M&M Compliance Training
On 15 April 2026 every NHS Trust in England received a formal notification that will reshape how Authorising Engineers (AEs) are appointed across the estate. From that date, all practising AEs who advise on or work with NHS infrastructure in England must obtain IHEEM Registered Authorising Engineer certification and appear on the central IHEEM AE Register. A three-year transition period applies, after which only registered AEs will be eligible for appointment to NHS infrastructure work.
For estates leaders and the AEs who work alongside them, this is the most significant change to how AE competence is recognised in a generation. It is also a change that needs operational answers, not just acknowledgement. This article sets out what the register is, why it has been introduced, who it applies to, what it costs, and the three decisions every NHS Trust should be making in the next few months.
Following the transition period, only registered AEs will be eligible for appointment to work on NHS infrstructure." - NHS England
The Institute of Healthcare Engineering and Estate Management (IHEEM) and NHS England have jointly created a central register and certification process for Authorising Engineers operating across NHS infrastructure in England. The intent is simple: a single, transparent record of competent AEs that NHS Trusts can rely on when making appointments. Registered AEs commit to the IHEEM Code of Professional Conduct and to the specific Code and Rules of Conduct and Disciplinary Regulations for Registered Authorising Engineers.
The requirement is being formalised through the next release of HTM 00 — Policies and principles of healthcare engineering, which is currently being finalised. In other words, the register will not sit on the side of the regulatory landscape; it will be woven into the framework Trusts already use to appoint AEs across every HTM discipline.
Who the register applies to
The register applies to any AE who advises or works on NHS infrastructure in England. That includes consultancy and contracted AE roles across HTM 02-01 (medical gas pipeline systems), HTM 03-01 (specialised ventilation), HTM 04-01 (safe water systems, including legionella control), HTM 06-02 (low voltage electrical), and the other healthcare-specific HTM disciplines. Private healthcare and life-sciences operators that adopt NHS HTM standards as a baseline should expect their supply chains to follow suit, even where the strict regulatory requirement does not bite.
Who the register applies to
HTM 00 sets the overarching policies and principles of healthcare engineering. Folding the IHEEM register into HTM 00 means that an AE appointment letter will need to reference the AE’s current registered status — and that procurement teams will need to verify it. Trusts that already audit appointment letters annually will need to add a single, simple check; trusts that do not, now have a strong reason to start.
NHS England has deliberately allowed three years to ensure existing AEs can demonstrate competence without duplicating effort. The certification process recognises prior learning and long service. That is the good news. The less comfortable news is that three years passes quickly, and the AE you appointed in 2024 may already be due for revalidation by the time the transition ends. We recommend three actions now.
1. Aduit exisiting AE appointment by HTM discipline.
2. Map a competence-evidence plan with each practising AE.
3. Budget for IHEEM application and annual fees across the appointment portfolio.
Action 1: Audit your AE appointments
Pull every current AE appointment letter into a single schedule by HTM discipline. Note the appointed individual, the contractual end date, the year of their most recent revalidation, and the status of their IHEEM membership. This produces the baseline you will measure progress against for the next three years.
Action 2: Plan competence evidence
The IHEEM certification process recognises previous learning and experience. Practising AEs should not have to redo a decade of work, but they will need to evidence it. Help your AEs collate continuing professional development records, project examples, and discipline-specific qualifications now, rather than in the closing months of the transition.
Action 3: Budget for fees
The IHEEM AE application fee is £118, with an annual fee of £255 (a 5% discount applies if paid by annual direct debit). The numbers are modest individually, but Trusts with multiple AE appointments across HTM disciplines should reflect them in 2026/27 estates budgets and procurement schedules so they do not become a year-end surprise.
Registered AEs commit to the IHEEM Code of Professional Conduct as well as the specific Rules of Conduct and Disciplinary Regulations for Registered Authorising Engineers. Eligibility centres on demonstrable competence and experience: a minimum of ten years’ recent relevant experience in the AE’s primary discipline, plus at least two related areas. Recognition of prior learning means experienced AEs are not asked to duplicate evidence of expertise they already hold.
At-a-glance: IHEEM AE Register
Effective notice
15 April 2026 to all NHS Trusts in England
Transition period
3 years from announcement
Application fee
£118
Annual fee
£255 (5% discount with annual direct debit)
Minimum experience
10 years in primary discipline = 2 related related areas
Reflected in
Forthcoming release of HTM 00
The IHEEM register is structured around disciplines, and almost every Trust holds AE appointments across several. The most exposed areas are usually:
Safe water (HTM 04-01)
HTM 04-01 governs safe water in healthcare premises, including legionella control. Most Trusts hold an AE (Water) appointment supported by a Water Safety Group and a Responsible Person. The AE’s registered status will need to be visible on the appointment letter from now on.
Medical gas pipeline systems (HTM 02-01)
HTM 02-01 covers medical gas pipeline systems. AE (Medical Gases) appointments often sit alongside Quality Controller and Authorised Person roles, all of which should be reviewed together when the AE is recertified.
Specialised ventilation (HTM 03-01) and Low-Voltage electrical (HTM 06-02)
HTM 03-01 covers specialised ventilation for healthcare premises and HTM 06-02 covers low-voltage electrical safety. AE appointments in these disciplines should be reviewed on the same schedule as water and medical gases to keep audit and renewal cycles aligned.
A registered AE on every appointment letter; supported by competent APs and a documented Water Safety Group, is the new baseline.
The IHEEM register has not appeared in isolation. The Building Safety Regulator (BSR) became an independent statutory body in January 2026, sharpening accountability for higher-risk buildings, including hospitals. Trusts already feeling the pressure of stronger evidence requirements under the Building Safety Act will find that a registered AE is one of the clearest, most defensible signals of competence they can point to during scrutiny.
The combined effect is a tighter, more transparent appointment regime — one that rewards Trusts who already keep good records and that will reward AEs who treat continuing professional development as core to the role.
We work with NHS Trusts and practising AEs across the UK on three connected activities. We deliver AE training and appointment support aligned to HTM 00, helping engineers prepare evidence packs for IHEEM certification. We deliver AP training across HTM 02-01, 03-01, 04-01 and 06-02 so the wider competence framework underpinning every AE appointment is solid. And we help estates teams build competence management systems that map cleanly onto HTM 00, so the register is reflected operationally rather than just on paper.
Book a 30-minute AE transition review with our team. We will help you audit current appointments, map competence evidence, and prioritise training across HTM disciplines.
Talk to our AE teamWe’re here to support you. Just fill out the form and one of our team members will be in touch shortly to discuss your requirements.