Legal & Compliance

MCS Installer Certification

Obtain MCS certification for battery installation. Required for SEG eligibility and consumer trust. Must use MCS-approved installer from the register.

Contacting MCS-certified installers in Lancashire. Annual audit required once certified.

MCS Annual Audit Compliance

Maintain compliance with MCS annual audit requirements. Covers installation quality, documentation, and consumer protection standards.

Not applicable until MCS certification obtained.

G99 Application Process (ENWL)

Submit G99 applications for battery systems exceeding 16A per phase to ENWL. G98 for systems up to 16A per phase. Current processing times 6-12 weeks for G99.

Need to establish G99 application process with ENWL. Required documents: system design, site plan, single line diagram.

G99 Design Submissions

Prepare and submit required design documentation for each G99 application including single line diagrams, system specifications, and protection settings.

Commissioning & Connection Agreements

Ensure all commissioning certificates and connection agreements are in place before system goes live.

BS 7671 Wiring Regulations (incl. Amendment 4, Chapter 57)

All battery storage installations must comply with BS 7671 (IET Wiring Regulations 18th Edition). Amendment 4 publishes 15 April 2026 and introduces new Chapter 57 dedicated to battery energy storage — covering thermal runaway protection, isolation requirements, location restrictions, ventilation, and documentation. This is the most significant regulatory change for domestic BESS in 2026.

Amendment 4 publishes 15 April 2026. Chapter 57 adds specific BESS requirements: thermal runaway containment, isolation switching, location restrictions (distance from habitable rooms), ventilation specs, and mandatory documentation. Review requirements immediately on publication. All installers must be trained on new chapter before Phase 1 installations.

PAS 63100:2024 & Battery Fire Safety Standards

PAS 63100:2024 is the MANDATORY UK domestic BESS fire safety standard (effective March 2024). All residential battery installations must comply. Supplementary standards include IEC 62619 and UL 9540A. PAS 63100 covers fire containment, thermal runaway mitigation, ventilation, and separation distances. This is the standard installers, local authorities, and fire services enforce.

PAS 63100:2024 is mandatory for all domestic BESS. Confirm compliance with Lancashire Fire & Rescue. Ensure all installations meet fire containment and ventilation requirements per PAS 63100. Now referenced in BS 7671 Amendment 4 Chapter 57.

Planning Permission Thresholds

Determine planning permission requirements for battery installations. Permitted development rights may apply for domestic battery storage under certain size thresholds.

Most domestic battery installations fall under permitted development. Confirm with Burnley/Pendle council for edge cases.

ESA Template — Solicitor Review

Energy Services Agreement template must be professionally drafted and reviewed by a solicitor. Must include all key clauses: 10-year term, monthly payment, access rights, insurance, termination, equipment removal, property sale provisions.

Letter of Authority (LoA) Clause

CRITICAL: The ESA must include a Letter of Authority granting RoseStack permission to: view homeowner energy accounts, switch tariffs on their behalf, communicate with energy suppliers, manage G99/SEG registrations, and be notified if the homeowner changes supplier. This enables portfolio-wide tariff optimisation.

LoA is the key enabler for the tariff optimisation strategy. Must be drafted by solicitor as part of ESA. Covers: account viewing, tariff switching, supplier communication, G99/SEG management, supplier change notification.

Supplier Change Notification Clause

ESA must require homeowner to notify RoseStack before switching energy supplier. RoseStack must approve that the new supplier supports the battery configuration.

Land Registry Charge Registration

Process for registering ESA charge against property at Land Registry. Ensures contract obligations survive property sale.

Need solicitor advice on whether charge registration is necessary or if a covenant is sufficient.

Consumer Credit Assessment

Determine whether the ESA structure triggers FCA consumer credit regulation. If the homeowner is paying monthly for an energy service, does this constitute credit?

Key legal question. If ESA is structured as a service agreement (not credit), FCA regulation may not apply. Need solicitor opinion.

Financial Promotion Rules

If raising investment: ensure all investor communications comply with FCA financial promotion rules. SEIS/EIS scheme communications must be properly structured.

SEIS/EIS Scheme Compliance

Ensure company structure and activities qualify for SEIS/EIS tax relief for investors. Advance assurance from HMRC recommended.

Agent 6 (Funding) tracks the investment side. Legal must ensure structural compliance.

Crowdfunding Regulations

If using crowdfunding for investment: comply with FCA crowdfunding regulations. Platform must be FCA-authorised or exempt.

Not applicable until crowdfunding is pursued as a funding route.

SEG Generator Registration

Register as Smart Export Guarantee generator with energy supplier. Requires MCS certification, correct meter configuration, and export payment arrangements.

Dependent on MCS certification being in place. Need to confirm meter requirements with supplier.

Export Meter Configuration

Ensure correct meter configuration for SEG export payments. Smart meter with export capability required.

Product Liability Insurance

Obtain product liability insurance covering battery system failures, defects, and resulting damage.

Professional Indemnity Insurance

Professional indemnity cover for energy services advice, system design, and tariff management activities.

Public Liability Insurance

Public liability insurance for installation activities and ongoing system maintenance visits.

Battery-Specific Insurance

Specialist insurance covering battery fire, theft, damage, and performance shortfall. May need specialist broker.

Investigate specialist energy storage insurance providers. Cover needed for fire, theft, damage, and potentially performance guarantee.

Homeowner Property Insurance Implications

Ensure homeowners are advised to notify their property insurer about battery installation. Document any impact on premiums.

Include requirement in ESA for homeowner to notify insurer. Track any reported premium changes.