Removing Barriers to Solar PV and Clean Energy
SolarSense is calling on the UK government and HMRC to urgently review and clarify outdated rules that could be preventing thousands of commercial and industrial properties from installing solar PV – despite it being one of the most effective routes to reduce costs and achieve net zero. At present, many pension-owned properties may be missing out on the significant cost savings and carbon reductions that rooftop solar PV can deliver, simply because of uncertainty in how current legislation is interpreted.
Tangible Moveable Property Rules
Under HMRC’s current framework, some assets are classified as Tangible Moveable Property (TMP) – items that can be physically touched and moved, such as furniture, works of art and machinery. The same classification could be applied to solar panels and wind turbines. Because pension funds are prohibited from owning moveable assets, they may be restricted from installing solar panels on properties they control. In addition, they are not allowed to trade – preventing them from selling excess solar energy to tenants or the grid. This decision is currently left to pension scheme administrators, creating uncertainty and discouraging investment in solar PV and clean energy solutions.
A Missed Opportunity for Cost Savings and Carbon Reduction
The current rules not only deter commercial landlords from installing solar PV, but also prevent tenants from doing so if they do not own or rent the roof outright. Workarounds, such as leasing roof space separately, are often impractical due to prohibitive legal costs. Ashley Wood, Chief Executive at SolarSense warns that the ambiguity is holding back progress:
“Solar panels have a huge role to play in reducing energy costs for UK businesses, supporting cleaner energy generation, and drastically cutting carbon emissions. It is wrong that organisations must navigate vague and outdated rules – often at considerable legal expense before making a decision that should be straightforward.” Ashley Wood, Chief Executive at SolarSense
Why the TMP Rules Need Updating
The Tangible Moveable Property (TMP) regulations have not been comprehensively reviewed for over a decade, despite major advancements in renewable energy. SolarSense believes solar PV systems should be classified as permanent fixtures, not moveable assets, because they are securely fixed in place and cannot be removed without causing damage.
Clearer HMRC guidance would allow pension funds to invest in rooftop solar and sell renewable energy to tenants – unlocking significant cost savings and supporting the UK’s net zero targets.
“Not only will the current TMP rules stop significant numbers of industrial landlords from installing solar, their tenants also will not be able to fit PV because they don’t own or rent the roof. The only way to get by this would be to rent the roof space separately, but the legal costs would be prohibitive.” Ashley Wood, Chief Executive at SolarSense
The Scale of the Opportunity
The UK has an estimated two million commercial buildings, representing a vast untapped potential for rooftop solar PV. Removing legislative barriers could transform the energy performance of a significant proportion of these properties – cutting energy costs for businesses, improving resilience against volatile markets, and delivering substantial carbon reductions.
For example, pension funds, which own a large share of warehousing, are particularly well-placed to benefit, yet risk missing out due to solar panels being classified as Tangible Moveable Property (TMP). The government’s Clean Power 2030 Plan, unveiled at the end of 2024, recognised the opportunity across the warehouse and industrial sector, citing UK Warehousing Association research that the largest 20% of warehouses alone could offer 75 million m² of roof space which is enough to support up to 15 GW of rooftop solar capacity.
SolarSense has formally written to the Secretary of State for Energy Security and Net Zero, urging the government to:
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Clarify HMRC guidance that solar PV systems are not Tangible Moveable Property.
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Allow pension-owned properties to generate and sell renewable energy to tenants.
Such reforms would align legislation with the UK’s net zero goals, enable pension funds to improve the financial and environmental performance of their property portfolios, and accelerate the transition to clean energy.
Get in touch
If you manage or occupy a commercial property and want to reduce your costs and explore the benefits of rooftop solar PV and clean energy, please get in touch to speak to one of our energy experts. We can provide a tailored breakdown of your potential energy cost reduction, carbon savings, and ROI.
