40 to 60% of your energy is cooling

Your hospital's chiller plant is running at the same efficiency it did in 2015, and nobody has asked a question about it since the last major retrofit. Then the annual BCA benchmarking submission goes in, the energy use intensity figure lands above the peer benchmark for healthcare facilities, and the board wants to know why the estate is carrying a cost and a disclosure risk that nobody flagged. The qualified person who signed the original plans is long gone. The duty rests with the building owner, which means it rests with you.

Cooling accounts for 40 to 60% of building energy consumption in Singapore, according to BCA's own study published in July 2026. In a hospital or care home, that cooling load runs around the clock, because the people inside cannot be asked to tolerate a warm afternoon. The efficiency of that system is not a sustainability talking point. It is a line in your operating budget and a number in a statutory return.

The regulation applies to existing buildings above 5,000m², and hospitals are named

The Building Control (Environmental Sustainability) Regulations 2008, as amended in 2021, 2022 and 2025, set a minimum environmental sustainability standard for new buildings and for existing buildings undergoing major retrofitting. The threshold that matters for a portfolio director is gross floor area. For projects with a first submission date for planning permission from 1 December 2021 onwards, the trigger is a GFA of 5,000m² or more. For projects submitted between 15 April 2008 and 30 November 2021, the threshold was 2,000m².

Major retrofitting to an existing building with a GFA of 5,000m² or more brings that building into scope. An alteration that does not involve major retrofitting works is not subject to the requirement, which is the sentence every asset manager reads first. But a hospital plant replacement, a ward block reconfiguration, or a care home extension that pushes the GFA past the threshold is not an alteration in the ordinary sense. It is a regulated works project, and the qualified person who submits the building plan is jointly responsible with the other appropriate practitioners for meeting the standard.

What that means for you: if your portfolio includes a hospital or care home where a major retrofit is being scoped, the cooling system specification is not a facilities decision. It is a compliance decision, and the evidence trail runs through CORENET. For BP and TOP submissions in CORENET 2.0, the qualified person must generate the environmental sustainability forms via the ES Online Portal. For CORENET X, the BC ES Appendix 1 form applies. The BCA guidance on environmental sustainability legislation sets out the submission routes and the code editions that apply by planning submission date.

Every year, your healthcare buildings must report energy data to BCA

Since 2013, building owners have been required to submit annual building information and energy consumption data to BCA. The annual mandatory submission covers buildings with a gross floor area of 5,000m² or more. Healthcare facilities are a covered building type, alongside commercial buildings, institutional buildings, sports and recreation centres, and mixed developments.

The metric is energy use intensity, or EUI, calculated by dividing a building's total annual electricity consumption in kWh by its gross floor area in m². EUI allows comparison against similar building types, and it is influenced by both energy efficiency and consumption patterns. A hospital with a 24-hour cooling load will sit in a different band from an office tower, but the benchmark for healthcare facilities is published, and your building's number is compared against it.

The BCA Building Energy Benchmarking Report is published annually, and the underlying data is available as a spreadsheet. That means your building's EUI is not private. It is part of a national dataset, updated each year to reflect newly added buildings and major renovations. If a care home in Jurong or a hospital in one-north is running its chillers inefficiently, the number shows up, and the comparison is public.

The practical check here is not whether you filed the return. It is whether you can explain the number to your board before someone else asks. A rising EUI in a healthcare building usually traces back to a chiller plant running at part load, a cooling tower that has not been cleaned, or a controls sequence that nobody has reviewed since commissioning. None of those are visible in the annual submission. They are visible in the trend line across three years.

Alternative cooling technologies can cut cooling energy by 30 to 50%, and the evidence is now public

BCA's Design Prototyping for Decarbonisation study, published in July 2026, confirmed that alternative cooling technologies such as Passive Displacement Cooling and hybrid cooling systems are capable of reducing building cooling energy consumption by 30 to 50% while maintaining thermal comfort. The study covered high-rise commercial office, hotel, and mixed-development building typologies, and a public report documenting the details will be available by end of 2026.

As of July 2026, at least 33 public buildings and 14 private buildings in Singapore have adopted alternative cooling technologies. Dulwich College (Singapore) achieved 49.5% energy savings for the air-distribution system through Passive Displacement Cooling across classrooms, the auditorium, and collaborative spaces. Paya Lebar Green delivered 45% energy savings with a cooling system combining perimeter active chilled beams, interior VAV AHU systems, and a high-efficiency dual-temperature chiller plant. Both are recipients of the SGBC-BCA Leadership in Sustainability Award in the Carbon Performance category.

Those are not hospitals or care homes, and I would not pretend the same specification transfers directly. A ward or a resident room has different occupancy patterns, different infection control requirements, and different tolerance for draughts. But the principle holds: the cooling system is the largest single lever on your energy cost, and the technology to reduce that load by a third or more is already installed in Singapore buildings. The BCA study on the 80% energy efficiency target sets out the findings and the building types covered.

Singapore's target is an 80% improvement in energy efficiency from 2005 levels, and leading buildings have achieved 72% improvement thus far. The target for 80% of buildings by GFA to achieve Green Mark Certification by 2030 is at 66% as of July 2026. Your healthcare buildings are part of that count, and the cooling system is where the improvement is won or lost.

What the inspector and the board both look at

When a compliance review reaches your healthcare portfolio, the questions are specific. Can you produce the current environmental sustainability submission for any building that has undergone major retrofitting since the applicable threshold date? Can you show the annual benchmarking submission for every building above 5,000m²? Can you explain the EUI trend for each hospital and care home against the published benchmark?

The qualified person who signed the plans holds part of that evidence, but the building owner holds the duty. If the QP has retired or the firm has changed, the submission records still need to be retrievable. CORENET holds the filed forms, but the calculations, the as-built submissions, and the correspondence sit with whoever managed the project. In a portfolio that has acquired buildings rather than built them, that trail is often incomplete.

The cooling tower registration point is a separate but related exposure. An unregistered cooling tower is a different breach from an inefficient chiller plant, but both surface in the same due diligence exercise. I have written about what an unregistered cooling tower costs when a local authority or an insurer asks the question.

Your 60-second self-check

• For every hospital and care home in your portfolio above 5,000m² GFA, could you produce the last annual BCA benchmarking submission today?
• If a major retrofit has been carried out on any of those buildings since the applicable threshold date, can you show the environmental sustainability submission and the as-built forms?
• Could you explain the three-year EUI trend for each healthcare building against the published benchmark, without asking the facilities manager to prepare a slide?

If you want to see which statutory deadlines and penalties apply to your portfolio, each with its official source, the free 5-minute Director's Risk Check gives you that view. It scores your cost control exposure and shows you where the gaps sit before a board paper or a due diligence request finds them. You can run the Director's Risk Check here, or send it to the colleague who holds the building records.

Herman's verdict

The annual benchmarking submission is not a sustainability report. It is a public number with your building's name on it, and the cooling system is what moves it. If you cannot explain the EUI trend for a hospital or care home before the next submission is due, you are not managing the cost. You are waiting for someone else to notice it.

— Herman