Energy Performance of Buildings (Scotland) Regulations 2025: business and regulatory impact assessment

Annex A

Benefits to consumers are not monetised, suggesting overall benefits are significantly under-represented.

Key Costs and Benefits

The largest monetised costs to businesses are associated with administration, audit and familiarisation. The largest monetised costs to consumers are associated with an increased demand for EPCs. The largest monetised costs to SG and LAs are associated with administration.

The largest monetised benefits to businesses are associated with assessors seeing an increased demand for EPCs. The largest monetised benefits to consumers are not monetised. The largest monetised benefits to SG and LAs are associated with the lodgement fee.

N.B. Because benefits to consumers cannot be monetised, overall benefits appear much lower than they are believed to be.

Quantification of monetised costs and benefits

• Costs and benefits associated with a change in demand for EPCs
  • Demand for EPCs for owner occupied dwellings is not expected to change
  • Demand for EPCs for rented dwellings is expected to rise with a shorter validity period. This increase is higher for PRS dwellings than for SRS dwellings.
  • Increased demand for EPCs results in higher costs for LAs, consumers, some businesses, and landlords, and benefits to businesses including EPC assessors and Approved Organisations
  • Higher numbers of EPCs results in a higher demand for audit. Under the preferred option, this cost is held by SG.
• Costs and benefits associated with a change in the EPC Lodgement Fee
  • Under the preferred option, costs to businesses increase in line with the increased lodgement fee, though it is likely some or all of this will be passed to consumers
  • SG sees a benefit due to the increased lodgement fee
• Costs associated with implementing a new system
  • Landlords, local authorities, assessors, approved organisations, and other businesses such as conveyancers see a cost due to the time required to familiarise with new systems and requirements
  • SG sees staffing costs for administration of the programme

Limitations and uncertainties

• Labour capacity
  • Due to limited data, it is extremely uncertain how many EPC assessors might be needed to meet increased EPC demand. Rather than assuming an increase in number of assessors, this analysis assumes fairly high familiarisation times for existing assessors and organisations
• Familiarisation
  • It is unclear how much time would be needed by different actors to familiarise with new systems; estimates are based on existing programmes and anecdotal information
• EPC demand
  • Demand for EPCs is highly uncertain, due to both lack of data and uncertainty about future regulations, or funding opportunities requiring EPCs. Numbers of EPCs are modelled and estimated, with significant uncertainty
• Non-domestic data
  • The non-domestic analysis relies on the accuracy of EPC records from the EPC register. However, only a small proportion are quality assured, and the register lacks full data cleansing. To reflect this uncertainty, low, mid, and high range estimates are provided where EPC data is used.