Ofgem Recovering 25% of RHI Payments for Missed Annual Biomass Boiler Servicing

Treco is seeing an increasing number of RHI compliance cases where Ofgem is recovering 25% of annual Renewable Heat Incentive payments because biomass boilers have not received the required annual maintenance check by a HETAS-approved provider.

For businesses receiving substantial income through the Non-Domestic Renewable Heat Incentive (RHI), the financial consequences of missing an annual biomass boiler service can be significant.

Since April 2022, RHI participants operating qualifying solid biomass boilers have been required to arrange an annual maintenance check that meets the MCS 040 standard, with appropriate certification issued by HETAS or an equivalent approved body.

Despite this requirement having been in place for more than four years, we are still encountering biomass boiler owners who are unaware of their obligations or who mistakenly believe that having their boiler serviced by any maintenance contractor is sufficient.

Across multiple compliance cases handled by Treco, we have now seen Ofgem seek recovery of 25% of RHI payments for payment years in which the required annual maintenance check was not completed.

This highlights the importance of ensuring that biomass boiler servicing is carried out by an appropriately registered maintenance provider and, crucially, within the correct RHI payment year.

What Could a 25% RHI Payment Recovery Cost You?

For many commercial biomass installations, RHI payments represent a substantial source of annual income.

Where the annual maintenance requirement has been missed in multiple payment years, the potential amount at risk can increase substantially.

For example, an installation receiving £60,000 annually could face a total recovery of £45,000 if 25% of payments were recovered for each of three non-compliant years.

The 25% figure reflects multiple compliance cases encountered by Treco.

What Are the RHI Annual Biomass Boiler Servicing Requirements?

From 1 April 2022, amendments to the Non-Domestic RHI Regulations introduced an annual maintenance requirement for installations generating heat using solid biomass or solid biomass contained in waste.

The requirement applies to qualifying installations participating in the Non-Domestic RHI scheme.

To demonstrate compliance, participants must ensure that:

• A qualifying maintenance check is completed in each RHI payment year.
• The maintenance is carried out in accordance with the MCS 040 maintenance standard.
• The work is undertaken by a suitably registered and competent maintenance provider.
• Appropriate certification is issued by HETAS or an equivalent body approved under the regulations.
• Evidence of the maintenance is retained and made available to Ofgem if requested.

HETAS operates the Approved Biomass Maintenance Scheme, through which registered businesses can undertake qualifying maintenance and issue the required documentation.

Having a biomass boiler serviced does not necessarily demonstrate RHI compliance unless the work meets the applicable maintenance standard and is supported by the required evidence.

Why the RHI Payment Year Matters

One of the most important details, and one that can easily be overlooked, is that the maintenance requirement applies to each RHI payment year.

This is not necessarily the same as the calendar year running from January to December.

For example, if an installation's RHI payment year runs from 1 July to 30 June, a qualifying maintenance check must be completed within that payment year.

Having a boiler serviced in May one year and August the following year could leave the intervening payment year without a qualifying maintenance check, depending on the precise dates.

This means that simply booking a service approximately once every 12 months is not always sufficient.

We recommend that RHI participants establish the exact start and end dates of their payment years and arrange maintenance well before the relevant deadline.

Leaving servicing until the final weeks of a payment year increases the risk of non-compliance if an engineer is unavailable or the appointment needs to be postponed.

What Happens if Your Biomass Boiler Has Been Serviced by a Non-HETAS Contractor?

We encounter situations where biomass boiler owners have arranged regular servicing but have not appreciated that the RHI scheme has specific requirements concerning the maintenance standard and certification.

A boiler may have been maintained by a competent engineer, but if the maintenance does not meet the relevant RHI requirements or the necessary evidence cannot be provided, the participant may still face compliance difficulties.

This can be particularly relevant where:

• The original biomass installer is no longer trading.
• Maintenance has been transferred to a general facilities management contractor.
• A new service provider is unfamiliar with the RHI requirements.
• The servicing company is not registered under the appropriate maintenance scheme.
• The boiler has been serviced but the necessary HETAS maintenance documentation has not been issued.

If you are unsure whether your current maintenance provider is appropriately registered, we recommend checking their status and confirming that they issue the necessary RHI maintenance certification.

What if You Have Already Missed an Annual Service?

If you believe that a qualifying maintenance check has been missed in a previous RHI payment year, it is important to investigate the situation promptly.

Arranging a compliant service now can help ensure that the current payment year's requirements are met, but it does not automatically correct a failure in a previous year.

We recommend:

1. Checking the payment-year dates for your RHI installation.
2. Reviewing your service records from April 2022 onwards.
3. Confirming whether qualifying HETAS maintenance documentation was issued for each applicable payment year.
4. Identifying any missing or incomplete records.
5. Arranging the next qualifying maintenance check before the current payment-year deadline.
6. Seeking specialist advice where historical non-compliance or an Ofgem investigation is identified.

If Ofgem has already contacted you about missing annual maintenance evidence, it is important to understand exactly what information is being requested and respond within the specified timescales.

Why Is Annual Biomass Boiler Maintenance Important?

The annual maintenance requirement is not simply an administrative exercise.

Proper maintenance helps ensure biomass boilers continue to operate safely, efficiently and with appropriate emissions performance.

A comprehensive biomass boiler maintenance check may include:

• Inspection and cleaning of heat exchanger surfaces.
• Inspection of combustion chamber components.
• Checking combustion performance and control settings.
• Inspection of fuel feed and ash removal systems.
• Checking safety devices and associated components.
• Inspection of seals, fans and other mechanical equipment.
• Reviewing the condition of the boiler and identifying developing faults.

The exact maintenance requirements depend on the boiler manufacturer, model, output and operating conditions.

Regular maintenance can also help identify problems before they result in expensive breakdowns or extended heating system downtime.

How Treco Can Help With RHI-Compliant Biomass Boiler Servicing

Treco provides commercial and industrial biomass boiler servicing, maintenance and RHI compliance support.

Our HETAS-approved biomass maintenance capability allows us to assist customers with meeting their annual servicing obligations.

We can help with:

• Annual biomass boiler maintenance in accordance with the applicable RHI requirements.
• HETAS maintenance documentation for qualifying work.
• Planning maintenance around RHI payment-year deadlines.
• Reviewing historical service records and identifying potential compliance gaps.
• Responding to technical questions raised during Ofgem compliance investigations.
• Wider biomass boiler repairs, maintenance and technical support.
• Assistance with RHI account amendments and other ongoing obligations.

We also provide servicing and maintenance for biomass boilers originally installed by other companies.

Don't Risk Losing 25% of Your Annual RHI Payments

With Treco now seeing multiple Ofgem compliance cases involving recovery of 25% of annual RHI payments, the financial implications of missing a qualifying annual biomass boiler service should not be underestimated.

For an installation receiving £100,000 per year in RHI income, a 25% recovery represents £25,000.

That is a substantial amount of money to put at risk by overlooking an annual maintenance requirement.

If you are unsure whether your biomass boiler has received a qualifying HETAS maintenance check during the current RHI payment year, now is the time to check.

Treco can help you establish your servicing requirements, arrange the necessary maintenance and review any concerns about historical compliance.

Contact Treco's Biomass Service Team

Telephone: 01884 684916

Email: [email protected]

Find out more about Treco's biomass boiler servicing and maintenance

The 25% recovery figure is based on multiple Ofgem compliance cases encountered by Treco. It should not be interpreted as a standard or automatic penalty for every missed annual maintenance check. Individual enforcement decisions depend on the circumstances of the case.