Installer briefing: Changes to the Heat Pump Standard – MIS 3005 split
29th March 2022
On 1 April 2022, significant changes to the MCS Heat Pump Standard (MIS 3005) will come into effect.
The standard is to be split between Design and Installation, creating two new Standards:
This split is intended to improve access to the MCS Scheme, reflecting two distinct skill sets that exist within the heat pump sector, with system design separate from installation.
To accommodate an increase in contractors wishing to install heat pumps, this change will allow for those who wish to focus on ‘installation only’ to work with an independent designer. It also allows a designer to support certified installers.
The two new Standards were published on the MCS website on 1st December 2021 and will be mandatory from the 1 April 2022, following the closure of Domestic RHI.
This separation will have little impact on existing contractors who, by default, are currently certified for both design and installation (under MIS 3005 issue 5.0). On 1 April 2022, all contractors currently certified to the existing standard will automatically be granted certification to both new Standards. At the time of their next surveillance assessment, contractors will be asked to confirm to their certification body (CB) if they wish to be certified for only D or I, or both.
- Now two heat pump Standards – one for design and one for installation.
- New Standards become mandatory on 1 April 2022.
- Existing certified contractors get ‘grandfather rights’ and will continue to be certified until their next surveillance visit.
- Compliance certificates will no longer be required.
- The MID is being updated to support this split in heat pump Standards.
- If you want to provide direct feedback to the Working Group on the new Standard, you can email email@example.com
Heat pump design is a specialist area, and the performance of an installation is highly dependent on good design. If a clear design is provided, installation can be undertaken by most skilled heating engineers who may only be familiar with the installation of fossil-fuelled systems. By separating out heat pump design and heat pump installation, we can encourage those fossil-fuelled heating installers into the heat pump industry and grow the capacity we will need for the transition away from fossil fuels.
Q2. If I am already certified against MIS 3005 Issue 5.0, how does this split in the Standard affect me from 1 April 2022?
You will gain ‘grandfather rights’ meaning that you will be certified for both heat pump design and heat pump installation. Then, at your next surveillance visit with your CB you can either:
- remain certified for design and installation but against both MIS 3005-D and MIS 3005-I or,
- change to being only a certified designer (against MIS 3005-D) or,
- change to being only a certified installer (against MIS 3005-I).
MCS does not formally define ‘grandfather rights’ in any of its Standards. However, ‘grandfather rights’ are typically where historic certification, qualification and competency can be considered as meeting current or future requirements. In the case of the split of MIS 3005, you will have to meet the competency requirements of whichever Standard you are being assessed against during the assessment – either at first assessment or annual surveillance. Therefore, ‘grandfather rights’ for existing contractors certified against MIS 3005 (Issue 5.0) will last until your next surveillance assessment.
You have a choice depending on the competencies within your company. You could choose either to:
- Get certified against both MIS 3005-D and MIS 3005-I if you can demonstrate competencies for both.
- Get certified only as a heat pump designer (against MIS 3005-D). You can then sub-contract to an installer certified against MIS 3005-I.
- Get certified only as a heat pump installer (against MIS 3005-I). You can then sub-contract to a designer certified against MIS 3005-D.
Q5. If we are only certified for design against MIS 3005-D, how can we deliver a compliant installation?
If you hold the contract with the customer directly, you can undertake the design work, but you would need to sub-contract the installation to an installer that is certified against MIS 3005-I. The responsibility for raising the MCS certificate and overall responsibility for the system would sit with you as the designer as you hold the contract. You must also ensure that the MIS 3005-I sub-contractor’s installation is complaint with the Standard.
Q6. If we are only certified for installation against MIS 3005-I, how can we deliver a compliant installation?
If you hold the contract with the customer directly, you can undertake the installation work, but you would need to sub-contract the design to an installer that is certified against MIS 3005-D. The responsibility for raising the MCS certificate and overall responsibility for the system would sit with you as the installer as you hold the contract. You must also ensure that the MIS 3005-D sub-contractor’s design is complaint with the Standard and appropriate for the property.
Q7. What does audit and assessment look like for MIS 3005-D and MIS 3005-I? Is this doubled-up if a Contractor wants to be certified for both?
- Certification assessment for design would be against MCS 001-1 and MIS 3005-D so including assessment of designs.
- Certification assessment for installation would be against MCS 001-1 and MIS 3005-I so including assessment of installations and workmanship.
- If a contractor is being assessed for both design and installation, they’d only be assessed the once against MCS 001-1. Then their designs would be assessed against MIS 3005-D and their installation work assessed against MIS 3005-I.
There are many clauses duplicated across both standards so a combined assessment will not require twice the time/resource of a single assessment.
NB. By splitting of the standard, there are no additional technical or competency requirements – the levels of competence in MIS 3005-D and MIS 3005-I haven't increased, they have simply been separated.
- Contractors certified against both MIS 3005-D and MIS 3005-I can sub-contract as normal, if they meet the requirements in MCS 001-1 clause 4.11 relating to subcontracting for the appointment and supervision of any subcontractor.
