Our Part S Review - The Changes We'd Make
Part S Building Regulations: Part 2 of 3
Part S has been in effect for over two years now. In this three-part series, we examine what's working, what's failing, and what developers can do about it. In Part 1, we outlined what's failing with Part S regulations. Here, we share six specific changes that would help developers, property managers, and residents.
In Part 1, we argued Part S regulations are failing to deliver functional EV infrastructure. The Building Regulations (Part S) are currently in a Statutory Review period. We've submitted formal recommendations and here, we share some of our ideas to help the industry move in the right direction.
Proposal 1: Mandate Open Protocol Systems (OCPP 1.6 Minimum)
Current situation: Part S doesn’t specify communication protocols.
The problem: Closed, proprietary systems lock residents and property managers into single suppliers, stifling competition.
Our proposal: Mandate Open Charge Point Protocol (OCPP) version 1.6 or higher for all hardware and software.
Why it matters: OCPP is the international standard. 95% of the market already supports it. The remaining 5% are legacy systems or deliberate lock-in models.
Open protocols will help competition. If your operator provides poor service, you can switch without replacing hardware.
The pushback: "Integrated solutions work better together!"
Maybe. But they can still operate with open protocols, they just can't use lock-in as a business model. If their integration is genuinely superior, they'll win on merit.
Proposal 2: Remove the Underground Car Park Exemption
Current situation: Underground car parks can be exempted if deemed “too difficult”.
The problem: This exempts exactly the developments that most need EV infrastructure - urban housing where residents have no other charging options.
Our proposal: Remove the exemption. Replace with mandatory guidance on safe implementation:
Ventilation requirements for enclosed parking
Fire safety specs (sprinkler integration, smoke detection, emergency cutoff)
Load management to work within existing capacity
WiFi/cellular connectivity for monitoring
Why it matters: Urban air quality is worst where this exemption is most used. Underground parking in new builds must be electrified.
The pushback: "This will make urban developments more expensive."
As much as we want to see more infrastructure go where it’s needed, there also must be an acknowledgement that in some areas the current guidance overshoots. For example, in retirement villages the provision is 100% despite the residents often driving very little and having the opportunity to share a charging facility. Total provision in these spaces leads to very poor utilisation (now and in the future) but increases the costs of developing homes for our growing elderly population. It just doesn’t make sense.
Proposal 3: Define "Passive Provision" With Actual Standards
Current situation: Part S requires "cable routes" without defining what this means.
The problem: Vague language produces infrastructure that looks good on checklists but is unusable.
Our proposal: Replace vagueness with specifics by tightening the definition of a future ‘Connection Location’ (taking the opportunity to align with OZEV language) and the software and load management provision required to achieve this.
Why it matters: Passive provision costs money. If it can't be activated when needed, that money is wasted. Failures here also undermine EV adoption and confidence.
Proposal 4: Mandate Operational Handover Plans
Current situation: Part S requires infrastructure installation, but doesn’t provide guidance or obligations relating to ongoing management.
The problem: For shared parking (flats, apartments) this becomes a massive problem. Property managers don't have expertise or systems to manage chargers. Residents don't want service charges for infrastructure they don't use and developers certainly don’t want to retain a complex interest long after they’ve left site.
Our proposal: For developments with shared parking serving 5+ units, require:
Clear handover plan identifying who will manage the infrastructure post-completion
Maintenance and warranty provisions
Guidance on how billing will work and how residents will be charged
Assignment to a nominated operator with clear responsibilities and minimum service levels
Why it matters: This is one of the biggest gap. Installing hardware without operational systems is causing residents and property managers all sorts of headaches.
The pushback: “It’s already hard enough”
Building regs cover water supply, Wi-Fi supply, electrical supply. Why is EV infrastructure different?
Proposal 5: Mandate Connectivity Requirements
Current situation: Part S is silent on internet connectivity for chargers.
The problem: EV chargers need internet to function properly. Billing, smart charging, remote diagnostics, and grid flexibility all depend on internet functionality. Yet many installations (especially underground car parks) have no connectivity plan.
Our proposal: Mandate that all EV infrastructure must have reliable internet connectivity, WiFi or 4G/5G connectivity.
Why it matters: Without connectivity, "smart" chargers aren't smart. They can't bill residents, respond to grid signals, or be remotely maintained. We see installations fail constantly because nobody planned for connectivity. Trying to fix the issue post completion is a lot more expensive and disruptive.
The pushback: "WiFi infrastructure costs money ongoing!"
Yes if done badly. If however the infrastructure is adopted by a CPO then they will adopt the ongoing costs of comms provision into their commercial model.
Proposal 6: Align With OZEV Terminology
Current situation: Part S uses different language than OZEV guidance.
The problem: Gaps, misalignments and confusion in language between the grants, guidance and policies of OZEV and that of the Building Regulator.
Our proposal: Harmonise terminology and technical standards and infrastructure provider standards and installation methodologies will improve.
The pushback: None we can think of. This one is not controversial.
You might be reading this and thinking our proposals increase short-term costs. We don’t believe this to now be true.
Getting EV right creates a more attractive property to buy / rent. It also removes ongoing risk to developers and cuts off a long tail of rectification costs.
As EV adoption continues to surge the importance of getting EV infrastructure right grows too.
Put simply, when no one was charging the infrastructure didn’t need to work. Now they are so it does. Without this switch in approach the complaints and costs will continue to rise.
Happily we typically find significant savings when working with developers on their designs. They’re often over specified in key places leading to value engineering opportunities.
What happens next?
The statutory review must be completed no later that 15th June 2027.
That's a long wait if you're planning projects now.
Which brings us to Part 3: what developers can do today to avoid these problems, regardless of whether regulations change.
Disagree with our proposals? Let us know.
Next up: Part 3 details shares practical strategies you can use right now to deliver EV infrastructure that works.
