Consultation on proposals to Update the School Premises (General Requirements and Standards) (Scotland) Regulations 1967: Analysis of Responses

Executive Summary

A public consultation on proposals to update the School Premises Regulations ran from 16 December 2025 to 31 March 2026. Across 25 questions, the consultation sought stakeholders’ views on the Scottish Government’s proposed approach. In total, 264 consultation responses were received from 175 individuals and 89 organisations.

While agreement with the proposed changes was generally high, respondents often caveated their agreement, raising concerns about the need for flexibility to meet individual school needs, costs and feasibility, and the level of detail in the consultation paper.

Regulations to be retained

There was widespread agreement with proposals to retain these four regulations with over nine in ten respondents agreeing with the proposals at Q3 and Q4, and eight in ten agreeing at Q2. At Q1, 23% of those answering the closed question disagreed with the proposal; the highest disagreement in this section. While many respondents expressed support for using Building Bulletin 93 in their open comments, as they felt it was a good minimum standard, several detailed why they disagreed. They felt that it did not fully meet the needs of pupils or staff with hearing or sensory impairments and may not fully account for a more flexible, open-plan layout that is popular in recently built schools.

Across the remaining questions, respondents who disagreed or caveated their agreement provided other standards and guidance they thought should be referenced in the regulations. Others reiterated the importance of considering the impacts on children and young people with additional support needs when retaining older regulations.

Regulations to be updated

Proposals to update several existing regulations were widely supported. Over eight in ten of those answering agreed that seven regulations should be updated, as did over seven in ten of those answering Q6, Q7 and Q8. However, eight in ten of those answering Q9 disagreed that the proposals cover modern requirements for toilet and washing facilities.

Across these questions, local authorities in particular raised concern about whether these updated standards would need to be applied to existing school buildings, noting that doing so may not always be feasible and would likely have cost implications.

When asked about regulations around mixed-surface pitches (Q6), respondents who disagreed, and those who agreed but caveated their response, raised concerns about the loss of natural green space and possible health and environmental factors of dependence on synthetic surfaces. When asked about updated regulations around accommodation metrics (Q7), respondents who raised concerns felt that the proposed regulations may be overly prescriptive, while others questioned the impact they may have on smaller schools. Recommendations were made to consider the community use of school facilities and ensure there is flexibility in the metrics to consider multi-use spaces and students with additional support needs.

Sanitary accommodation was considered in Q8 and Q9. While 72% of those answering agreed at the closed question that the number of appliances per pupil as proposed is still appropriate, those who disagreed felt that a greater number of appliances were needed. Respondents at Q9 raised concerns about the specificity of the regulations and felt more detail was needed to ensure the privacy and dignity of different groups of students were respected. Many respondents felt that transgender students should have access to sanitary accommodation they felt most comfortable using. Conversely, many others suggested there should be greater clarity around usage based on biological sex at birth. Several others raised concerns that, without further clarification, a gender-neutral provision may impact the number of facilities provided for students with additional support needs.

Regulations to be removed

There were lower levels of overall support for proposals to remove certain regulations than for some other proposals. Mixed views were recorded regarding removing regulations around educational accommodation in special schools (Q20), accommodation for staff (Q22), and storage accommodation (Q23), which were supported by around half of those answering. Respondents also raised concerns around the proposal to remove playroom accommodation in nursery schools and classes (Q19), with 36% opposed.

Across the open responses, respondents raised concerns about how the removal of regulations may impact the clarity and quality of services delivered across schools in Scotland. Often, this included concerns about losing protections for students with additional support needs. At Q22, respondents also raised concerns that removing regulations around staff accommodation may negatively impact staff wellbeing, privacy and safeguarding.

Conclusion

The responses to this consultation highlight broad agreement with the proposed adjustments to School Premises (General Requirements and Standards) (Scotland) Regulations 1967. Further consideration may need to be given to a small number of areas of disagreement, and specific suggestions to strengthen and improve proposed updates may provide greater clarity for regulations going forward. While respondents may have highlighted areas needing further clarity, most of the proposed changes were recognised by respondents as being necessary to modernise school estates across Scotland.