Building Energy Act 2023 - Heating outside the thermal envelope

Does anyone else have their heating (air heat pump) located in the unheated basement (exterior wall insulated, U value 0.35)?

In this case, does the basement have to be fully included in the building energy law calculation?

Background: The basement builder and the structural engineer of the house, who also performs the heat calculation, disagree on what needs to be taken care of.

Thank you very much for any good advice.

We also have the heating in the (otherwise) unheated basement. In our case, only the basement ceiling is insulated, but I am still waiting for the documents from the energy consultant.

We also have the heating in the (otherwise) unheated basement. In our case, only the basement ceiling is insulated, but I am still waiting for the energy consultant's documents.

How are your exterior basement walls constructed?

How are your basement exterior walls constructed?

Our energy consultant only calculated the Building Energy Act for the thermal envelope and noted that the heating is located outside the thermal envelope in the basement. The basement builder does not accept this and wants the entire basement to be considered in the Building Energy Act. I am going crazy.

How are your basement exterior walls constructed?

Natural stone masonry with an inner cladding shell made of aerated concrete