There are ten days than three weeks left to register for the government’s Carbon Reduction Commitment Energy Efficiency scheme. Here, Knight Frank head of sustainability David Goatman gives his view on what you should be doing now:

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You’ve registered right? No? Oh dear.

If you are one of the many property companies and funds yet to register for the CRC scheme it may already be too late to avoid a fine on 1 October.

Putting this bad news to one side, something that has really struck me over the last few days is a recurring difficulty for offshore property funds, the requirement for a UK-based primary member.

This has thrown up all kinds of risk and liability issues. Clearly legal advice is making a number of organisations very wary of taking on this role and as a result a number of large offshore property funds are having to resort to phoning around potential agents to try and get someone to act as their UK primary member.

New guidance has hopefully provided a bit more flexibility for offshore funds to get their CRC registrations over the line, but not much.

Option 1 is that the overseas parent nominates a UK office as their UK primary member. This is not ideal for the EA as it makes validation more difficult, they will still end up dealing with the overseas parent and the UK primary member must have a UK bank account.

Option two is to appoint a third party agent as UK primary member / compliance account holder. This is easier for the offshore fund and for the EA. So why isn’t everybody doing it? Because the compliance account holder will need full indemnity from the parent for the potential liabilities they are assuming. Funds don’t want to offer this and agents won’t take on the role without it.

So we are left with multi billion pound offshore property funds searching for a UK agent to register for the CRC whilst the days towards the deadline slip away. Hardly the most auspicious start.

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• CRC countdown blog: don’t count on leniency
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