- Contractors certified for heat pump design (MIS 3005-D) will only be able to sub-contract the installation to certified installers (MIS 3005-I). This is because they won’t have demonstrated the competencies required to install (or supervise those installing).
- Contractors certified for heat pump installation (MIS 3005-I) will only be able to sub-contract the design to certified designers (MIS 3005-D). This is because they won’t have demonstrated the competencies required to design (or supervise those designing).
Yes, but only if you are certified against both MIS 3005-D and MIS 3005-I as this demonstrates that you have the competencies to train and supervise your sub-contracted designers and installers (as stipulated in MCS 001-1 clause 4.11).
Q10. If a consumer/homeowner identifies a designer certified against MIS 3005-D and an installer certified against MIS 3005-I that they would like to use, can they contract separately with each to arrive at an MCS certified installation?
No – neither of the above would be permitted to raise an MCS certificate as neither would be contractually responsible to the consumer for BOTH design and installation (i.e. a fully working system). The only way that they could get an MCS certificate is if they were to contract with either the designer or the installer, who then sub-contracts to the other. That way, there is only one contract for a fully functioning system.
Q11. An MCS certified contractor has identified a designer certified against MIS 3005-D and an installer certified against MIS 3005-I and they would like to use them both. Can they contract separately with each to arrive at an MCS certified installation?
Yes, but only if they are certified against both MCS 001-1 and MIS 3005-D and MIS 3005-I. This is because an MCS certificate can only be generated by an MCS certified contractor who holds the contract directly with the customer. Neither of their preferred sub-contractors (designer or installer) can raise a certificate as they would not have the contract with the customer given they are their sub-contractors.
Q12. If a contractor wants to become certified against MIS 3005-D and/or MIS 3005-I only for the purpose of sub-contracting to a certified designer or installer, do they have to be a member of a Consumer Code given that they won’t have contracts directly with customers?
Yes, they will as this is a requirement in MCS001-1 (clause 4.4).
Q13. If a contractor is only certified for heat pump design (MIS 3005-D) or heat pump installation (MIS 3005-I) who registers the installation on the Microgeneration Installation Database (MID) to create the certificate for the customer?
Whichever contractor (designer or installer) has the contract with the customer can register the system on the MID (as stipulated in clause 4.10.1 of MCS 001-1).
Q14. If a contractor is certified as an Installer (MIS 3005-I) can they sub-contract to non-certified installers to undertake some of their installations?
Yes, they can but they will have to comply with the requirements in MCS 001-1 clause 4.11 for sub-contracting and, most importantly, demonstrate that their company has the necessary in-house competencies to train and supervise any subcontractors they use.
Yes, you can design against the new Standard MIS 3005-D straightaway. This was published on the MCS website on 1st December 2021. An installation compliant with the old Standards will be considered compliant with the new.
Q16. The new Standards only become valid from 1 April 2022 so what happens if a current MCS certified installer is designing now (under the old version of the Standard) for installations that will be commissioned after 1 April?
At the point at which the installation is commissioned and handed over to the customer, it must be compliant with the version of the Standard in force at that time. This is why we published the new versions several months in advance of their implementation. That way, if an MCS certified contractor has installations likely to be commissioned on or after 1 April 2022, they can design and install them to be compliant with the new version of the Standard.
If the installation is commissioned before the end of 31 March 2022 (i.e. before the old version is withdrawn), and designed and installed according to the new version, then it will be compliant with the old (because the new requirements are no less than in the old).
We’d therefore recommend contractors start working to the new versions as soon as they can.
Q17. Historically, when MCS has updated a Standard there has been a transition period (often around six months) where both the old and new versions are applicable. Why is that not the case this time?
Both the new and old Standards are closely linked to government legislation, which needs to be clear in terms of precisely which standards apply and when. Having both old and new versions applicable at the same time could have caused confusion both with certified contractors, the applicable legislation and consumers.
Compliance Certificates are a separate Excel spreadsheet document that had to be completed and uploaded to the MID when an installation was being registered. They were introduced at the request of government to help with the administration of the Renewable Heat Incentive scheme. As that scheme will cease to new applications from 31 March 2022, Compliance Certificates will no longer be required.
All the CBs are aware of the new Standards and are in the process of developing their own internal procedures to certify against the new Standards as soon as they are implemented from 1 April 2022.
NAPIT is offering certification against D&I combined, D only and/or I only.
OFTEC is offering certification against D&I combined, D only and/or I only.
NICEIC is offering certification against D&I combined only.
APHC is offering certification against D&I combined only.
Q21. If a contractor was MCS certified for another technology (e.g. Solar PV), could they secure a heat pump installation contract but sub-contract to certified heat pump designers and installers?
No. Under MCS 001-1 clause 4.10.1 a contractor would need to have the contract with the customer for the technology type(s) they are certified for. So, in this scenario they would need to add heat pumps to their certification scope with MCS.
Both new Standards are now available on the MCS website; you should read them and familiarise themselves with the new clauses.
We are also accepting feedback in relation to the new Standards. In October 2022, we will review all feedback and share with the Heat Pump Working Group to help shape updates to the Standards.
You can email any comments or feedback to: firstname.lastname@example.org.