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

The Scope of the EQIA

Summary of EQIA Framing Exercise Results

The EPC reform will affect people, those involved in property transactions in Scotland. Therefore, an EQIA is required.

A framing exercise was held on 09 June 2025 to review evidence gathered to date. This involved economic advisers, social researchers, and policy officers to assess the scope and impacts of EPC reform.

The exercise concluded that a full EQIA is necessary due to the potential implications for equality rights, despite limited public input on equality issues during consultations.

Next Steps

The EQIA record summarises engagement since 2021. It considered both potential positive and negative impacts. It identifies any required mitigating actions. The EQIA Results will be published alongside the regulations.

Data, Evidence, and Consultation for EQIA

The Equality Evidence Finder was used to identify relevant data across all protected characteristics.

In existing literature, some evidence related to age and energy efficiency was found, however this does not directly relate to the reform of EPCs. The Scottish House Condition Survey 2019^[18] found Older households are less likely to live in energy-efficient homes than other groups.

Language Comprehension Accessibility Issue

The requirement for moderate English literacy to engage with EPC documentation may present barriers for individuals whose first language is not English, those with literacy-related disabilities, and others with limited literacy skills. These barriers may disproportionately affect people with protected characteristics under race, disability, and age. Mitigation measures such as translated materials, plain language summaries, and alternative formats should be considered.

Public Engagement Activities

A range of consultations, interviews, and workshops were conducted to explore equality impacts:

• Scottish Firms Impact Test interviews for the EPC Reform 2023 Consultation
  • Seven interviews were held with a range of organisations directly and indirectly impacted by EPC Reform, ranging from small traders and business enterprises through to those with global reach
  • All participants were asked 18 open questions including a focused question on equality rights
• Energy Performance Certificate reform consultation 2023 workshops
  • Domestic Reform (14 August 2023)
  • Non-Domestic Reform (29 August 2023)
  • Quality Standards & Assurance and the Future of EPCs (04 October 2023)
  • Consumers (11 October 2023)
  • Breakout sessions provided attendees the chance to consider equality rights issues
• BRIA interviews for consultation on lodgement fees, penalty charges and on-site audits
  • Eight interviews were held with a range of organisation directly and indirectly impacted by EPC Reform and ranging from small traders and business enterprises through to those with global reach
  • A dedicated interview section highlighted equality rights and related Island, data and socio-economic issues and welcomed feedback
• EPC lodgement fees and penalty charges consultation workshops
  • A dedicated consultation section highlighted equality rights and related Island, data and socio-economic issues and welcomed feedback
• Engagement with Age Scotland to consider issues for older people (which did not identify any negative impacts at this stage).
• Engagement with consumers through multiple rounds of user testing of redesigned certificates. The final website and EPC designs will meet all accessibility legal requirements.
• Responses to equality-related questions are documented in the EQIA Record.