What SAT and Zero-Export Test Records Does a BESS Commissioning File Need?

SAT and zero-export test records in a battery energy storage system commissioning file are the dated evidence that the installed system passed its site acceptance checks and that export to the grid stayed within the agreed limit on the test date. The records apply to a stationary storage system at a named site, for the operator named in the commissioning file, and the governing dates are the test dates stated on each record and the date of the acceptance agreement that the tests were measured against. Regulation (EU) 2023/1542 sets the battery passport framework that the commissioning file feeds, but the Regulation text gives no published list of SAT checks and no published list of zero-export test checks, so the record method here is built from the acceptance agreement, the grid connection terms, and the test evidence itself.

SAT means site acceptance test: the set of checks applied to the installed system at its site, against criteria agreed before testing, to decide whether the system is accepted for operation. Zero-export means a mode or setting in which the system is required to prevent export of electricity to the grid, or to hold export at an agreed limit, rather than to export freely. The scope of this guide is the record of those tests: what to file, what identifiers and dates each record must carry, what pass or fail evidence looks like, and how the records trace to the commissioning file. This guide does not cover general installation and commissioning records, does not explain how to run a SAT check or a zero-export check, does not set an export limit, and does not decide whether a particular system should operate in zero-export mode.

What does a SAT record set contain?

A SAT record set contains one record per acceptance check, grouped under a single SAT cover sheet for the system and the site. The cover sheet states the system identifier, the site name and address as recorded in the commissioning file, the acceptance agreement reference, the SAT start date and end date, the tester role, the witnessing role where a witness was required, and the overall SAT result. Each check record states the check name as written in the acceptance agreement, the criterion from that agreement, the method used, the result, and the pass or fail decision. A set with only a cover sheet and no check records does not evidence acceptance. Where a check was not applicable, the record should say so in words, with the reason and the date, rather than leaving the check out silently.

What identifiers and dates must each test record carry?

Each SAT record and each zero-export record must carry the system identifier, the site identifier as used in the commissioning file, the test record reference, the acceptance agreement reference where the check comes from that agreement, and the equipment identifier for any meter, analyser, or test instrument whose reading supports the result. Where a system is made of separately identified units, the record should name the unit or units tested, so a later reader can tell whether the result covers the whole system or only part of it. Each record must also carry the test date, the tester name and role, and, where required, the witness name and role. A record dated only by month, or by the compilation date rather than the test date, fails the traceability check. A corrected record should keep the original visible, with a correction note, a correction date, a reason, and a new version identifier.

What pass or fail evidence counts for a SAT check?

Pass or fail evidence consists of the criterion, the observed result, and the decision, all stated on the same record. The criterion is copied or referenced from the acceptance agreement, with the clause or schedule reference, so a later reader does not have to guess what standard the test was judged against. The observed result is the reading, functional outcome, or recorded state the test produced, stated in the unit used by the criterion and by the method named on the record. The decision is a single word, pass or fail, entered by the tester on the test date and attested in the manner required by the commissioning file. A pass without a criterion, or a criterion without an observed result, is an assertion rather than evidence. Photographs, meter exports, and control logs may support a record, but the record itself must state the criterion, the result, and the decision, and must reference each supporting file by identifier and date.

What does a zero-export test record prove, and how is the limit stated?

A zero-export test record proves, for the test conditions and test period stated, that the system did not export electricity to the grid above the agreed limit during the test, and that the control or setting intended to prevent export behaved as expected under those conditions. The record does not prove that export will never occur in later operation, does not prove compliance with grid terms beyond the test evidence, and does not replace a grid connection approval or a metering record. The record must therefore state the export limit as a value with a unit, its source by reference and date, the measurement point, the meter or analyser identifier, and the reading interval or sampling basis. The measurement point matters because export at the inverter terminals and export at the grid connection point are different readings. Where the governing agreement states a tolerance or averaging interval, the record should state it with its source. Where no tolerance is stated, the record should say so honestly and state the raw reading basis used.

How are failed tests and retests filed?

A failed SAT check or a failed zero-export check is filed as a failure record, not deleted and not overwritten. The failure record states the check name, the criterion, the observed result, the fail decision, the test date, and the tester. The file then adds a fault note stating the cause as found, the corrective work performed, and the date of that work, followed by a retest record that repeats the same check under the same method and the same criterion, with a reference back to the original failure record. A commissioning file should not be signed as accepted while a check stands as failed with no retest and no formal disposition. Where a failure is dispositioned by deviation rather than retested, the file should contain a deviation record stating the failed check, the reason for acceptance, the justification relied on, the person who authorised the deviation, and the date of authorisation. A deviation without a reason and without an authoriser is an open failure, not a closed record.

How is traceability kept between test records and the passport file?

Traceability is kept by using the same system identifier on every SAT record, every zero-export record, the commissioning cover sheet, and the passport record or linked record entry that refers to commissioning. Where the passport record does not itself hold the full test reports, the passport entry or linked file should state the commissioning file reference, the SAT record set reference, the zero-export record set reference, and the location where the full records are held. A passport entry that mentions commissioning in general terms, with no file reference, does not trace to evidence. A later change, such as a module replacement, a software update that changes an export setting, a revised export limit, or a change of operator, needs a new dated entry referencing the original records and stating what changed. The original records remain as evidence for the configuration tested on the test dates, and overwriting them to match a later configuration destroys that history.

What gaps make a SAT or zero-export file incomplete?

A file is incomplete when any gap below is present. Each gap should be given an owner and a review date. This gap list is a checking method, not a Regulation list, since the Regulation text gives no published gap list for SAT or zero-export records. The check is performed against the acceptance agreement and the grid terms that governed the tests.

What does an illustrative SAT and zero-export file look like?

The table below uses placeholder values only, labelled illustrative, and shows the form of the records rather than results from a real battery. No value here should be read as a measurement from an installed system. Each numeric entry carries a unit, a method, and a date.

A real file differs from the illustrative file only in that every placeholder is replaced by the real identifier, the real criterion, the real result, and the real test date. This guide does not decide an export limit, does not decide whether zero-export mode is appropriate, and does not decide a retention period, because the Regulation text gives no published retention figure for these records in the material checked for this guide. Retention should follow the commissioning file policy, the acceptance agreement, and the operator record policy that apply to the system, with the applicable policy reference stated in the file.

General educational information only is the status of this guide, not individual legal advice for a specific battery, site, or grid connection. Check the current Regulation text and any applicable delegated or implementing act before acting on a specific battery or decision, and check the acceptance agreement and grid connection terms that governed the tests, since those documents, not this guide, set the criteria, the export limit, and the measurement basis that the records must evidence.