You are now required to record photographic evidence to form part of the as built construction evidence. These need to be provided to the energy assessor and building control body. Approved Document Part L 2021 Appendix B details the requirements of the evidence that needs to be collated.

Photographic evidence helps ensure the as built construction reflects that of the design stage SAP calculation.

It's now a requirement for an audit of the as built construction photos to be conducted by the energy assessor to prior to the production of the EPC and BREL output compliance report for each dwelling. Both of which are required by the Building Control Body for final completion sign off.

Below are details of what you need to do to keep on top of this requirement and help your project run smoothly.

What you need to Photograph

Paragraph ADF Part L Section B7:

Photographs should be taken of typical details as listed below and should be unique to each property. One photograph per detail should be recorded. Additional images, such as a closeup detail, should be provided only when necessary (see below). Photographs should be taken at appropriate construction stages for each detail when completed, but prior to closing-up works.


1. Foundations/substructure and ground floor, to show thermal continuity and quality of insulation in the following places.

     a. At ground floor perimeter edge insulation.

     b. At external door threshold.

     c. Below damp-proof course on external walls.


2. External walls: for each main wall type, to show thermal continuity and quality of insulation for the following.

     a. Ground floor to wall junction.

     b. Structural penetrating elements.


NOTE: For blown fill, photos should show clean cavities and clean brick ties with very limited mortar droppings.


3. Roof: for each main roof type, to show thermal continuity and quality of insulation at the following.

     a. Joist/rafter level.

     b. Eaves and gable edges.


4. Openings: for each opening type (one image per wall or roof type is sufficient), to show thermal continuity and quality of insulation with photographs of the following.

     a. Window positioning in relation to cavity closer or insulation line.

     b. External doorset positioning in relation to cavity closer or insulation line


5. Airtightness: additional photographs for all details 1–4 to show airtightness details (only if not included or visible in continuity of insulation image).


6. Building services: for all plant associated with space heating, hot water, ventilation and low or zero carbon technology equipment within or on the building, show the following.

     a. Plant/equipment identification label(s), including make/model and serial number.

     b. Primary pipework continuity of insulation.

     c. Mechanical ventilation ductwork continuity of insulation (for duct sections outside the thermal envelope).

How you should keep a record of the Photos

Paragraph ADF Part L Section B7:

Photographs should be digital and of sufficient quality and high enough resolution to allow a qualitative audit of the subject detail. Close-up photographs may be needed where a long shot image provides insufficient detail. More than one image of each detail may be needed. Geolocation should be enabled to confirm the location, date and time of each image. Each image file name should include a plot number and detail reference according to the numbers used in paragraph B7. For example, Plot 1 eaves detail would be P1/3b.


We recommend that you provide your site management a schedule and checklist to ensure that the evidence is collected at the correct time and prior to works proceeding to ensure photos are recorded correctly. Failure to do this may result in needing to either deconstruct work or do invasive investigates to show compliance. This could also result in non-compliance with the BREL report. This report is required by Building Control as part of their final sign off.

Be Prepared

Integrate the collection of photos into the site programme and part of your quality management system. Set up a system for recoding photos and inspections during the project.


The digital storage of photos is important. Ensure they are safely stored and correctly labelled. We would recommend all photos are backed up to a cloud or 2nd storage device regularly.


You will also need to make sure that the camera device can embed geo-location, time and date directly into the photo. This is to assist energy assessor and building control body identify the photos relevance to the project. All photos will need to be stored and labelled so that the filename correctly identifies the plot and construction stage/detail. Failure to do so will result in additional charges from your energy assessor for collating, processing, and preparing the evidence for Building Control submission and EPC production.


We would also recommend practicing ensuring that your systems are set up and working correctly.


Click the link below to download A Guide to Photographic Evidence for New Homes published by our accreditation company Elmhurst Energy. This can assist you in setting up your report templates and provide more detail on the Photo Evidence Process.

TB157_OCDEA__Technical_Bulletin_A_Guide_to_Photographic_Evidence_for_New_Homes.pdf