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

1. Introduction

Background

The School Premises (General Requirements and Standards) (Scotland) Regulations 1967 prescribe a broad minimum standard that the premises or equipment of schools must meet. The 1967 Regulations set out minimum standards for aspects such as school site areas, overall educational accommodation, lighting and ventilation.

There is now a need to ensure the regulations reflect modern educational needs. Drivers for reform include:

• The Learning Estate Strategy was jointly produced with CoSLA in 2019 and was refreshed in November 2025. It sets out a shared vision, aspirations and principles for the efficient and effective design, construction and management of schools.
• Changes in pedagogical practice, digital connectivity needs, and accessibility requirements. The pandemic highlighted the importance of effective ventilation and the role of indoor environments in supporting health and wellbeing. Inclusive education requires accessible and barrier-free buildings and equipment.
• Significant improvements in the condition of the school estate. The proportion of schools in good or satisfactory condition has increased from 62.7% in April 2007 to a record 92% in April 2025.
• The need to align the regulations with a significant body of other legislation that applies to all buildings, including schools, and to avoid duplication.

A consultation on changes was undertaken in 2017/18 to bring forward new regulations; however, this work was disrupted by the Covid pandemic.

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. The consultation focused on three key areas:

• Updating the parts of the regulations that remain necessary.
• Considering new areas for inclusion.
• Removing school-specific requirements that duplicate other legislation

It should be noted that this consultation was not about the design and construction required for compliance with building regulations, but what the minimum standards should be in schools for factors such as internal space, outdoor space, ventilation, digital infrastructure, sanitation, and facilities for breaks and eating. The technical nature of the regulations means it is not practical to fully repeat or explain these within this report. Further information on the proposals can be found in the consultation paper.

Public consultations invite everyone to express their views; individuals and organisations interested in the topic are more likely to respond than those without a direct interest. This self-selection means the views of respondents do not necessarily represent the views of the entire population, or of everyone with an interest in this topic.

Respondent profile

In total, 264 consultation responses were received^[1]. Almost all were submitted via the online consultation platform, Citizen Space. Those received in an alternative format, for example, an email or PDF document, were reviewed separately by the research team.

Individuals provided 175 responses to the consultation; the remaining 89 responses were from organisations. To aid analysis, organisations were grouped according to the nature of their work. Table 1 shows the number of each type of respondent.

Table 1: Respondent profile

Analysis approach

The Lines Between was commissioned to provide a robust, independent analysis of the responses to the public consultation. The main purpose of consultation analysis is to understand the full range of views expressed, and, where possible, using closed questions, to quantify how many respondents hold particular views. This report provides a thematic analysis of responses based on the analysis approach outlined below.

Reflecting the number and knowledge of respondents, it is not practical to detail every response in this report; some, especially organisations, shared lengthy submissions reflecting their specific subject matter expertise. These responses are referenced where possible. Full responses to the consultation, where permission for publication was granted, can be found on the Scottish Government’s consultation website.

Quantitative analysis

The consultation included 23 closed questions. Not all respondents answered every question. To compare across sub-groups, this report presents the results of the closed questions based on those who answered each question. For clarity, each table shows:

• The percentage of respondents from the total sample of 264 respondents who selected each response (grey row).
• The percentage response among those who answered each question, broken down by individual and organisation responses (rows including and under “All answering”).

A full breakdown for each question is also provided in Appendix A. Please note that the row percentages may not add to 100% due to rounding.

Qualitative analysis

Qualitative analysis identifies the key themes across responses to each question. The research team developed a draft coding framework based on a review of the consultation questions and a sample of responses. During the coding process, new codes were created if additional themes emerged.

The response rate to each open question varied across the consultation. The qualitative element of the consultation questions invited respondents to elaborate on why they disagreed with the proposed changes to regulations. However, not all respondents chose to comment, and comments were often left by respondents who agreed with the proposals. The qualitative analysis can therefore only be based on the information provided by those who commented.

When reviewing the qualitative analysis in this report, we would ask the reader to consider:

• Many respondents repeatedly raised the same issues or suggestions at multiple questions, regardless of the specific focus of the question. In particular, responses to the last two questions (Q24 and Q25), which focused on impact assessments, typically reiterated points which had been raised earlier in the report. All respondents' views are included in this report, but analysts exercised judgment about the most relevant place to include each theme to minimise repetition.
• In a small number of instances where a response received via email or in a PDF document contained information that did not align with specific questions, analysts exercised judgment about the most relevant place to include this material for analysis purposes.
• Where differences between the views of different types of respondents were evident in qualitative responses, these have been noted. If no specific differences are highlighted, then a theme was raised by a mix of respondents.
• In some cases, the closed question results show a majority in agreement with the changes, but the qualitative analysis may focus on reasons for disagreement. Again, this is driven by the open question inviting reasons for disagreement.
• Where appropriate, quotes from a range of responses are included to illustrate key points and provide useful examples, insights and contextual information.

Weight of opinion

This report presents the themes identified in responses from most to least commonly mentioned. All themes, including views shared by small numbers of respondents, are covered; a view expressed by a very small number of participants is not given less weight than more general comments shared by a majority.

Similarly, all responses have an equal weighting. We recognise this means a response from an individual has the same weight as the response from an organisation which may represent many members, but this approach ensures all views are presented.

Qualitative analysis of open-ended questions does not permit the quantification of results. However, to assist the reader in interpreting the findings, a framework is used to convey the most to least commonly identified themes in responses to each question:

• “Many respondents”, a prevalent theme, mentioned by 25 or more respondents out of all 264 respondents.
• “Several respondents”, a recurring theme, mentioned by between 15 and 24 respondents.
• “Some respondents”, between 5 and 14 respondents, another theme.
• “A few / a small number”, fewer than 5 respondents, a less commonly mentioned theme.
• “Two/one respondents”; a singular comment or a view identified in only one or two responses.

This framework is used solely to present the prevalence of themes within consultation responses. This does not necessarily represent the importance of a theme, given the subjective nature of attributing importance and the self-selection of consultation respondents.