The TM44 Compliance File: What UK Businesses Must Keep Ready Before an Audit, Sale, Lease Review or Enforcement Check

Most TM44 problems do not begin with the air conditioning inspection.

They begin with missing records.

A business may have a working air conditioning system. The maintenance contractor may be visiting regularly. The units may be cooling the building properly. The facilities team may believe everything is under control.

Then something happens.

An auditor asks for compliance evidence.
A managing agent requests building records.
A buyer’s solicitor raises a due diligence question.
A landlord and tenant start reviewing lease obligations.
A finance director asks why a certificate is missing.
An enforcement letter arrives and asks for proof.

Suddenly, the issue is not only whether the air conditioning system works. The issue is whether the business can prove its TM44 compliance position clearly, quickly and properly.

That is where the TM44 compliance file becomes important.

A TM44 compliance file is not a legal phrase most businesses use every day. It is a practical way of describing the documents, records, reports, asset information and evidence a business should keep together so it can show that its air conditioning systems have been properly assessed, reported and managed.

For UK businesses with air conditioning systems over the relevant threshold, this is not just paperwork. It is risk control.

The UK government guidance states that air conditioning systems with an effective rated output of more than 12kW must be inspected by an energy assessor, with inspections no more than five years apart. The guidance also confirms that this can include multiple smaller units where their combined effective output exceeds 12kW.

That means a business does not need one large visible chiller to fall into TM44 territory. Several split systems, cassette units, VRF systems, comfort cooling units or tenant-controlled systems can bring a building into scope when looked at together.

The real commercial risk is simple: many businesses do not know where the evidence is.

They may have had a TM44 inspection years ago, but the report is sitting in an old inbox. The person who arranged it may have left. The asset list may not match the current system. New air conditioning units may have been installed since the last report. The landlord may assume the tenant is dealing with it. The tenant may assume the landlord is dealing with it. The managing agent may have partial records but no complete compliance file.

This article explains what a proper TM44 compliance file should contain, why it matters before an audit, sale, lease review or enforcement check, and how TM44.uk can help businesses put the right evidence in place.

For a wider overview of the inspection itself, see our guide to TM44 air conditioning inspections. If you already know you need a quote, you can go straight to Get a TM44 quote.

Why TM44 compliance is more than having a certificate

A common mistake is to think TM44 compliance is only about having a certificate.

The report is essential, but the report alone is not the whole compliance picture.

A TM44 inspection is designed to assess the efficiency of the air conditioning system, review how it is maintained, look at the adequacy of controls, identify faults or improvement opportunities, and provide recommendations. Government guidance states that the report should provide information about efficiency, faults, maintenance, controls, system sizing, operating performance and key recommendations.

That means the report depends heavily on the quality of the available information.

If the assessor receives a clear asset list, model details, maintenance records, floor plans, access information and previous reports, the process is smoother. If none of that is available, the inspection can still often proceed, but the business starts from a weaker position.

This is why a TM44 compliance file matters.

It gives the business a central evidence pack showing:

The system exists.
The capacity has been reviewed.
The inspection requirement has been considered.
The report has been completed where required.
The report has been lodged where applicable.
The renewal date is known.
The recommendations have been reviewed.
The responsible party is clear.

Without this, a company may be technically trying to comply but practically unable to prove it.

That is a dangerous place to be during an audit, sale, lease review or enforcement check.

What is a TM44 compliance file?

A TM44 compliance file is a structured folder of evidence relating to the air conditioning inspection status of a building or portfolio.

It can be digital, physical or both. Most businesses should now keep it digitally, ideally in a shared compliance folder accessible to the facilities manager, property manager, finance director, compliance lead and authorised external consultants.

For one small building, it may be a simple folder containing the TM44 report, asset list and renewal date.

For a larger building or multi-site portfolio, it should be more detailed. It may include multiple reports, plant schedules, site photographs, maintenance logs, responsibility notes, lease extracts, F-Gas records, renewal trackers and action logs.

The purpose is not to create admin for the sake of admin.

