Many houses have an air-source heat pump, but it is rarely recorded in the Building Register. It usually comes up when the house is sold, mortgaged or insured and the bank or buyer looks at the register data. The good news: an air-source heat pump can be entered in the register after the fact, and it is one of the simplest legalisation jobs.
Does an air-source heat pump need a building notice?
Under § 4 (3) 3 of the Building Code, reconstruction also includes installing or altering a technical system in a building that changes the building's appearance or other properties. The outdoor unit of an air-source heat pump sits on the facade, on the roof or next to the house and changes the house's appearance and heating system – which is why local authorities treat it as reconstruction of a technical system.
Annex 1 to the Code says whether you need a building notice, a building design or both. It depends on the type and size of the building.
Private house and apartment building: what you need
| Building | Before installation | After installation |
|---|---|---|
| Private house (EHR codes 11100 and 11210), footprint area 20–60 m² and up to 5 m high | Building notice | Notice of use (kasutusteatis) |
| Private house with a footprint area over 60 m² or height over 5 m (most houses) | Building notice and building design | Notice of use (kasutusteatis) |
| Other residential building (e.g. apartment building) and non-residential building, over 20 m² | Building notice and building design | Notice of use (with a building design for a larger building) |
| Building with a footprint area of up to 20 m² and up to 5 m high | Not needed | Not needed |
Source: Annexes 1 and 2 to the Building Code, column "Reconstruction of the technical system only". In justified cases the local authority may require a building notice even where the table does not (EhS § 35 (4)).
What the building design contains
An air-source heat pump design is simple. According to local authority guidelines (e.g. Tartu city, Rae rural municipality), you need:
- Title page – project name, address, author, date.
- Explanatory note – where the pump is installed, whether the outdoor unit is screened and with what, the unit's data and noise: local authorities require the outdoor unit's noise to stay at up to 50 dB by day and up to 40 dB at night.
- Site plan (1:500 or 1:1000) – the building, the location of the outdoor unit and, if needed, distances to neighbouring buildings and the plot boundary.
- Drawing – if needed, a facade view or plan showing where the outdoor unit is located.
- The documents are digitally signed and attached to the building notice in the Building Register (ehr.ee).
Who can prepare the design
Under § 24 (2) 2 of the Building Code, the qualification of a competent person is required when preparing the building design for a building that requires a building permit. Installing an air-source heat pump does not require a building permit – a building notice is enough. In practice the design is often prepared by the pump installer or a designer; the local authority assesses whether the design is sufficient.
After installation: notice of use
Once the pump is installed, a notice of use is submitted in the Building Register. According to local authority guidelines, it is accompanied by:
- installation certificate or construction diary (signed by the installer);
- the unit's installation and user manual and technical data;
- electrical installation declaration of conformity with a visual inspection report (main fuse up to 35 A) or the findings of a pre-commissioning electrical audit;
- hidden works certificates, if such work was done.
Legalising after the fact
If the pump has been on the wall for years, the same work is done after the fact: a building notice with the design and a notice of use with the documents you have. If the installer can no longer find the documents, proof for the electrics has to be obtained another way, for example with an electrical installation audit.
If the pump was installed before 1 July 2015, under § 28 of the Building Code and Planning Act Implementation Act the building's safety is assessed against the requirements in force at the time of construction.
The best time to legalise is before selling the house or applying for a loan – then the deal doesn't have to wait for the paperwork.
Summary
| Step | What to do |
|---|---|
| 1. Check | Check the Building Register to see whether the pump or the heating system change is recorded |
| 2. Design | Pump location on the existing design or drawing + explanatory note with noise data |
| 3. Building notice | Submit in the Building Register with the design (no state fee) |
| 4. Notice of use | Installation certificate, technical data, electrical declaration of conformity |
| Apartment building | Plus the consent of the co-owners or the apartment association |
Frequently asked questions
Do you need a building notice to install an air-source heat pump?
Yes, in most cases. Under the Building Code, installing a technical system that changes the building's appearance is reconstruction. For a private house, Annex 1 requires a building notice (with a building design for a house over 60 m² or over 5 m high) and, after installation, a notice of use.
What does an air-source heat pump design contain?
A title page, an explanatory note (location, screening, unit data and noise – up to 50 dB by day, up to 40 dB at night), a site plan showing the outdoor unit's location and, if needed, a facade view. The simplest way is to mark the pump's location on the existing design.
Can an air-source heat pump be legalised after the fact?
Yes. You submit a building notice with the design and a notice of use with the documents you have (installation certificate, technical data, electrical declaration of conformity). If there are no documents from the installer, an electrical audit may be needed.
Do you need the apartment association's permission in an apartment building?
Yes. The outdoor unit goes on the building's shared facade or roof, so you need the consent of the co-owners or the apartment association. In some areas the local authority also requires the outdoor unit to be screened.
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