Guidance by Hearsay
Chargepoint installations in and around buildings are being refused on fire-risk grounds that are routinely attributed to “the guidance”. This paper audits the most commonly imposed requirements against the documents they cite - Part S, the Arup covered car parks guidance, RC59 - with clause references throughout, and finds that none of them appears in any of them. It sets out how hearsay becomes doctrine, what the refusals cost, the route to yes that already exists in the insurers’ own literature, and what the insurance sector should do now. Version 1.1 is updated for the OZEV consultations opened on 21 October 2026.
Cite as: McKemey, J. I. (2026) Guidance by Hearsay. RCP Working Paper 2026/01. Rapid Charge Paradox Ltd, October 2026.
Executive summary
Across the UK, Electric Vehicle (EV) chargepoint installations in and around buildings are being refused, cancelled, and even decommissioned on fire-risk grounds. The requirements cited - minimum distances from buildings, blanket prohibitions on covered and basement car parks, demands for costly mitigation retrofits - are routinely attributed to "the guidance".
This document examines what the guidance actually says. Its central finding is simple and uncomfortable: the most commonly imposed requirements do not appear in any of the canonical documents. They are hearsay - requirements cited in a process where defined technical terms are misheard, precautionary suggestions harden into prohibitions, and every retelling ratchets more conservative than the last. The ratchet turns one way because the incentives do: excessive caution carries no penalty, while nobody wants to be the name on a permissive decision when zero fire risk can never be certified.
The clearest example is the widely applied “10 metres from a building” separation rule, routinely attributed to “the guidance”. The only 10-metre clause in the canonical literature - RC59, the insurance sector’s own umbrella guidance - concerns hazardous areas, Zone 1 or 2, ATEX: locations where an explosive atmosphere may occur, such as ignitable liquids storage at fuel-filling stations. RC59 contains no distance-from-building requirement of any kind, and nor does any other canonical document. The only 10-metres-from-buildings figures I have been able to locate sit in insurer and broker loss-prevention literature - and there the figure mostly arrives qualified: “ideally”. Those qualifiers die in transmission. RC59 does, however, contain something the market appears not to have noticed: an explicit, conditional compliance pathway for the basement and covered-car-park installations that individual insurers and fire risk assessors are refusing outright.
The consequences are material, both in terms of EV uptake and fire risk:
An estimated one million UK households that park in covered car parks are effectively unable to install home charging - one of the largest remaining infrastructure barriers to EV uptake, and a direct drag on the government's own targets (e.g. the ZEV mandate). Property owners face exclusions and refusals that their insurers' own literature does not require. And the prohibition does not remove the charging; it removes the safe way of doing it.
Drivers denied a purpose-built, protected installation resort to improvised ones - extension leads through windows, domestic sockets never rated for sustained load, cables trailed across shared spaces - which carry material fire risk the prohibition was meant to prevent. The insurance sector is operating a de facto ban that its evidence base does not support and that makes its own risk worse.
Government has now moved: on 21 October 2026 it opened consultation on extending the Part S chargepoint requirement to covered car parks, and on a statutory “ability to charge” for tenants and leaseholders. Both address real barriers. Neither can reach the one this paper is about, because it concerns how the market reads the documents. New guidance is coming too, and RC59 itself is being revised. Unless the mechanisms identified here are addressed - by insurers, brokers, fire risk assessors and drafters alike - the market risks converting the next document into hearsay too.