The purpose is to stop the business from being caught unprepared.

If someone asks, “Are we TM44 compliant?”, the answer should not depend on searching through five years of emails.

The answer should be available in one controlled file.

What documents should be inside a TM44 compliance file?

A strong TM44 compliance file should contain the following records.

1. The current TM44 report

This is the core document.

It should be the full air conditioning inspection report, not just a short email confirmation. The report should identify the building, system, assessor details, inspection date, findings and recommendations.

The file should also make it clear whether the report covers the whole building, only part of the building, one tenant area, one landlord area, one floor, one system group or a wider site.

This matters because many commercial buildings are complex. One report may cover landlord-controlled plant. Another may be required for tenant-installed equipment. In multi-let buildings, there may be separate responsibilities for communal systems, tenant systems and supplementary cooling.

If the current report is missing, expired or unclear, the business should review its position quickly. You can check our guide on what happens when a TM44 certificate has expired.

2. Lodgement or register evidence

A TM44 report should not just sit as an unofficial PDF. Where required, the report should be lodged correctly.

Your compliance file should include evidence that the report has been lodged or is traceable through the appropriate process. This may include a reference number, lodgement confirmation, assessor confirmation or register evidence.

This is especially important in a sale, lease transaction or enforcement scenario, where someone may ask not only whether an inspection was done, but whether there is formal evidence behind it.

For more on this area, see TM44 certificate and government lodgement and TM44 lodgement process UK.

3. Air conditioning asset list

An asset list is one of the most useful documents in the whole file.

It should show the air conditioning units on site, ideally including:

Indoor unit references
Outdoor unit references
Manufacturer
Model numbers
Serial numbers where available
Cooling capacity
Location
Area served
System grouping
Installation dates where known
Maintenance contractor details

A good asset list helps confirm whether the system crosses the 12kW threshold. This is important because the requirement can apply where multiple smaller units combine to exceed the effective rated output threshold.

Many businesses do not have a proper asset list. They may have units above ceilings, on roofs, in comms rooms, in tenant areas or in plant spaces that nobody has fully documented.

If you are in this position, read our guide: No asset list for a TM44 inspection?

4. Floor plans or marked-up location notes

Floor plans are not always essential, but they are extremely useful.

A marked plan showing where indoor and outdoor units are located can save time during inspection and reduce confusion. It also helps future managers understand what the TM44 report actually covered.

This is especially useful for:

Large offices
Schools and colleges
Hotels
Retail sites
Multi-floor commercial buildings
Mixed-use buildings
Warehouses with office areas
Sites with rooftop condensers
Multi-tenant buildings

If full plans are not available, simple marked-up notes can still help. A document saying “Unit AC-01 serves first-floor meeting room, outdoor unit located on rear flat roof” is better than no record at all.

5. Maintenance records

TM44 is not the same as routine maintenance, but maintenance records still matter.

The government guidance makes clear that inspection, maintenance and cleaning programmes are separate from the energy efficiency assessment, but they support the safe and effective operation of air conditioning systems.

Your TM44 compliance file should include recent maintenance visit sheets, service records, fault logs and contractor reports. These records help show that the system is not being ignored.

They also help the assessor understand whether filters, coils, controls and general system condition are being managed properly.

A business with no maintenance evidence can look disorganised, even if the system is physically working.

6. F-Gas records

TM44 and F-Gas are separate compliance areas, but they often sit close together operationally.

Air conditioning systems may contain refrigerants subject to F-Gas obligations. Maintenance contractors often hold F-Gas records, leak check evidence and refrigerant information.

Including F-Gas records in the compliance file gives a fuller picture of how the air conditioning system is being managed.

This is useful for facilities managers, ISO managers, environmental reporting and larger businesses with ESG responsibilities.

For related service support, see F-Gas leak testing and compliance checks.

7. Previous TM44 reports

Do not delete old reports.

Previous reports show compliance history. They help identify whether recommendations were repeated, whether systems changed, and whether inspection dates were maintained properly.

A previous report can also help compare system condition over time.

