PAS 2038 Compliance: What Retrofit Professionals Need To Know

NEWS

9th April 2025

As the UK moves closer to its ambitious goal of achieving net-zero carbon emissions by 2050, retrofitting non-domestic buildings has become a crucial strategy in reducing overall energy consumption and emissions. 

Buildings such as offices, hospitals, and industrial facilities account for a significant portion of the nation’s carbon footprint, contributing around 23% of the total emissions, making them a key focus for decarbonisation efforts. 

To address this, PAS 2038, introduced in 2021, provides a comprehensive British Standard that outlines best practices for retrofitting these buildings, to enhance their energy efficiency. 

The framework ensures that retrofit projects are carried out with precision, resulting in sustainable and long-lasting improvements. For retrofit professionals, understanding PAS 2038 compliance can help with securing funding and achieving sustainability goals, while also delivering high-quality retrofit outcomes. 

We’ll explore what retrofit professionals need to know about PAS 2038 compliance below, including how our courses can help you understand and apply its principles effectively. 

What Is PAS 2038?

PAS 2038 is the British Standard designed to guide the retrofitting of non-domestic buildings, ensuring energy efficiency improvements are well-planned, executed, and maintained. 

Introduced in 2021, the framework provides a structured, whole-building approach that considers everything from initial assessments to post-installation evaluation. By defining key roles, competencies and project stages, PAS 2038 promotes consistency and high-quality outcomes across the industry. 

Beyond reducing energy consumption, PAS 2038 delivers broader benefits. Retrofit projects carried out under this standard can enhance occupant comfort, improve indoor environments, and extend building lifespan. 

It also helps preserve the architectural and cultural value of structures while reducing their environmental impact. By addressing these factors, PAS 2038 supports the UK’s commitment to cutting carbon emissions and creating more sustainable, resilient buildings. 

As sustainability regulations tighten, PAS 2038 is expected to become a key requirement for accessing government-backed retrofit funding. For professionals, compliance with this standard ensures projects meet best practices and opens doors to new commercial opportunities. 

Retrofit projects carried out under PAS 2038 can enhance occupant comfort, improve indoor environments, and extend building lifespan.

Which Buildings Does PAS 2038 Apply To?

PAS 2038 is designed for non-domestic buildings across England and Wales, covering a wide range of properties, such as retail spaces, and public sector facilities. However, not all non-domestic buildings are required to follow PAS 2038.

Smaller commercial buildings, which are under 500m² with building services similar to residential properties, have the option to follow PAS 2035 instead. This allows building owners and project managers to choose the most suitable framework, based on the scale and complexity of their retrofit needs.

PAS 2038 is particularly relevant for projects funded or supported by government schemes. This helps sustain a standardised approach to improving energy efficiency in larger, more complex non-domestic buildings

The standard also accounts for historic and traditionally constructed buildings, recognising the need for specialised assessment and conservation considerations. 

While PAS 2038 focuses on retrofit, rather than routine maintenance and repair, it does emphasise that buildings should be in good condition before energy efficiency upgrades take place. 

PAS 2038 also applies when a building component is replaced with a version that improves its energy efficiency, such as upgrading to better insulation, energy-efficient windows, or a more efficient heating system. 

Before proceeding with a retrofit, professionals should assess whether PAS 2038 or PAS 2035 is the best fit for their project, ensuring compliance with the appropriate standards and achieving optimal energy efficiency outcomes. 

PAS 2038 is designed for non-domestic buildings across England and Wales, covering a wide range of properties, such as retail spaces, and public sector facilities.

Key Roles In PAS 2038

PAS 2038 promotes a high-quality, well-structured approach to retrofitting non-domestic buildings by outlining responsibilities and necessary qualifications.

The framework outlines three essential lead roles responsible for overseeing and delivering successful retrofit projects.

  • Retrofit Lead Professional: Acting as the project manager, this individual is responsible for coordinating the entire retrofit process. Depending on the project’s focus, the role may be filled by a specialist in building fabric or building services. 
  • Lead Assessor: This role involves evaluating the existing building, including its condition, energy performance, and usage patterns. The assessment may rely on both new inspections and existing documentation. 
  • Lead Designer: Responsible for the design and specification of retrofit measures, the Lead Designer ensures that improvements align with energy efficiency goals while maintaining structural integrity and compliance with regulations. 

 

These roles require specific qualifications, particularly in areas like condensation risk assessments and energy performance analysis. Additional expertise is needed for projects involving traditionally constructed or protected buildings, where professionals must hold a Level 3 Award qualification in retrofitting traditional buildings. 

The Retrofit Lead Professional also checks that all aspects of the project align with PAS 2038, from defining objectives to managing costs and regulatory compliance. 

PAS 2038 defines three key roles: Retrofit Lead Professional, Lead Assessor, and Lead Designer—to manage energy-efficient retrofits for non-domestic buildings.

Competency Requirements & Professional Development

The energy efficiency retrofit of historic buildings is a highly specialised field, and PAS 2038 recognises this by introducing strict competence criteria. 

Retrofit professionals working on these buildings must complete the Level 3 Award qualification. This ensures that they are qualified to handle the complexities involved in retrofitting protected buildings.

At Environment Study Centre, our Level 3 Award for Energy Efficiency for Older & Traditional Buildings (QCF) is a government-approved qualification that ensures professionals are equipped to work on heritage and traditionally constructed structures.

Developed by industry experts, including Professor John Edwards, who played a key role in developing PAS 2038, this two-day course covers essential topics such as assessing building characteristics, evaluating retrofit options, and providing informed recommendations. 

The qualification is essential for those involved in retrofit assessments, improvement planning, or regulatory approvals for historic and traditionally built properties. 

How Can We Help

We hope that this post on PAS 2038 compliance helps you understand the key requirements of PAS 2038 compliance and where it applies in future retrofit projects. 

With over 2,000 professionals trained since 2015, including those from the English Heritage and National Trust, the Environment Study Centre is a trusted leader in retrofit education. 

We are committed to providing the knowledge retrofit professionals need to navigate PAS 2038 compliance. 

For further details on our Energy Efficiency for Older and Traditional Buildings course, or queries on our other retrofitting courses, please contact us

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