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The Scope Expands. Is Your Building Now on the List?

Series: Building Energy Efficiency (Amendment) Ordinance 2025

5 min read
Last updated: January 2026

If you own or manage a building in Hong Kong, the definition of "compliance" just got a lot broader. For years, the Buildings Energy Efficiency Ordinance (BEEO) has primarily been a concern for commercial landlords. If you ran a shopping mall or an office tower, you knew the drill. If you ran a school, a community centre, or a data centre, you were largely exempt from the mandatory audit cycle. With the Buildings Energy Efficiency (Amendment) Ordinance 2025, that exemption is over. As the first installment in our deep-dive series on the new mandate, we are breaking down the most immediate change: the dramatic expansion of the "Prescribed Buildings" list.

From 2 to 11: The New Categories

Previously, the mandatory energy audit requirements applied to just two broad categories. The new amendment expands this to 11 specific building types.

If your asset falls into one of the categories below, you will face mandatory statutory requirements starting September 20, 2026:

The Original Categories (Still Included):

  • 1
    Commercial buildings (offices).
  • 2
    Commercial portions of composite buildings (retail podiums in residential towers).

The 9 New Categories:

  • 3
    Educational buildings: Schools, universities, and training centres.
  • 4
    Community services buildings: Community halls and social welfare facilities.
  • 5
    Municipal services buildings: Markets, libraries, and sports complexes.
  • 6
    Medical and healthcare buildings: Hospitals and clinics.
  • 7
    Government buildings: Buildings housing government functions.
  • 8
    Airport passenger terminals.
  • 9
    Railway stations.
  • 10
    Data centres: Standalone facilities.
  • 11
    Industrial building data centres: Portions of industrial buildings occupied as data centres.

Why "Data Centres" is a Big Deal

The inclusion of data centres (items 10 and 11) is particularly significant. As high-intensity energy users, their inclusion signals the government’s intent to tackle the heavy hitters of carbon emissions. If you are operating a data centre within an industrial shell, you are no longer flying under the radar. You are now subject to the same audit scrutiny as a Grade-A office tower.

Why It Matters

The inclusion of data centres signals the government’s intent to tackle the heavy hitters of carbon emissions.

What You Need To Do Now

The new audit requirements for these categories kick in on September 20, 2026. While that might sound distant, the sheer volume of newly regulated buildings means there will be a rush for Registered Energy Assessors (REAs).

  • 1
    Check Your Portfolio: Detailed reviews of your asset list to confirm which buildings now fit these descriptions.
  • 2
    Prepare Your Data: Audits require historical data. Ensure your BMS and metering systems are actually logging the data an auditor will need.
  • 3
    Plan the Budget: If you manage a portfolio of schools or community clinics, you need to factor the cost of these 5-year cyclical audits into your operational budget immediately.
  • 4
    Find the right Partner: With the scope expanding to data-critical assets, the complexity of the audit increases. You need a solution that bridges the gap between your hardware and the regulator’s requirements. Platforms like Portfolio One can help streamline the data collection from your BMS and smart sensors, ensuring you have the accurate historical logs ready for your REA without the last-minute scramble.

Coming Up Next

Coming Up Next: Now that you know who is involved, you need to know how often you have to report. In our next post, we will cover Update #2: The New 5-Year Audit Cycle and why the days of the "once-a-decade" check-up are over.

Strategic Importance

The amendment ensures broader compliance to achieve greater energy efficiency and reduce emissions in Hong Kong.

Bottom line

With the Buildings Energy Efficiency (Amendment) Ordinance 2025, the exemption is over. Building owners and managers must prepare for expanded mandatory audits to ensure compliance.

Key Takeaways

  • The Buildings Energy Efficiency (Amendment) Ordinance 2025 expands the scope to 11 building types, including new categories like educational buildings and data centres.
  • Previously exempt buildings such as schools, community centres, and data centres are now subject to mandatory energy audits.
  • Data centres are highlighted as high-intensity energy users now under the same scrutiny as commercial buildings.
  • Mandatory statutory requirements for new categories start on September 20, 2026.
  • Preparation steps include checking portfolios, preparing data, planning budgets, and partnering with solutions like Portfolio One for streamlined compliance.
  • The amendment signals the government's intent to tackle major carbon emitters through broader energy efficiency measures.

Navigate Hong Kong's Energy Mandate

Schedule a platform demo to see how Portfolio One can help with the 2025 Buildings Energy Efficiency Ordinance

Peter Dampier

Peter Dampier

Vision Zero Connect's APAC Business Leader

Based in Hong Kong

Ready to turn the 2025 Energy Mandate into a competitive advantage? Contact Peter for a personalised Portfolio One demonstration.

peterdampier@visionzeroconnect.com