Industry Challenges
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UK F-Gas Regulations for HVAC Operators

F-Gas compliance for commercial HVAC operators comes down to a handful of recurring obligations: checking for leaks on a schedule set by CO2 equivalent, keeping specific records for five years, and making sure anyone touching the refrigerant circuit holds the right certification, against a refrigerant supply that's about to tighten further. This post gives an overview of each, with links through to the official guidance and legislation for anyone who needs the full detail.

Which regulations apply

The Fluorinated Greenhouse Gases Regulations 2015 is the UK statutory instrument giving effect to F-Gas rules in Great Britain, incorporating the retained EU Regulation 517/2014. Gov.uk's F-Gas guidance collection confirms it covers anyone who uses or services equipment containing F-gases, including refrigeration, air conditioning and heat pump systems, regardless of whether that business produces, imports, sells or simply operates the equipment. Northern Ireland remains subject to the EU's own F-gas system rather than the GB regulation for most purposes.

Enforcement sits with different bodies depending on where a business is registered: the Environment Agency for England, and the Scottish Environment Protection Agency, Natural Resources Wales and the Northern Ireland Environment Agency for their respective nations, all listed with contact details on the gov.uk collection above.

A separate duty worth knowing about is TM44. Gov.uk's guide to air conditioning inspections confirms this applies to England and Wales only, under different legislation from F-Gas, and requires an inspection at least every five years for systems with a combined cooling output over 12kW. Scotland and Northern Ireland have their own separate arrangements.

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The refrigerant phase-down

The regulation caps the total quantity of HFC refrigerant that can be placed on the GB market each year, set as a percentage of a fixed baseline. Annex V of the regulation sets that percentage at 31% for 2024 to 2026, stepping down to 24% for 2027 to 2029, and 21% from 2030, a reduction of roughly a fifth at the next step.

Defra consulted in late 2025 on tightening this further, but its May 2026 update to that consultation confirms it will not legislate in 2026 to change the phase-down steps due from 1 January 2027, so the Annex V schedule above proceeds as already set out. The practical effect for operators is straightforward: less high-GWP refrigerant entering the market pushes price up and availability down, and that's a trend to plan for rather than a one-off event.

Separately, virgin refrigerant with a global warming potential above 2,500 has been banned for refilling refrigeration equipment holding 40 tonnes CO2e or more since 2020, as set out in gov.uk's guidance on banned refrigerants for refilling. Existing equipment can keep running and being serviced, the restriction is on adding new virgin high-GWP gas to systems above that threshold.

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Leak checks: set by CO2 equivalent, not cylinder size

Leak-check frequency depends on the CO2-equivalent weight of the refrigerant charge, not the number of kilograms in the system, since it factors in the gas's global warming potential. Gov.uk's guidance on checking F-gas equipment for leaks sets out the bands in full, summarised here:

  • 5 to under 50 tonnes CO2e: at least every 12 months
  • 50 to under 500 tonnes CO2e: at least every 6 months
  • 500 tonnes CO2e or more: automatic leak detection required, with checks every 3 months for certain older switchgear and organic Rankine cycle equipment instead
  • Automatic leak detection doubles the permitted interval between manual checks below the 500-tonne threshold
  • Hermetically sealed systems have no fixed interval until the charge reaches 10 tonnes CO2e

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Recordkeeping: what to hold and for how long

Gov.uk's guidance on recording F-gas in equipment sets out the requirement in full. In brief, records must be kept for 5 years for any equipment holding 5 tonnes CO2e or more, covering the gas quantity and type at installation, any gas added during maintenance, leak-check dates and results, and recovery or disposal details. Operators must also hold the certificate number of any company used to install, service or decommission the equipment. Your regulator can ask to see these records during an inspection.

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Certification: what qualifies someone to do the work

Gov.uk's guidance on F-gas qualifications sets out four categories of personal certification for refrigeration, air conditioning and heat pump work, from Category 1 (full scope) through to Category 4 (leak checks only, without breaking into the circuit). These come from City and Guilds, the Building Engineering Services Association, or LCL Awards.

Separately, any company servicing F-gas equipment for someone else needs its own company certification, renewed every 3 years. Gov.uk's guidance on company certification lists the approved bodies, including Refcom, which certifies the stationary refrigeration and air conditioning sector. When engaging a contractor, both the individual's category certificate and the company's certification are worth asking to see.

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Frequently asked questions

Does F-Gas certification apply to systems under 3kg?

Yes. Personal qualification requirements apply regardless of system size. Size determines which category applies, not whether a qualification is needed.

Can existing equipment keep using high-GWP refrigerants like R-404A?

Yes, for equipment already in service. The main restriction under the current ban is on adding new virgin refrigerant with a GWP above 2,500 to systems holding 40 tonnes CO2e or more, not on running or servicing that equipment.

Does Northern Ireland follow the same rules as Great Britain?

No. Northern Ireland remains subject to the EU's own F-gas system rather than the GB regulation for most purposes, per gov.uk's guidance collection.

Who enforces F-Gas compliance?

The Environment Agency in England, SEPA in Scotland, Natural Resources Wales, and NIEA in Northern Ireland. TM44, where it applies, is enforced separately by Trading Standards.

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Where this sits with your maintenance records

Most of what an auditor asks for traces back to the asset register: what gas is in a system, what's been added, when it was last checked, and who did the work. Service Geeni's F-Gas module ties cylinder transactions, leak-check reporting and engineer records to the specific asset they belong to, so the five-year record sits against the equipment itself rather than across several systems. It's part of a wider commercial HVAC maintenance platform built around the same asset-first approach.

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