Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations 2026: partial BRIA

Executive summary

This Partial BRIA is published to help respondents to the consultation on the proposals for PRS MEES regulations to understand possible costs and benefits of the proposals as well as identify areas where they might want to provide further evidence of impacts to assist the further development of the regulations.

Our policy aim is to improve the fabric efficiency of the domestic PRS stock, in order to both tackle fuel poverty and to reduce emissions from PRS buildings. In this Partial BRIA, we consider both a ‘do nothing’ option and an option to introduce regulations to establish a PRS MEES, to achieve this aim.

There has been some progress to date in PRS properties, and the proportion of properties in EPC band C or above has been steadily increasing but 48% remain at band D or lower (34% of properties are EPC band D and 14% of the stock is rated EPC band E/F/G). There are misaligned incentives in the PRS because the costs of making improvements (even with access to low cost government loans) will fall to landlords, while the primary benefits from increased thermal comfort or lower fuel bills will fall to the tenant. We have therefore concluded that our preferred option is to introduce regulations to mitigate these misaligned incentives.

As noted, the primary costs are likely to fall on PRS landlords and we set out an estimated average cost of £1,400 - £2,700 per property based on possible measures that could be installed. We have also noted the potential positive impacts for tenants and for the energy efficiency supply chain.

Alongside the written consultation, we will engage further with stakeholders, including organisations representing landlords and other affected groups. We will continue to engage with COSLA and the Regulatory Review Group (RRG), amongst others. The consultation responses and this stakeholder engagement will feed into both the further development of our policy for the regulations and for the final BRIA and other impact assessments. We will also aim to improve our cost estimates ahead of publication of the final BRIA, when we have more information about the new HEM that will underpin the reformed EPCs. We intend to introduce regulations in this parliamentary term.