What Does F-Gas Compliance Actually Require?

A plain-English guide to the F-Gas duties on commercial air conditioning — and who’s responsible for them.

F-Gas compliance means having your commercial air conditioning and refrigeration leak-checked at set intervals, keeping proper records, using F-Gas certified engineers for the work, and repairing leaks promptly — with the duty to arrange and evidence all of that sitting on the operator of the equipment (the business or building owner), even where the work itself is outsourced. Responsibility for actually stopping leaks is shared between the operator and the technicians who work on the system. The exact leak-check frequency depends on how much refrigerant a system holds. The sections below explain what’s actually required and how to stay on the right side of it.

For most commercial buildings with air conditioning, these rules apply — and the duties are easy to lose track of until an inspection, a sale or a lease event brings them into focus.

What is F-Gas, and why is it regulated?

F-gases (fluorinated greenhouse gases) are the refrigerants in most air conditioning, heat-pump and refrigeration systems — commonly HFCs such as R-410A and R-32. They’re very effective refrigerants, but they’re also potent greenhouse gases if they escape, which is why their use is tightly regulated and why the rules are steadily pushing the industry toward lower-impact refrigerants over time.

Who is responsible? (The “operator”)

Plenty of businesses assume their maintenance contractor carries the whole legal duty. It’s more nuanced than that. The compliance duties — arranging leak checks on schedule, keeping the records, and making sure whoever works on the system is certified — sit with the operator, defined as whoever has actual control over the technical functioning of the equipment. For most commercial premises that’s the business occupying the building, the landlord, or the facilities manager, and that responsibility stays with the operator even if the maintenance is outsourced — hiring a contractor doesn’t transfer it, it just means a competent contractor helps you meet it. Responsibility for actually stopping leaks, though, is shared: both the operator and the technicians who install, maintain or decommission the equipment carry obligations there. So it isn’t simply “the operator’s problem and not the contractor’s” — the operator owns the compliance framework, while preventing and fixing leaks is a joint duty.

Leak checks — and how often

Systems have to be checked for leaks at intervals that scale with the amount of refrigerant they hold — measured not in kilograms but in CO2 equivalent (CO2e), which combines the quantity of refrigerant with how powerful a greenhouse gas it is. (CO2e = refrigerant charge × its global warming potential.) In broad terms, under the GB rules:

5 tonnes CO2e or more — checked at least every 12 months.
50 tonnes CO2e or more — at least every 6 months.
500 tonnes CO2e or more — at least every 3 months, and a fixed automatic leak-detection system is required.

Where an automatic leak-detection system is fitted, the interval between manual checks can be doubled. That detection system isn’t fit-and-forget, though — it has to be checked itself: every 6 years on electrical switchgear, and every year on all other equipment. Smaller systems below the 5-tonne threshold — and hermetically sealed systems below 10 tonnes CO2e — don’t carry a mandatory leak-check interval. Because the threshold depends on the refrigerant type as well as the amount, two systems of the same physical size can fall into different tiers, which is why it’s worth having the actual figures worked out rather than assumed.

Record-keeping

For any system that requires leak checks, the operator must keep records — and keep them for at least five years, available to officials on request. The records cover things like the type and quantity of refrigerant in the system, any added or recovered during servicing, the leak checks carried out, and details of the certified company that did the work. In practice we keep this register maintained for the systems we look after — signed reports after every visit — and we provide you with a copy and ongoing access to it. As the operator, you’re the one who needs to keep those records available, so having your own copy on site means you’re covered if an inspection, sale or lease event brings them into focus. “My engineer has them somewhere” is not a position you want to be in.

Using certified engineers

Installation, servicing, leak checking, repair, refrigerant recovery and decommissioning all have to be carried out by properly F-Gas certified people — and there are two separate parts to that. Each individual engineer must hold a personal F-Gas qualification, and the company doing the work must hold its own F-Gas company certificate (from REFCOM or an equivalent body) to work on another business’s equipment. Certified engineers without a company certificate isn’t enough on its own. It’s part of the operator’s duty to check that whoever works on the system holds both.

Repairing leaks and end-of-life

If a leak is found, it must be repaired without undue delay, and the system re-checked within a month to confirm the repair worked. At the end of a system’s life, the refrigerant must be properly recovered by certified personnel rather than vented — releasing F-gas to the atmosphere is itself an offence.

The direction of travel

Beyond the standing duties, the wider rules are tightening, not loosening — high-global-warming refrigerants are being phased down, some are already restricted for servicing older systems, and prices for those gases are rising as supply is squeezed. For a business running older plant on a high-GWP refrigerant, that’s worth factoring into any replace-or-repair decision: the cheapest refrigerant to run today may be the harder one to source and service tomorrow.

What this means for your building

In practical terms, F-Gas compliance comes down to knowing what refrigerant your systems hold, getting them checked on the right schedule, keeping the records straight, and using certified engineers — and the simplest way to cover all of that is to fold it into a planned maintenance arrangement rather than treat it as a separate chore. Inherit a building and the systems often come with no usable records at all; the first job is then to establish what’s actually installed and get the paperwork honest before an inspection does it for you.

React Cooling holds F-Gas company certification and our engineers are individually F-Gas qualified — both halves of what the law requires — so on the systems we maintain across the Midlands the compliance runs as part of the servicing: testing on schedule, records kept properly, and leaks dealt with while they’re small. If you’re not sure where a building stands, we can survey what’s installed and tell you straight.

Book a Site Survey · Call 0330 912 8325

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