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SAP 10.3 vs HEM — Choosing Your FHS Compliance Route

Last updated: |Verified against GOV.UK
10 min read
By Guy Smith — DEA, SAP & SBEM Assessor

The Future Homes Standard offers two compliance routes during the transition period: SAP 10.3 (an updated version of the familiar SAP methodology) and HEM (the government's new half-hourly dynamic simulation). Both routes demonstrate compliance against the same FHS notional building, but the underlying calculations differ significantly. This page compares the two routes to help assessors, architects, and developers choose the right approach for their projects.

Side-by-Side Comparison

AspectSAP 10.3HEM
Calculation methodMonthly steady-stateHalf-hourly dynamic simulation (17,520 timesteps/year)
Software deliveryThird-party SAP software providersCentralised ECaaS API
Calculation speedNear-instantaneous5–10 minutes per calculation
Assessment time (typical house)~20 minutes data entry~1 hour 40 minutes data entry
Heat pump modellingFixed seasonal efficiency (COP)Dynamic COP at each timestep based on conditions
Solar PVAnnual generation estimateHalf-hourly generation + self-consumption modelling
Battery storageLimited modellingFull charge/discharge at each timestep
Thermal massSimplified parameterDynamic modelling at each timestep
Thermal bridgesAnnual uplift factorCalculated at each timestep
Carbon factorsUpdated for FHS (forward-looking)Forward-looking (2025–2029 projected)
Missing data handlingStandard SAP defaultsPunitive defaults — more severe than SAP
Assessor familiarityHigh — existing workflowLow — new methodology and platform
Long-term statusInterim — will eventually be withdrawnPrimary — government's preferred methodology

SAP 10.3 — The Familiar Route

SAP 10.3 is an updated version of SAP that incorporates the FHS notional dwelling specifications, revised carbon emission factors, and updated primary energy factors. It retains SAP's monthly calculation approach and is delivered through existing third-party software providers.

Advantages

  • Familiarity — assessors already know the SAP workflow, data entry process, and software
  • Speed — calculations are near-instantaneous, allowing rapid iteration on designs
  • Lower data requirements — SAP requires less detailed input data than HEM
  • Established software — existing SAP software is mature, with well-understood interfaces and workflows
  • No ECaaS dependency — assessments can run locally without relying on the ECaaS platform's availability

Limitations

  • Less accurate technology modelling — heat pumps, solar PV, and battery storage are modelled less precisely than in HEM
  • Monthly resolution — cannot capture within-day or within-month performance variations
  • No self-consumption modelling — cannot accurately model how much solar PV electricity is used on-site
  • Interim status — will eventually be withdrawn; investing heavily in SAP 10.3 workflows is a short-term strategy
  • Software inconsistency — different providers may produce marginally different results

HEM — The Future-Proof Route

HEM is the government's preferred long-term compliance methodology. It uses a half-hourly dynamic simulation based on BS EN ISO 52016-1:2017, delivered exclusively through the ECaaS platform.

Advantages

  • More accurate modelling — half-hourly timesteps capture real-world performance, particularly for heat pumps, solar PV, and thermal mass
  • Solar PV self-consumption — properly credits electricity used on-site, not just total generation
  • Battery storage — full charge/discharge modelling at each timestep
  • Dynamic heat pump COP — models efficiency based on actual source and sink temperatures at each timestep
  • Consistency — every assessment uses the identical calculation engine via ECaaS
  • Future-proof — HEM is the government's long-term methodology; early adoption builds capability
  • Design flexibility — more accurate modelling may reveal compliance margin that SAP misses, enabling design optimisation

Challenges

  • Longer assessment time — approximately 1 hour 40 minutes per house type versus 20 minutes for SAP (excluding geometry and U-value calculations)
  • More data required — detailed geometry, individual hot water outlets, specific product data, inverter specifications
  • Calculation time — 5–10 minutes per run versus near-instantaneous for SAP
  • Punitive defaults — missing data triggers default values that are far more severe than SAP defaults
  • ECaaS dependency — requires internet connectivity and platform availability
  • Learning curve — new methodology, new platform, new data requirements

