BICS Compliance: What manufacturers need to know before applying

August 18, 2026

The publication of the latest BICS guidance gives manufacturers a much clearer picture of how the scheme will work in practice. For businesses looking ahead to the application window opening from 1 October 2026 and closing on the 30 November 2026, much of the early attention will naturally be on eligibility and the potential value of the relief.  

However, the guidance also reveals something equally important: BICS is being built around a much more structured compliance framework than a simple one-off application.  

A significant change from previous schemes is the new requirement for a Companies House officer to sign off each application. This is a clear signal of the Department for Business, Innovation, Science and Trade’s (DBIST) intention to strengthen accountability and ensure every application is formally authorised by the business. 

That requirement sits alongside a wider set of compliance obligations, including: 

  • Authorised sign-off – applications and declarations must be approved by a Companies House officer or duly authorised agent. 
  • Supporting evidence – demonstrating continued eligibility where required. 
  • Annual declarations – confirming that key company, site and production information remains accurate. 
  • The Year 2 review – a full reassessment of eligibility and the level of support being received. 
  • Reporting material changes – changes that could affect eligibility or support must be reported. 
  • Audits and site visits – DBIST may carry out further verification checks. 
  • Recovery of overclaimed support – excess relief can be recovered where a business receives more than it is entitled to. 

Taken together, these requirements make clear that BICS is not simply an application process, but an ongoing compliance commitment that businesses will need to manage throughout the life of the exemption. Below, we look at each of these compliance requirements in more detail and what they mean in practice for manufacturers preparing to apply. 

Accountability and Authorised Sign-Off 

The latest guidance establishes a clear line of accountability from the application stage onwards. 

An applicant must either be an officer registered at Companies House or have authorisation from someone who is. Where a consultant or other third party manages the application, they can do so on the company’s behalf, but the business remains responsible for the information being submitted.  

The individual providing the required sign-off therefore needs to be confident that the position being declared is accurate and that the business can support it if questioned later. 

For many manufacturers, this is where the practical burden starts to emerge. BICS brings together energy, manufacturing and compliance requirements that may ordinarily sit across several internal teams. 

Bonham & Brook can help bring those strands together. Our role is to interpret the scheme requirements, manage the technical work and provide those responsible for sign-off with a clear, well-supported position. 

Supporting Evidence 

BICS compliance also depends on businesses being able to substantiate the position behind their exemption over time. 

The latest guidance makes clear that supporting information may need to be revisited as part of annual declarations, the Year 2 eligibility review or any additional verification activity. In particular, businesses may be asked to demonstrate that eligible production is still taking place and that the level of support they are receiving remains appropriate. 

This makes record-keeping an important part of the compliance process. The underlying basis for the exemption should remain clear and accessible throughout the period of support, rather than having to be reconstructed when a review takes place. 

Bonham & Brook can help maintain that continuity, ensuring the rationale and supporting information behind the original application remain organised and ready to support future compliance requirements. 

Annual Compliance Obligations 

Receiving an exemption does not bring the compliance process to an end. BICS has been designed with annual reporting checkpoints throughout the period of support, giving DBIST an opportunity to confirm that businesses continue to meet the conditions under which their exemption was originally awarded.  

Businesses will be expected to confirm whether relevant details have changed, including information relating to the company, manufacturing sites and activities supporting the exemption. Where circumstances have changed, further information may be required. 

The declaration is intended to test whether the conditions behind the original exemption are still being met. If production, sites or electricity arrangements change, the exemption entitlement may need to be reviewed. 

The Year 2 Eligibility Review 

The most significant scheduled compliance checkpoint comes in the second year of support. For businesses that begin receiving BICS exemptions in 2027, the review must be completed between April and 30 November 2028. 

This goes considerably further than an annual declaration. The review combines an update on the business’s circumstances with a full eligibility reassessment. Manufacturers will need to demonstrate that eligible production is still taking place and remains at a level appropriate for the exemption originally granted. 

DBIST will look to use information already provided through the original application, annual declarations and any changes reported in the meantime where possible. According to the guidance, the requirements for demonstrating continued eligibility will broadly mirror those of the original application, making continuity particularly important. 

Two years after the first application, a business should still be able to understand how its original position was reached, what has changed since, and whether those changes affect its entitlement. If the Year 2 review is not completed, or information is knowingly provided incorrectly, the exemption can be revoked.  

Bonham & Brook’s role is to manage our clients’ compliance obligations throughout the entire BICS exemption lifecycle, reducing the burden on internal teams and helping keep the position consistent and defensible. 

Reporting Material Changes 

Manufacturing businesses rarely remain static for five years. Sites are acquired or consolidated, meters change, production lines evolve and the balance of manufacturing activity can shift. Under BICS, some of those everyday commercial developments can have compliance implications. 

Where a material change could affect eligibility or the level of support being received, businesses are expected to proactively inform DBIST rather than simply waiting for the next scheduled declaration or review.  

This is important because the trigger may not initially look like a BICS issue. 

A change made by an operations, property or energy team could ultimately affect the relief being received. Maintaining oversight therefore means understanding not only the original application, but what is changing within the business afterwards. 

This is another area where an experienced compliance partner can help businesses identify when an operational change may have a BICS consequence before it becomes a problem. 

Ongoing Verification and Site Visits 

The scheduled reporting requirements are not the only way a BICS position can be reviewed. In addition to annual declarations and the Year 2 reassessment, DBIST can undertake further verification activity before and after exemptions are awarded. The guidance says this may include requests for additional information, targeted or random checks, checks against other available information and site visits.  

Businesses must retain the records supporting their BICS exemption for at least six years and be able to provide them if DBIST carries out a later review or verification check. 

Overclaims, Recovery and Enforcement 

The guidance makes clear that false, misleading or incomplete information can lead to an application being rejected, an exemption being revoked, support being recovered and, where appropriate, further enforcement action.  

That does not mean every mistake will automatically lead to enforcement. The guidance recognises the difference between genuine administrative errors and more serious cases. What it does underline is the importance of being able to explain and defend the position being taken. 

For businesses receiving potentially valuable electricity cost relief over several years, compliance cannot be an afterthought. 

Managing BICS Compliance Over Five Years 

The latest guidance gives manufacturers greater certainty over BICS, but it also shows the level of ongoing oversight that will come with the scheme. 

There is an initial application to get right, an authorised sign-off requirement, ongoing declarations, a significant reassessment in Year 2, material changes to monitor and the possibility of additional verification throughout the exemption period. 

That can represent a considerable additional responsibility for finance, energy and operational teams already managing the day-to-day demands of the business. 

Bonham & Brook’s Energy team specialises in this area. We combine technical energy-relief expertise with a compliance-led approach, helping clients manage the BICS position from the initial application through to ongoing reporting and review. 

Our role is to take on the heavier work behind the scheme – interpreting the requirements, maintaining continuity and helping ensure the position remains accurate and defensible – while keeping the time commitment required from the client as low as possible. 

With applications opening on 1 October 2026, businesses considering BICS should be thinking not only about whether they qualify, but how they will manage the compliance responsibility that follows.  

We offer a free initial BICS eligibility consultation to help you understand whether your business could qualify and what the ongoing compliance requirements would involve. 

Speak to our Energy team about preparing for BICS. 

Contact Us

 

Shannon Shaw

Senior Commercial Manager – Energy

 

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