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

Step Three – Consultation

Previous Engagement

In 2021, an ICIA was undertaken as part of the Scottish Government’s Heat in Buildings Strategy^[31].

Following a desktop literature review and direct engagement with representatives from Highlands and Islands Enterprise (HIE), a number of challenges were identified relating to island communities. The focus was predominantly on the existing building stock across Scotland’s islands:

• Supply chain and skills, including the availability and supply of workers, a lack of accommodation for workers not resident on the islands, and challenges in obtaining parts for service and maintenance.
• Weather disruption, which could impact project timescales and costs.

The Scottish Government operates an email mailbox (EPCenquiries@gov.scot) through which enquiries from the public are received.

Further engagement was conducted through the aforementioned consultation periods.

EPC Reform Public Consultations

The Scottish Government has consulted three times on various aspects of EPC reform:

• 2021 - Domestic Energy Performance Certificates (EPC) reform: consultation - gov.scot. The consultation analysis summary report^[32] did not identify any issues relevant to this ICIA.
• 2023 - Energy Performance Certificate (EPC) reform: consultation - gov.scot. The consultation analysis^[33] did not identify any issues relevant to this ICIA.
• 2025 - Energy Performance Certificate reform – lodgement fees and penalty charges: technical consultation - gov.scot. The consultation analysis did not identify any issues relevant to this ICIA.

Officials have engaged openly throughout the consultation periods through public workshops, hosted online to encourage participation from those outside the central belt. Officials record notes from the consultation events which were taken into account in the ICIA. These events include:

• 14 September 2021 Domestic EPC Reform Consultation Workshop
  • No islands-specific issues were raised.
• 14 August 2023 Domestic EPC reform workshop
  • A participant raised concerns around the need for grid reinforcement for the uptake of electric heating. This was not considered directly relevant to EPC reform.
• 29 August 2023 Non-Domestic EPC reform workshop
  • No islands-specific issues were raised.
• 04 October 2023 EPC quality assurance workshop
  • No islands-specific issues were raised.
• 03 March 2025 EPC technical consultation workshop 1
  • A participant noted that additional audits could have an increased cost on islands. However this was not considered in scope as the Scottish Government will meet the cost of additional on-site audits.
  • A participant noted that the cost of an EPC is generally higher on islands.
• 10 March 2025 EPC technical consultation workshop 2
  • A participant noted that additional audits could have an increased cost on islands. However this was not considered in scope as the Scottish Government will meet the cost of additional on-site audits.
• 13 March 2025 EPC technical consultation workshop 3
  • A participant noted that additional audits could have an increased cost on islands. However this was not considered in scope as the Scottish Government will meet the cost of additional on-site audits.

16 one-to-one interviews were conducted by the Scottish Government with businesses from 2023 to 2025. While the interviews did not solely relate to the ICIA, they included questions about the positive or negative impact of the proposals on rural and island areas and communities around Scotland. The interview participants included businesses of all sizes, including business operating on Scottish islands. The data was analysed and keyword searched for statements by interviewees relating to islands.