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Accountants for air conditioning and ventilation installers

Installing air-conditioning and ventilation systems is named in the statute, so it is inside CIS. Manufacturing the components and delivering them is expressly excluded — which is the line a business that does both crosses continuously.

UK trades and construction
In scope
InstallationOf air-conditioning and ventilation systems
Excluded
ManufactureOf components, and their delivery to site
Not on the list
Comfort coolingNot a qualifying energy-saving material

Air conditioning · CIS scope

Installing is in, manufacturing is out

Section 74(2) expressly covers the installation in any building or structure of systems of heating, lighting, air-conditioning, ventilation, power supply, drainage, sanitation, water supply and fire protection. So air conditioning and ventilation installation is a construction operation and inside CIS.

Section 74(3) then excludes the manufacture of components for those same systems and their delivery to site. For a business that fabricates ductwork or assembles units and also installs them, that boundary is crossed continuously — and which side a payment falls on is decided by what the contract is for.

Where a single contract covers both, the whole payment is generally within the scheme, but the cost of manufacture or prefabrication comes out of the payment subject to deduction. On a ductwork business that is often the largest exclusion available, and it is regularly left unclaimed because the invoice shows one figure.

What air conditioning is not

It is not on the qualifying energy-saving materials list. Air source heat pumps are, and so are ground and water source heat pumps, micro combined heat and power units, solar, insulation and heating controls. So a business doing both heat pumps and comfort cooling has qualifying and non-qualifying work running side by side — zero-rated until 31 March 2027 and 5% after it on one, standard rated throughout on the other.

And the two things that are true whatever the trade

The deduction is charged on the payment less materials you directly incurred, consumable stores, fuel other than fuel for travelling, plant hire, the cost of manufacture or prefabrication, and the VAT you charged. Travel and subsistence stay in. And where the contractor buys the materials and recharges them, you have not directly incurred them, so no reduction is due at all.

If the deduction is costing you cash, gross payment status is the fix rather than a workaround — the turnover test is £30,000 of relevant payments net of VAT and materials for a sole trader, and the compliance test, which since 6 April 2024 includes VAT, is the part that needs preparing for.

Quick answers

Frequently asked

Is an air source heat pump treated differently from air conditioning?

For VAT, yes, substantially. Air source heat pumps are qualifying energy-saving materials, so installing one in residential accommodation is zero-rated until 31 March 2027 and 5% from 1 April 2027. Comfort cooling is not on the list and is standard rated. Both are inside CIS as installation of an air-conditioning or ventilation system — so the CIS answer is the same and the VAT answer is not. In practice that means a single job installing a heat pump and a comfort cooling unit carries one CIS treatment and two VAT rates, and the invoice has to show which is which.

Does fabricating ductwork reduce my deduction?

Yes, where the payment is within the scheme. The cost of manufacture or prefabrication is expressly excluded from the payment subject to deduction, alongside materials you directly incurred, consumable stores, fuel other than fuel for travelling, plant hire and the VAT you charged. It has to be identified on the invoice to do anything. An invoice reading “supply and install ductwork” as one figure gives the contractor nothing to exclude, and the contractor is the party HMRC expects to justify the materials figure — so it will estimate rather than take your word for it.

Is F-Gas work inside CIS?

The scheme asks whether the payment is for a construction operation, not whether the work is regulated. Installing, altering or repairing an air-conditioning system in a building is a construction operation regardless of the certification the work requires. Servicing an existing system is repair and maintenance of the building's installed systems, which sits inside the same wording. F-Gas certification is a competence and environmental requirement that runs alongside the tax treatment rather than deciding it. Certification decides who may lawfully do the work; the scheme decides how the payment is taxed, and neither answers the other's question.

What about work in a commercial building?

CIS does not distinguish by building type — it asks whether the operation is construction. Installing air conditioning in an office is as much a construction operation as in a house. What changes with the building is the VAT: the zero and reduced rates concern dwellings, relevant residential and relevant charitable use, so commercial work is generally standard rated and therefore inside the reverse charge where the other conditions hold. The exception on a commercial building is a relevant residential or relevant charitable use, which can bring the zero or reduced rate back into play — so the question is what the building is used for, not whether it is an office.

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