For example, if a report from five years ago recommended better controls, and the new report repeats the same recommendation, that may indicate the business has not acted on an energy-saving opportunity.

There is no general legal requirement to implement every TM44 recommendation, but acting on appropriate recommendations can help reduce operating costs and carbon emissions. Government guidance confirms that there is no legal requirement to act on recommendations, but doing so can contribute to efficient operation and lower costs.

8. Recommendation action log

This is where most businesses can improve.

After receiving a TM44 report, someone should review the recommendations and create a simple action log.

The action log should show:

Recommendation
Risk or benefit
Priority
Responsible person
Decision
Action taken
Date completed
Reason if not actioned

This does not mean every recommendation must be carried out immediately. Some may not be commercially practical. Some may be planned for a future refurbishment. Some may already be covered by maintenance.

But doing nothing and keeping no record is weak.

A recommendation action log shows that the business has reviewed the report properly, not just filed it away.

This is especially valuable for larger companies, ISO 14001 reviews, ESG reporting and board-level risk management.

See also: TM44 report recommendations explained.

9. Renewal date tracker

TM44 inspections are required at intervals no more than five years apart for qualifying systems.

That means your compliance file should include a renewal tracker.

This can be simple:

Inspection date
Report issue date
Lodgement/reference date
Expiry or renewal deadline
Reminder date
Person responsible
Next review date

The mistake many businesses make is treating TM44 as a one-off document.

It is not.

It is a recurring compliance requirement. If nobody tracks the renewal date, the report can expire quietly. The business may only notice when someone asks for evidence.

For larger businesses, renewal tracking should be part of a wider compliance calendar.

For support with ongoing sites, see TM44 portfolio management.

10. Responsibility note

This is one of the most important parts of the file.

Who is responsible for arranging the TM44 inspection?

The landlord?
The tenant?
The managing agent?
The occupier?
The facilities company?
The building owner?
A head office compliance team?

In some buildings, this is obvious. In others, it is not.

The person who controls the operation of the air conditioning system is usually central to the responsibility question. Government guidance refers to the person who controls the operation of the system, such as the building owner or manager, having statutory obligations and duties of care related to the operation and maintenance of air conditioning systems.

For complex buildings, the compliance file should include a short responsibility note explaining who controls which systems and who is arranging the inspection.

This is very useful before lease reviews and disputes.

See our detailed guide: TM44 responsibility guide for landlords, tenants and managing agents.

Why this file matters before an audit

Auditors do not like vague answers.

If an auditor asks for air conditioning compliance records, “I think the maintenance company has something” is not a strong response.

A proper TM44 compliance file allows the business to provide evidence quickly.

This is particularly important for companies with:

ISO 14001 systems
Environmental management obligations
Corporate ESG reporting
Internal compliance audits
Health and safety audit processes
Facilities management reviews
Public sector governance requirements
Multi-site compliance checks

TM44 is often overlooked because it sits between property compliance, energy efficiency and HVAC maintenance. It is not always owned by one department.

Finance may think facilities deals with it.
Facilities may think the landlord deals with it.
The landlord may think the tenant deals with it.
The contractor may only deal with maintenance, not TM44.
The ISO manager may not know whether the report exists.

A compliance file removes that confusion.

For businesses linking TM44 to environmental systems, see TM44 and ISO 14001.

Why this file matters before a property sale

When a commercial property is being sold, compliance evidence becomes part of the due diligence process.

Buyers and their advisers may ask questions about:

EPC position
MEES risk
Air conditioning systems
Plant condition
Service records
Statutory inspections
Energy efficiency liabilities
Tenant-installed systems
Maintenance obligations

A missing TM44 report can create friction.

It may not always stop a sale, but it can raise questions. It can suggest poor building management. It can delay replies to enquiries. It can make the seller look unprepared.

A clean TM44 compliance file gives the seller a stronger position.

It shows that the air conditioning systems have been reviewed, the report is available, the renewal date is known, and the supporting records are organised.

This matters even more for buildings with large cooling systems, multiple tenants, complex plant or recent refurbishments.

