Can my assessor really refuse to issue the EPC until they have photos?

Yes — and it is not the assessor being difficult; their accreditation scheme requires it of them.

Why the assessor's hands are tied

Since 1 February 2025, the accreditation schemes behind on-construction assessors have required the photographic evidence to be submitted with audit documentation when lodging EPCs for new homes in England and Wales. Missing or inadequate photos may delay the lodging of the as-built BREL (or Welsh BRWL) report and the EPC. Working practice matches: assessor firms state openly that they will not issue a BREL or EPC until satisfactory photographs have been received. And without the EPC and signed BREL, the dwelling's completion cannot be signed off — which is why photo problems surface at the worst possible moment, right at handover.

If photographs are missing for a detail

There is a route, but it is narrower than people hope: documentary evidence of an alternative, plus acceptance by the building control body. That is a negotiation, not an entitlement — talk to your assessor as early as possible, before the detail is buried under the programme's critical path.

The practical takeaway

Photograph each detail before it is closed up and keep the evidence organised per plot (the six categories). Buildsnapper exists to make that side of it routine: every photo geotagged, timestamped and filed to its plot and section, so what reaches your assessor is what the scheme requires.

Verified against primary sources 13 July 2026.