No More Secrets—Mandatory Data Disclosure is Here
Series: Buildings Energy Efficiency (Amendment) Ordinance 2025 (Part 3 of 5)
For decades, building energy performance in Hong Kong was largely a private affair. You conducted your audit, you received your certificate, and perhaps you hung it in the management office. The detailed results, like how efficient your chillers really were, or how much energy you were bleeding during off-hours, remained safely filed away.
That era of privacy ends in September 2026.
The most controversial update in the Buildings Energy Efficiency (Amendment) Ordinance 2025 is not the 5-year cycle or the expanded scope. It is the Mandatory Data Disclosure.
What is Being Disclosed?
Under the new amendments, the "Energy Audit" is no longer just a compliance checkbox; it is a public report card.
Building owners will now be required to submit a specific "Data Disclosure Form" (Form EE-D) along with their audit. The Director of Electrical and Mechanical Services (EMSD) is then empowered to publish technical data from this form online for public inspection.
This goes far beyond the old "Energy Utilisation Index" (EUI) sticker. We are moving toward a transparent benchmarking system where specific technical metrics, such as the efficiency coefficients of your major services and your operational characteristics, could be visible to the market.
The "Brown Discount" Risk
Why does this matter? Because transparency changes value.
In markets like London and New York, public energy grades have already created a two-tier property market. Buildings with poor public ratings suffer from a "Brown Discount"; they lease for less, sell for less, and struggle to attract top-tier tenants who have their own Net Zero targets to hit.
If your building’s data is published and shows it performing in the bottom 25% of its category, that isn't just an engineering problem. It’s a leasing problem.
Accuracy is Your Best Defense
The danger of this new system isn't just having bad performance; it's having wrong performance data.
If you rely on manual data collection or sporadic meter readings, your REA (Registered Energy Assessor) might be forced to make conservative assumptions that make your building look worse than it is. Once that data is submitted and published on the EMSD website, correcting the public record is difficult and damaging to your reputation.
How Vision Zero Connect Protects Your Asset
You cannot afford to guess your numbers anymore.
Vision Zero Connect ensures that the data you hand to your auditor is defensible, accurate, and optimized. By pulling granular, real-time data directly from your BMS and sensors, our platform highlights anomalies before the auditor arrives.
- •Pre-Audit Vetting: See your EUI and efficiency trends months in advance.
- •Data Integrity: Eliminate manual entry errors that could skew your public rating.
- •The "Green Premium": Use our verified data to prove your efficiency, turning a compliance obligation into a marketing asset.
Coming Up Next
We’ve covered the what (Scope), the when (5-Year Cycle), and the risk (Disclosure). But how do you actually fix the issues the audit finds? In our next post, we’ll discuss Update #4: RCx—The Shift from "Audit" to "Action".
Navigate Hong Kong's Energy Mandate
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Peter Dampier
Asia Business Lead
Ready to turn mandatory data disclosure into a competitive advantage? Contact Peter for a personalised Portfolio One demonstration.