For more detail, see TM44 inspection before selling or leasing commercial property and TM44 commercial property deal risk.

Why this file matters before a lease review

Lease situations can become complicated.

A tenant may install supplementary cooling.
A landlord may provide base-build air conditioning.
A managing agent may control communal systems.
A tenant may maintain their own split units.
A lease may refer to statutory compliance generally without naming TM44 specifically.

When lease obligations are reviewed, the parties may need to understand who controls the air conditioning system and who is responsible for compliance.

This is where the TM44 compliance file becomes practical evidence.

It can show which systems exist, who uses them, who maintains them, when they were inspected and whether the report covers the relevant areas.

Without that file, the discussion can become messy.

A tenant might say, “That is the landlord’s system.”
A landlord might say, “Those units were installed by the tenant.”
A managing agent might say, “We only manage the common parts.”

The compliance file helps turn assumptions into evidence.

Why this file matters before an enforcement check

TM44 enforcement has historically been overlooked by many businesses, but that does not mean it should be ignored.

The safer commercial position is to assume that enforcement, audits and document requests will become more serious over time. TM44 sits inside the wider building energy efficiency and compliance environment, and the direction of travel is towards better evidence, clearer reporting and stronger accountability.

If a business receives a warning letter or request for evidence, the worst moment to start building a compliance file is after the letter arrives.

At that point, the business may be rushing to find old reports, identify system capacity, contact contractors, review access and arrange inspection.

A prepared business can respond far more calmly.

It can show the current report, lodgement evidence, asset list and renewal tracker. If the inspection is due, it can show that action is already in progress.

If you receive a letter or are worried about your position, see TM44 enforcement letter: what to do and TM44 enforcement fines and penalties UK.

Case study example 1: The office that thought maintenance was enough

A medium-sized office building has several air conditioning systems serving open-plan workspace, meeting rooms and a small comms room.

The business has a maintenance contractor visiting twice a year. Filters are cleaned. Faults are repaired. The office manager assumes the building is compliant because the units are serviced.

During an internal compliance review, the finance director asks for the TM44 report.

Nobody can find one.

The maintenance contractor confirms they service the system but have not carried out a TM44 air conditioning energy assessment. The office manager checks the equipment and realises the combined cooling capacity is above the threshold.

The business now needs to arrange an inspection quickly.

What went wrong?

The business confused routine maintenance with TM44 compliance.

A proper compliance file would have separated service records from statutory inspection evidence. It would have shown whether the report existed, when it was due, and who was responsible for arranging it.

This is a common issue.

Maintenance is important, but it is not a substitute for a TM44 inspection where the system qualifies.

For more on this distinction, see PPM contract vs TM44 compliance.

Case study example 2: The tenant-installed units nobody documented

A tenant leases a floor in a multi-let commercial building.

The landlord provides some cooling through the base-build system, but over time the tenant adds additional split units for a boardroom, server area and high-density desk zone.

The units are installed at different times by different contractors. Some paperwork is held by the tenant. Some is with the installer. The managing agent knows extra cooling was added but has no complete asset list.

During a lease review, a question is raised about air conditioning compliance.

The landlord says the tenant controls the extra units.
The tenant says the landlord manages the building.
The managing agent asks for equipment details.
Nobody has a complete file.

The issue is not only technical. It becomes contractual and administrative.

A proper TM44 compliance file would include tenant-installed units, locations, model details, capacity, responsibility notes and inspection status. It would help clarify whether those systems needed to be included in the TM44 assessment.

This type of situation is common in offices, retail spaces, clinics, education buildings and mixed-use commercial properties.

Case study example 3: The sale delayed by missing air conditioning evidence

A commercial property owner prepares to sell a small office building.

The EPC is available. Fire alarm records are available. Asbestos information is available. The buyer’s solicitor asks for details of statutory inspections and air conditioning records.

The seller believes a TM44 inspection was done, but the report cannot be located. The previous facilities manager left two years ago. The maintenance contractor has service sheets but no TM44 report. A new split system was installed after the supposed inspection.

