Energy Performance of Buildings (Scotland) Regulations 2025: equality impact assessment

Executive Summary

Policy Context

Many external stakeholders and independent reports have highlighted concerns around the relevance, accuracy and quality of EPCs produced. The ratings which EPCs currently display have been criticised by stakeholders as in need of reform as, in their current format, EPCs are not aligned with our net zero ambitions. An independent review of EPCs recommended the need to improve the quality of EPCs and, in particular, to strengthen quality assurance requirements around audit and inspection of Certificates^[1].

Furthermore, the supporting technical and operational infrastructure which underpins EPCs (the EPC Register and the EPC calculation methodology) is life-expired, requiring significant upgrades.

These calls for reform have been made across the UK, with the UK Government receiving similar recommendations from the Climate Change Committee and consumer groups such as Which?, following its decision to retain EPC legislation in UK law following EU exit.

Intended outcomes

We want to enhance EPCs so they continue to be a valuable source of information for home buyers, owners, and tenants, and to continue to support existing government policies and programmes.

The main changes introduced by the 2025 Regulations that will impact consumers, businesses and users of EPCs are as follows:

• EPCs are better-aligned to net zero objectives giving better information to current and prospective property owners and tenants;
• consumers receive more up-to-date information through EPCs which have a five-year instead of 10-year validity period, to more accurately reflect a property’s transition on the journey to net zero;
• life-expired systems are replaced through adopting updated calculation methodologies and infrastructure shared with the UK Government; and
• EPCs are carried out to the highest standard through the introduction of enhanced quality assurance and oversight requirements for EPC assessors and Approved Organisations, including the creation of new onsite audit and inspection functions, thus maintaining alignment with the EU’s own enhanced audit requirements in the 2024 recast of the EPBD.

Who is Affected

The largest group impacted by EPC reform is likely to be the current and prospective owners, landlords and tenants of domestic or non-domestic property. This is because the information the EPC displays about their property will change with the introduction of the new rating system and redesigned certificates.

While the trigger points for when an EPC is required are not changing, the new rating system, redesigned certificate, and reduced validity period will mean that current and prospective owners, landlords, and tenants will receive new and more relevant information, which is more up-to-date, on how a property they occupy, or are thinking of occupying, performs against net zero objectives, and on potential improvements they could make to it.

Equality Impact Assessment (EQIA) Scope

A framing exercise in June 2025 confirmed the need for a full EQIA as EPC reform affects people, particularly those involved in the sale or let of buildings.

The EQIA ensures compliance with the Public Sector Equality Duty to:

• Eliminate discrimination.
• Advance equality of opportunity.
• Foster good relations.

Evidence & Consultation

The EQIA considered a wide range of data, including from both existing literature and engagement with the public.

Existing literature provided limited equality-specific data that was directly relevant to EPC Reform. The Scottish Housing Condition Survey 2019^[2] provided evidence which reports that older people are less likely to live in the most energy efficient homes. The Scottish Housing Condition Survey 2023^[3] provided evidence that older households were more likely to report that their heating system keeps them warm.

Public Engagement included 16 interviews, workshops, and three consultations with the public, businesses and specific stakeholders. Equality issues were explored through specific questions but yielded limited direct feedback. Material associated with these consultations can be found through relevant links presented in this document.

2021 Domestic EPC reform

• Domestic Energy Performance Certificates (EPC) reform: consultation - gov.scot
• Domestic EPC reform consultation: analysis summary report - gov.scot

2023 EPC reform

• Energy Performance Certificate (EPC) reform: consultation - gov.scot
• Energy Performance Certificate reform: consultation analysis - gov.scot
• Energy Performance Certificate (EPC) reform: government response - gov.scot

2025 EPC

• Energy Performance Certificate reform – lodgement fees and penalty charges: technical consultation - gov.scot
• Analysis available through Publications - gov.scot

Key Findings

No significant negative equality impacts related to EPC reform were identified.

Stakeholders expressed concerns about moving to a webpage-based EPC from a PDF. They noted a need to maintain both digital and physical accessible EPCs for older adults and people with visual impairments.

Stakeholders highlighted the difficulty that some people may have in accessing and understanding the information contained on an EPC^[4]. This could be due to difficulty accessing web-based information, or due to visual or cognitive impairments.

Mitigating Actions

There is a clear need to ensure EPCs and the information they contain is made as easily accessible as possible. This is well-recognised by the Scottish Government. A programme of user-centred design and testing began in 2024 and will continue until the reformed certificate is introduced, to ensure that it is in an accessible format. The new EPC Register will meet all required accessibility standards.

Communications Strategy

EPCs and their reform are technically complex. A communications strategy to support the reform is in early development. This will aim to communicate the changes to people with protected characteristics and hard-to-reach groups.

Conclusion

The EQIA process has informed policy design, including the use of a significant period of user-centred design and testing to ensure the reformed certificate is accessible to users with different needs.

No changes to the policy were required based on equality findings, as we are confident that mitigation measures are already built into the design process which will continue to be developed.

The Scottish Government will monitor the development and implementation of the policy to ensure continued alignment with equality duties.