Energy Performance of Buildings (Scotland) Regulations 2025 - EPC reform consultations: SG response - update

1. Overview

The Scottish Government is pleased to lay the new Energy Performance of Buildings (Scotland) Regulations 2025 in the Scottish Parliament on 10 October 2025. These regulations will come into force on 31 October 2026 and be the principal vehicle to deliver the reforms to Energy Performance Certificates (EPCs) set out in the Scottish Government’s January 2025 Response^[1] to its 2023 consultation on EPC reform.

Energy Performance Certificates (EPCs) are a long-established feature of the property market and provide information about the energy efficiency and emissions of a building. EPCs must be provided when a building is advertised for sale or for let to a new tenant. They are also required upon completion of construction of a new building, and must be displayed by certain large non-domestic buildings. They have formed part of the domestic Home Report since 2008 and help current and prospective tenants or owners to make informed choices when moving or considering improvements to their buildings.

The Scottish Government has consulted three times on EPC reform prior to laying the new Regulations (2021^[2], 2023^[3] and 2025^[4]). This update to the Government Response represents our final decisions on EPC reform.

Actions since issuing the January 2025 Government Response

In the period since the Government Response was published during January, the Scottish Government has:

• issued a technical consultation on reforms to EPC lodgement fees and penalty charges contained within the new Regulations
• completed its review of the current Operational Framework which specifies the requirements that Approved Organisations who accredit EPC assessors, must meet
• developed its initial versions of the new calculation methodologies for domestic and non-domestic EPCs which will be used to calculate the new ratings set out within the new Regulations
• used those initial versions of the calculation methodologies (the Home Energy Model and Simplified Building Energy Model) for domestic and non-domestic buildings, respectively, to model the likely performance of the building stock against the principal new ratings
• worked with independent building experts to consider the approach and logic by which the calculation methodologies will suggest potential improvements on the reformed EPC’s new Property Report that domestic building owners could make for their building to achieve better potential ratings (improved energy efficiency, reduced emissions and lower energy costs)
• conducted further user testing with consumers of the design of the new domestic and non-domestic EPC and Property Report, to ensure that it contains the most relevant information in a form that is accessible and well-understood
• completed a series of impact assessments and considered transitional impacts for sectors impacted by the new Regulations
• completed the discovery phase of work to set the requirements for building the new digital EPC Register (working with the UK Government) and is now moving into the alpha phase of project design and build

In addition, the Scottish Government has:

• issued a scoping consultation on a proposed Heat & Energy Efficiency Technical Suitability Assessment (HEETSA)^[5] as an optional step beyond the EPC, which recognises the limitations of the EPC as a basic, standardised assessment, and the potential need for a more bespoke, technical assessment of which energy efficiency and clean heat measures would, or would not be, suitable for a building (in particular those which are harder-to-decarbonise such as traditional buildings or tenements)
• consulted upon a potential minimum energy efficiency standard for the private rented sector (PRS MEES)^[6] which would use the reformed domestic EPC’s new Heat Retention Rating as a basis for setting the standard.

These consultations closed at the end of August 2025 and are still under analysis before Ministers take decisions on the way forward. They do not form part of the Government’s updated response on EPC reform, but are an important context for the reforms we are now making to EPCs.

Updates to the Government Response

In this update to the Government Response, we set out further information to help support stakeholders and Parliament in their scrutiny of the new Regulations. This update should be read together with the initial Response issued in January. This response sets out:

• A summary of the new Regulations, including the provisions which we are retaining, and those which are new, together with transitional arrangements for when the new regulations come into force, to mitigate potential negative impacts on particular parts of the property market (Chapter 2)
• The Government Response to the Technical Consultation on Energy Performance Certificate (EPC) Reform – Lodgement Fees and Penalty Charges^[7] (Chapter 3)
• The conclusions of our internal review of the current Operational Framework for Approved Organisations, and the next steps we will take to initiate a new process to appoint Approved Organisations to operate Accreditation Schemes under the new Regulations (Chapter 4)
• Our initial high level approach to specifying the new calculation methodologies which will be used to calculate the new EPC ratings and the logic by which they will suggest improvements on the new Property Report (Chapter 5)
• Revised bandings we intend to adopt for further more detailed modelling of the Heat Retention Rating on the new domestic EPC, following initial modelling using the new Home Energy Model. This will continue to meet our commitment that the new Band C should be as largely as possible ‘equivalent’ to the current EPC’s SAP-based Band C (Chapter 5)
• The approach we will take to presenting information on the Heating System Rating on the new domestic EPC, which we have updated following further user testing (Chapter 5)
• Some minor changes to the naming of the ratings on the non-domestic EPC (Chapter 5).

This updated Government Response can be read alongside the Business & Regulatory Impact Assessment (BRIA) published alongside the new Regulations, which contains further information on the performance of Scotland’s domestic and non-domestic buildings against the new ratings.

Next steps to support our EPC reforms ahead of the new Regulations coming into force

The Scottish Government intends to bring the new Regulations into force on 31 October 2026 – this is to give all stakeholders who are impacted, sufficient time to prepare for the changes. It also takes account of the UK Government’s intention for the new Home Energy Model and new cloud calculation-based EPC Register to be ready as the basis for issuing the new EPCs by October 2026. By working to align as far as possible on the timetable for bringing new reforms into force across the UK, both governments are working to support the continued operation of the EPC assessor market, which operates across the UK and is covered by some of the provisions of the UK Internal Market Act 2020.

Subject to Parliament approving the new Regulations, the Scottish Government will, in the period between the Regulations becoming law, and coming into force:

• engage with all stakeholders in the property market directly affected by the new Regulations (estate and lettings agents, landlords, conveyancing solicitors, surveyors, EPC assessors, lenders, local authorities) and with the general public through a communications and marketing campaign to ensure they understand the changes
• finalise and publish the full calculation methodologies for generating new EPCs (including rating bandings) and Property Reports as specified in Regulation 10
• complete the final stages of user testing of the new web-based EPC and Property Report design, to ensure it meets accessibility requirements
• undertake discovery work on the technical and design requirements for an interactive digital user interface to enable consumers to input occupancy and energy tariff information to adjust the EPC’s final user testing and develop user interface
• complete the design, build and testing of the new EPC Register and calculation methodologies, including working with Approved Organisations and the UK Government to ensure that EPC assessors are trained in their use and are familiar with the new EPC and Property Report and rating systems
• during Winter 2025-2026, once the detailed requirements of new Accreditation Schemes have been approved by Ministers, notify the market of the new enhanced Operational Framework and the new AO appointment process, inviting applications from existing AOs and new entrants to operate Accreditation Schemes. Applications will be appraised and, pending Ministerial approval, new appointment letters issued during summer/autumn 2026 ahead of the Regulations coming into force.
• work with Approved Organisations, informed by discussions with the Danish Energy Agency and Sustainable Energy Authority of Ireland, to design the new onsite audit and inspection requirements of Regulation 12.