BRL 100 in 2026: what changes for installation companies?

BRL 100 has been the assessment guideline for installation companies working on refrigeration installations, heat pumps and air conditioning installations since 2017. The guideline is periodically revised to align with new European F-gas legislation and technical developments. Version 3.0 was adopted on 5 December 2025 and formally takes effect on 31 August 2026 — with practical consequences for many companies.

This article sets out what actually changes, which transition period applies, and — more importantly — what you can already prepare today so you're not caught by surprise at the next audit.

Why a revision?

Three developments are driving the update:

• EU 517/2014 → Regulation (EU) 2024/573. The new F-gas Regulation requires more tightly maintained change records and stricter quotas for high-GWP refrigerants.
• Energy transition. The share of heat pump installations is growing explosively; BRL 100 has to keep up with the installation requirements for air-to-water and ground-water systems.
• Digitisation expectation. Auditors increasingly expect records to be available digitally — not as a stack of binders.

What actually changes?

### 1. Stricter change traceability

From now on, every refrigerant change must have at least the following data:

• Date + time (to the minute)
• Cylinder ID moved from/into
• Installation ID
• Type of change (top-up / recovery / transfer / disposal)
• Quantity in grams (no longer in 0.1 kg)
• Technician ID + signature
• Work order ID the change belongs to

Companies that still keep this in Excel will find it's practically impossible to do this consistently to the minute without a digital work order flow. Our refrigerant module does this automatically — every change gets a server timestamp, work order link and technician context.

### 2. Leak-check frequency: thresholds unchanged

The leak-check frequency stays tied to the amount of CO₂ equivalent of the refrigerant in the installation. These thresholds already applied under the old Regulation (EU) 517/2014 and have been carried over unchanged into (EU) 2024/573 — so the revised BRL 100 changes nothing here:

| CO₂-eq | Leak-check frequency | |---|---| | < 5 tonnes | Not mandatory | | 5–50 tonnes | 1× per year | | 50–500 tonnes | 1× per 6 months | | > 500 tonnes | 1× per 3 months + automatic leak detection system |

So the practical impact of the BRL 100 revision doesn't lie in these thresholds themselves, but in the tightened requirements for change traceability and audit trail above. Do check those against your current records.

### 3. Audit trail must be tamper-evident

This is the heaviest change in terms of administration. An audit trail must:

• Be cryptographically enforceable. Changes made after the fact must be detectable — for example via hash chaining, where each audit record contains the hash of the previous record.
• Be traceable per user. Not just "what was changed" but also "by whom, with which role, from which device, on which date".
• Be non-editable. Excel spreadsheets don't qualify by definition — a spreadsheet is always editable. Keeping the audit record elsewhere (a database with an INSERT-only constraint) is therefore the way to go.

Koldwerk's audit log has been built this way from day one: append-only, hash-chained, with an integrity check via a daily cron job.

### 4. Technician certification

Every technician who carries out F-gas work must hold a valid personal certificate — that was already the case. What changes: companies must be able to demonstrate that they actively monitor whether certificates are expiring, not only at the moment an audit asks for it.

Specifically: the system must issue a reminder 30 days before a certificate expires, and the company must be able to demonstrate that those reminders are acted on. Our technician certification module does both automatically.

Transition period

BRL 100 version 3.0 was adopted on 5 December 2025 and formally takes effect on 31 August 2026, with a transition period of 24 months until 31 August 2028 (the six authorised certification bodies — InstallQ is not one of these six, see what is BRL 100? — audit companies against the new version in phases during that period). For most companies this means:

• 5 December 2025: BRL 100 version 3.0 adopted
• 31 August 2026: version 3.0 formally takes effect
• Until 31 August 2028: transition period — phased audits under the new version
• From 31 August 2028: all companies must be compliant with version 3.0

Don't wait until your next audit to start preparing. The direction is clear — more digitisation, more traceability, stricter data validation.

What can you do today?

Three actions with immediate ROI:

1. Take stock of your portfolio by CO₂-eq. Installations just below the 5-tonne threshold will soon require a leak check — plan for that. Our installation management module calculates this automatically per installation. 2. Start with digital work orders — now. If you're still working on paper or in Excel: every month you keep doing that, you build up a bigger migration debt. Check out the migration guide from Excel to SaaS. 3. Test your audit trail. Ask yourself: "If the Kiwa auditor wants to see my 12 change records from Q2 2025 tomorrow, can I deliver them within 5 minutes — including who entered them, when, and from which device?" If not, that's your first priority.

Disclaimer: the adoption date (5 December 2025), effective date (31 August 2026) and transition period (24 months, until 31 August 2028) of BRL 100 version 3.0 are confirmed. The precise substantive changes described in this article (traceability, audit-trail requirements) are an analysis based on publicly announced direction, not a literal rendering of the official text. Consult Kiwa (opent in nieuw tabblad) or your own certification body for the exact, binding requirements.