The buyer asks whether the report covers the current system.

The seller cannot answer clearly.

The transaction does not collapse, but the replies are delayed. The buyer’s team raises additional questions about plant condition and compliance management.

A simple TM44 compliance file could have avoided this.

It would have held the report, renewal date, asset list, installation updates and maintenance records. It would have shown whether a new inspection was required before sale.

For sellers and buyers, this is not just compliance. It is transaction readiness.

How to build a TM44 compliance file in practice

You do not need to overcomplicate it.

Start with one folder per building.

Name it clearly:

TM44 Compliance File – Building Name – Address

Inside that folder, create subfolders:

01 Current TM44 Report
02 Lodgement Evidence
03 Asset List
04 Maintenance Records
05 F-Gas Records
06 Floor Plans and Photos
07 Previous Reports
08 Recommendation Action Log
09 Lease and Responsibility Notes
10 Renewal Tracker

Then assign ownership.

Someone must be responsible for keeping the file updated. This could be the facilities manager, office manager, property manager, compliance manager or managing agent.

The file should be reviewed:

After any new AC installation
After any major refurbishment
After any tenant fit-out
After any plant replacement
Before lease events
Before property sale
Before internal or external audits
At least annually as part of compliance review

A good compliance file should survive staff changes. If the office manager leaves, the next person should not have to rebuild everything from scratch.

How TM44.uk can help

TM44.uk helps businesses across the UK arrange TM44 air conditioning inspections, understand what information is needed, and improve their compliance evidence.

We can help if:

You are not sure whether your building needs a TM44 inspection
You do not have an air conditioning asset list
Your previous report has expired
You cannot find your old report
You need a fast quote
You have multiple sites
You need help before an audit, sale or lease review
You received a compliance or enforcement query
You need a clear TM44 report and government lodgement support

Our process is designed to reduce back-and-forth and help businesses provide the right information from the start.

Before quoting, we usually need key information such as building address, number of air conditioning units, system type, access details, previous reports if available, and any asset list or maintenance records. For a full breakdown, see what we need from you for a TM44 quote.

To request support, use our TM44 quote form.

The commercial value of being organised

A TM44 compliance file is not just about avoiding a penalty.

It protects the business from wasted time, internal confusion and weak evidence.

For finance directors, it supports risk control.
For facilities managers, it gives operational clarity.
For ISO managers, it supports audit readiness.
For landlords, it supports property management.
For tenants, it helps clarify obligations.
For managing agents, it improves portfolio control.
For buyers and sellers, it supports due diligence.

In a world where commercial buildings are under more pressure to show energy performance, compliance evidence and responsible management, a missing TM44 report can make a business look careless.

A complete file does the opposite.

It shows that the building is being managed properly.

Final checklist: what your TM44 compliance file should include

Before you close this article, check whether your business has the following:

Current TM44 report
Lodgement or register evidence
Air conditioning asset list
Indoor and outdoor unit details
Cooling capacity information
Floor plans or location notes
Maintenance records
F-Gas records
Previous TM44 reports
Recommendation action log
Renewal date tracker
Responsibility note
Lease or landlord and tenant evidence where relevant
Contractor details
Site access notes
Photos of key plant areas where useful

If you cannot find these records, your business may still be able to fix the position. But the sooner you act, the easier it is.

Conclusion

The strongest businesses do not wait for an audit, sale, lease review or enforcement check before looking for their TM44 evidence.

They keep the file ready.

A TM44 compliance file gives you control. It helps you understand what systems you have, whether they fall into scope, when they were inspected, what recommendations were made and when the next inspection is due.

It also helps avoid the common mistake of assuming that air conditioning maintenance is the same as TM44 compliance.

If your building has air conditioning systems over the relevant threshold, or if you are unsure whether the combined capacity triggers the requirement, TM44.uk can help you review the position and arrange the right inspection.

Start with the file.
Find the evidence.
Check the capacity.
Confirm the report.
Track the renewal.

And if anything is missing, deal with it before someone else asks for it.

Request a quote here: Get a TM44 inspection quote