UK Energy Smart Appliances Compliance: Dates and Routes
UK Energy Smart Appliances Compliance: DESNZ Moves Heating Deadline and Accepts EN 18031-3 and MID
UK energy smart appliances compliance has two important updates. On 17 September 2026, the Department for Energy Security and Net Zero (DESNZ) published an interim response to its consultation on the first phase Energy Smart Appliances Regulations. It gives electrical heating appliances more time and opens extra routes to compliance for metering and cyber security.
Background: the SSES Programme and the draft ESA Regulations
The Smart Secure Electricity Systems (SSES) Programme aims to unlock flexibility from small devices such as heat pumps and EV charge points. DESNZ consulted on the draft Energy Smart Appliances Regulations 2026 from 1 December 2025 to 5 February 2026. They apply in Great Britain only.
The draft rules would bring in a smart mandate for electrical heating appliances (EHAs), carry over the Electric Vehicles (Smart Charge Points) Regulations 2021 with some changes, and set minimum requirements for smart functionality, cyber security and grid stability. In scope are EHAs up to 45 kW, such as heat pumps, hybrid heat pumps, heat batteries, storage heaters and standalone direct electric hot water cylinders, along with EV smart charge points and domestic or small-scale smart battery storage. Obligations fall on manufacturers and importers placing products on the GB market, with OPSS as the proposed enforcement authority.
Key Changes in the UK Energy Smart Appliances Compliance Plan
The interim response sets out three decisions, shared before the full government response so manufacturers can plan.
A later date for electrical heating appliances
The consultation proposed that EHA requirements, including the smart mandate, would apply from 31 December 2027. Subject to final parliamentary approval, the date will now be 31 October 2028 or two years after the regulations are made, whichever is later.
MID accepted for metering
The draft required a Class B electricity meter complying with the Measuring Instruments Regulations 2016. Compliance with the EU Measuring Instruments Directive (MID) will now be deemed equivalent.
EN 18031-3 accepted for cyber security
The draft pointed to ETSI EN 303 645 and only said EN 18031 might be considered in future. Conformity with EN 18031-3:2024 will now be accepted as an equivalent route alongside ETSI EN 303 645.
DESNZ says these changes should ease the compliance burden by giving manufacturers and importers more choice of certification and approval bodies.
What This Means for Manufacturers
Heat pump, storage heater and hot water cylinder makers get at least ten more months before the smart mandate applies.
Products already tested for the EU market may be able to reuse evidence. MID-compliant meters and EN 18031-3 assessments now count.
Design work shouldn't stop. The requirements themselves haven't been dropped, and the final text could still change.
EV charge point and battery storage makers should note that the interim response only changes the date for EHAs.
A full government response and final regulations are still to come, so keep an eye on DESNZ publications.
Certification Impact Summary
Area | Before | After | Impact level |
EHA implementation date | 31 December 2027 | 31 October 2028 or 2 years after the regulations are made, whichever is later | High |
Metering compliance | Measuring Instruments Regulations 2016 | MIR 2016 or EU MID (deemed equivalent) | Medium |
Cyber security route | ETSI EN 303 645 | ETSI EN 303 645 or EN 18031-3:2024 | Medium |
Products in scope | EHAs, EV smart charge points, smart battery storage | Unchanged in the interim response | Low |
Legal status | Draft regulations | Still subject to final parliamentary approval | To be confirmed |
Timeline and Required Actions
Key Dates
Date | Milestone |
1 December 2025 – 5 February 2026 | Consultation on the draft Energy Smart Appliances Regulations 2026 |
17 September 2026 | Interim response published |
To be confirmed | Full government response and final regulations |
31 October 2028 at the earliest | Requirements apply to electrical heating appliances |
Required Actions for Manufacturers
Check which of your heating, charging and storage products fall in scope for Great Britain.
Update project plans for EHAs to the new date, without pausing design work.
See whether existing MID meter certificates can support your metering evidence.
Decide between ETSI EN 303 645 and EN 18031-3:2024 for cyber security, based on the testing you already have.
Prepare the technical file and statement of compliance the draft rules expect.
Watch for the full government response and the final regulations.
Conclusion
DESNZ has given heating appliance makers more time and more flexibility, but the direction hasn't changed: smart, secure and accurate devices will be required in Great Britain. Use the extra time to line up evidence that works for both the UK and the EU. Contact our team for support with UK energy smart appliance compliance.
