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

Step Two – Gathering data and identifying stakeholders

Available Data

The following publications provide an insight into the energy and assessment landscape across Scotland’s islands:

• The cost of remoteness - reflecting higher living costs in remote rural Scotland when measuring fuel poverty^[22]
• The Scottish House Condition Survey^[23]
• The Scottish EPC Register^[24]
• Fuel Poverty Strategy Islands Communities Impact Assessment^[25]
• Heat in Buildings Strategy Island Communities Impact assessment^[26]
• The New Build Heat Standard Islands Communities Impact Assessment^[27]

The Scottish EPC Register was analysed to identify the number of active and registered EPC assessors on islands.

This analysis suggests there is a high number of EPC assessors across the Scottish Island communities relative to their population. While highly variable, the estimated number of EPCs carried out per assessor in 2024 was higher for those based in island communities than on the mainland.

The analysis of consultation responses^[28] did not identify any islands’-specific impacts directly related to the proposals to reform of EPCs. Respondents to the consultations included:

2021 Domestic Energy Performance Certificates reform consultation:

• Age Scotland
• Argyll and Bute Council
• Citizens Advice Scotland
• Existing Homes Alliance Scotland
• Hjaltland Housing Association Ltd
• Historic Environment Scotland
• Scottish Land & Estates
• Shetland Islands Council
• The National Trust for Scotland

2023 Energy Performance Certificate reform consultation:

• Argyll and Bute Council
• Association of Scotland’s Self-Caterers
• Central Association of Agricultural Valuers
• Energy Action Scotland
• Existing Homes Alliance Scotland
• Heating and Hotwater Industry Council
• Hjaltland Housing Association Ltd
• Historic Environment Scotland
• Historic Houses Scotland
• Islay Energy Trust
• Scottish Association of Agricultural Arbiters and Valuers
• Scottish Federation of Housing Associations
• Scottish Land & Estates
• Shetland Islands Council

2025 Scottish Energy Performance Certificate Register Lodgement Fees and Penalty Charges consultation:

• Shetland Islands Council

In addition, we have engaged with businesses directly through one to one interviews, including during the formal consultation period. We started the business interviews in 2023 and they continued into 2025. Businesses interviewed ranged from SMEs to larger companies and international organisations. They covered multiple sectors including Approved Organisations; surveyors; architects; landlords; energy focused organisations; Local Authorities; financial industries and heating system manufacturers.

The interviews included specific questions seeking input into whether the effects of the EPC reform proposals would differ in different areas in Scotland.

Several consultation responses indicated that costs to retrofit energy efficiency and heating measures into buildings on islands are higher than in other areas in Scotland. This issue is not considered to be in scope for this ICIA as the ICIA relates only to the EPC regulations, which require assessments to be undertaken so that EPCs can be produced at specified trigger points of sale, lease, construction or for large buildings that are accessed by the public. These regulations do not require building owners to undertake work to then retrofit particular energy efficiency or heating measures, nor to reach a particular rating.

Other evidence gathered including through the EPC enquiries mailbox has highlighted difficulties in commissioning EPCs for some people on some islands, particularly where assessors would be required to travel between islands in order to complete the assessment. This issue is considered to be in scope for this ICIA.

Key Stakeholders

The key stakeholders were identified are as follows:

• Assessors and Approved Organisations (AOs) for domestic and non-domestic sectors
• Owners of domestic and non-domestic buildings (including landlords, owner-occupiers, and business owners)
• Registered Social Landlords
• Local Authorities
• Tenants
• Representative organisations (e.g. Scottish Land and Estates)

Section 0 below sets out the engagement conducted with these groups.

In addition, the Scottish Government convened an External Reference Group to provide feedback on planned reformed. This group included members from Consumer Scotland (to identify issues related to consumers), and all Approved Organisations and an EPC Assessor representative body (to identify issues related to the EPC industry).

Early engagement

The findings of early engagement and literature review suggest several relevant potential issues that are likely to be specific to, or more acute within, island communities. These are:

• Remoteness and consequent lack of assessors;
• Variation between islands in availability of assessors;
• Cost of assessment due to increased travel costs;

Additionally, differences in the housing stock could mean that the results of EPC assessments after reforms could impact islands due to:

• The high proportion of traditional buildings on islands (including solid wall buildings);
• Housing off the gas grid is more common in island areas^[29]

Difference between Islands

As set out in ‘Available Data’ previously, there is significant variation in the number of EPC assessors located on different islands. This would be expected given the variation in population between islands.

Existing Mitigations

The current EPC regulations set out a defence from prosecution for non-compliance with specified requirements where an EPC is unobtainable “despite all reasonable efforts and enquiries by the [building] owner”^[30]. This mitigates potential logistical issues for Island communities if, for instance, an assessor is unable to travel to or between islands due to transport disruption. This provision is being retained by the new regulations.