Choosing the Right Route

The choice between SAP 10.3 and HEM depends on your circumstances. Here is practical guidance for different situations:

SituationRecommended RouteReasoning
Standard house types with clear compliance marginSAP 10.3Faster, familiar, no additional training needed
Complex designs with heat pumps + solar PV + batteryHEMMore accurate technology modelling may reveal compliance margin
Team not yet trained on HEMSAP 10.3 (short-term)Pragmatic while building HEM capability
Long-term capability buildingHEMStart building experience now; SAP 10.3 will be withdrawn
Marginal compliance designsTry bothOne route may pass where the other doesn't
High-volume production plotsSAP 10.3 initially, then HEMSAP 10.3 for speed; transition to HEM as teams upskill

Data Requirements Compared

HEM requires significantly more detailed input data than SAP 10.3. The additional data points include:

Data CategorySAP 10.3HEM
Building geometryFloor area, room count, orientationDetailed 3D geometry with zone-level resolution
Hot waterTotal demand from floor areaIndividual outlet specifications (taps, showers, baths)
PipeworkBasic distribution assumptionsDetailed lengths and insulation for each run
Heating productsProduct type and basic efficiencySpecific make/model with EN 14825 performance data
VentilationSystem type and basic performanceSpecific product data, duct lengths, terminal details
Solar PVPanel area, orientation, tiltPanel specifications + inverter make/model/efficiency
Site dataRegion and basic orientationAltitude, noise nuisance potential, detailed shading

The additional data requirements are the primary reason HEM assessments take longer. However, they also enable more accurate modelling — particularly for heating systems and renewable technologies. For detailed preparation guidance, see our Assessor Transition Guide.

Practical Tips for the Transition

  • Run parallel assessments early on — submit a few designs through both routes to understand how results compare for your typical house types
  • Invest in data collection — good data is essential for HEM. Establish processes to capture the additional data points from designers, manufacturers, and site teams
  • Build product data libraries — collate make/model data for your standard heating, ventilation, and PV specifications
  • Factor in calculation time — HEM takes 5–10 minutes per run; plan workflows that allow for this rather than expecting instant results
  • Engage with ECaaS — familiarise your team with the platform's API and workflow before it becomes mandatory
  • Use SAP 10.3 as a backstop — if an HEM assessment fails unexpectedly, SAP 10.3 provides an alternative route during dual running

Frequently Asked Questions

Should I use SAP 10.3 or HEM for FHS compliance?

It depends on your team and project. SAP 10.3 is pragmatic for teams not yet trained on HEM — it is familiar, faster, and uses existing software. HEM provides more accurate modelling and may reveal compliance margin or design flexibility. Both routes demonstrate compliance against the same notional building, so homes that pass either route meet the same standard.

Do SAP 10.3 and HEM give the same compliance result?

Not necessarily. Both routes compare against the same notional building, but the calculation methods differ. A dwelling that marginally passes on one route may marginally fail on the other, particularly for designs relying on heat pumps and solar PV where HEM's dynamic modelling is more accurate. Most well-designed FHS homes will pass on both routes.

When will SAP 10.3 stop being accepted for FHS compliance?

SAP 10.3 will be withdrawn a minimum of 24 months after HEM is approved. Since HEM arrives at least 3 months after FHS launch, SAP 10.3 will be available for a minimum of 27 months total from FHS launch. The exact end date depends on when HEM is approved.

Can I switch between SAP 10.3 and HEM during a project?

Each submission must use one route — you cannot mix them in a single assessment. However, you can use different routes for different plots on the same site. For example, SAP 10.3 for standard house types and HEM for complex designs where dynamic modelling helps. The choice is made at submission, not at project start.

Is it harder to pass compliance with HEM than SAP 10.3?

Not inherently, but results may differ. HEM models heat pumps and solar PV more favourably (dynamic COP, self-consumption), but also assesses fabric more rigorously (thermal bridges at every timestep). Well-designed FHS homes pass comfortably on both. Designs relying on generous SAP assumptions may find HEM less forgiving.

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