations, the requirement of photographic evidence has been introduced.

What needs to be photographed?

To create the record for dwellings on a development, for each dwelling there must be photographs showing them thermal continuity and insulation quality of:

  1. Foundations/substructure and ground floor:
    1. At ground floor perimeter edge insulation.
    2. At external door threshold.
    3. Below damp-proof course on external walls.

  2. External walls, for each main wall type:
    1. Ground floor to wall junction.
    2. Structural penetrating elements.

  3. Roof, for each main wall type:
    1. joist/rafter level.
    2. Structural penetrating elements.

  4. Openings, for each opening type:
    1. Window positioning in relation to cavity closer to insulation line.
    2. External door set positioning in relation to cavity closer or insulation line.

  5. Airtightness - if not included/visible in continuity of insulation image, then additional photographs will be required for details 1-4 to show airtightness.

  6. Building services, for all plant associated with space heating, hot water, ventilation and low/zero carbon technology within or on the building:
    1. Plant/equipment identification labels - make, model and serial number
    2. Primary pipework continuity of insulation
    3. Mechanical ventilation ductwork continuity of insulation (for duct sections outside the thermal envelope).

Sample photo of 1b external door threshold.

Sample photo of 4a/b window/door positioning to cavity closer/insulation line.

For blown insulation, the photographs must show clean brick ties and cavities with minimal mortar droppings.

To ensure that the thermal continuity and insulation quality is property shown, the photographs must be high quality digital.

Who should take the photographs?

While anyone can take the photos, it is the builders' responsibility to organise who will take them

When should the photos be taken?

Photos should be taken throughout the build, once each detail is completed and prior to closing-up the works.

Who needs to receive the photographs?

The energy assessor, building control, and eventually building owner will require the photographs.

How should photographs be provided?

Building Control Bodies (BCBs) have previously commented that they would prefer photographs to be submitted in a report which includes all necessary information, such as:

  • Address
  • Client
  • Report date
  • Images clearly annotated with what the image is of, references and any additional notes.

It is good practice for the photographs to be location and time stamped.

Can the same photographs be used for multiple properties on one development?

No, the pictures must be unique to each dwelling.

What if I'm missing one photograph?

If one photograph is missed then it is acceptable to use an alternate form of evidence, such as commissioning certificate, as long as it provides the necessary detail (such as the make and model). This may, however, cause delays if the BCB isn’t happy with the missing photograph.

If there are no photographs available then this is not acceptable.


Performance Gap - The difference between how a building is expected to perform based on SAP calculations and how it performs in reality.

BCB - Building Control Bodies.

Dwelling - A place of residence, E.G. a house or flat.

SAP - Standard Assessment Procedure.

EPC - Energy Performance Certificate.

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