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

4. Quality Assurance and Approved Organisation Framework

Throughout 2024 and 2025, the Scottish Government undertook a review of the operational governance of EPCs, which covered five main thematic areas:

• Appointment and management of “Approved Organisations” (AOs) who oversee the EPC assessor market in Scotland and the Operational Framework^[10] they adhere to;
• Quality assurance (audit and inspection for EPC assessors);
• Enforcement of regulations;
• Consumer care; and
• EPC assessor skills and qualifications.

Our review has highlighted that, fundamentally, the existing EPC market is functioning in terms of the requirements set out within the Framework: building owners can secure access to EPC assessors, property transactions can take place, government funding schemes can award grant support, and our AOs are – broadly – fulfilling their obligations under the existing Operational Framework. However, when wider issues beyond the scope of the Operational Framework are considered, a clear case can be made for enhancing the overall assurance of the EPC regime – and we have identified a number of key areas where we think reform is needed. These proposals have been discussed directly with industry (including each AO individually), and the feedback we have received has been positive.

Regulations 11 and 12 make provision for the Scottish Ministers to approve an Approved Organisation to operate an Accreditation Scheme which they have also approved. EPC assessors must be members of an Accreditation Scheme.

The requirements of Regulation 12 set out the minimum legal requirements of future Accreditation Schemes – which will form the new Operational Framework requirements for AOs in Scotland. The Scottish Government proposes to further develop the detail of the provisions required in advance of inviting organisations to apply to become Approved Organisations under Regulation 11 ahead of the new Regulations coming into force in October 2026.

During Winter 2025-2026, once the detailed requirements of the Accreditation Schemes have been approved by Ministers, we will notify the market of the new enhanced Accreditation Scheme requirements 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.

We intend in the first instance to introduce time-limited appointments for AOs to operate Accreditation Schemes. We could then move to longer terms of appointment where AOs have demonstrated competence and compliance. The terms of approval will also introduce more stringent requirements on AOs who perform poorly (including remediation measures and formal notification procedures of intention to withdraw approval in the event of no improvement).

Alongside this work on AO appointments we will also:

• strengthen ongoing audit and reporting requirements on AOs; specifically working with AOs to introduce smart auditing when the Regulations come into force and (with advice from the Danish Energy Agency and Sustainable Energy Authority of Ireland) develop and agree the onsite audit and inspection requirements (to be overseen by the Scottish Government) to complement the existing EPC assessor desktop-based audit regime (which we expect to be operational during 2027);
• implement a new Scottish Government-AO operational governance decision-making structure;
• work with local government to develop an enforcement ‘toolkit’ (as agreed with COSLA) that can be ready to support the new Regulations coming into force, while also continuing to explore potential options for a lead local authority model;
• improve the recording and sharing of information relating to complaints, and increasing consumer awareness around escalation measures available to them;
• work with the UK Government and other devolved administrations to review and update the UK-wide National Occupational Standards relating to energy assessment during 2025-26;
• work with the AOs and the UK Government to ensure that EPC assessors are trained in the use of the new EPC Register and calculation methodologies, and to ensure they are familiar with the new EPC and Property Report and rating systems;
• work with the AOs to develop long-term arrangements to ensure delivery of Scottish-focussed CPD training for EPC assessors;
• work with the UK Government and other devolved administrations through our Memorandum of Understanding on Energy Performance of Buildings to consider UK-wide arrangements for consumer protection and the future of EPC assessor training and skills.