Energy Performance Certificate Reform: updates

24 August 2026 update

Following extensive engagement with the UK Government and with the EPC assessor industry on the implementation of EPC reform and the delayed launch date for new EPCs in England and Wales and the impacts of this on Scotland, regulations introducing new-style EPC certificates, validity periods and rating systems in Scotland will now be amended to come into force on 30 April 2028. This applies to both domestic and non-domestic EPCs and gives both consumers and industry certainty around the future of EPCs in Scotland.

The Scottish Government can confirm that the majority of the Energy Performance of Buildings (Scotland) Regulations 2008 and current EPC system will now remain in place until Spring 2028, at which point the outstanding provisions of the Energy Performance of Buildings (Scotland) Regulations 2025 will enter into force. We will engage with all stakeholders in the property market and with the general public through a communications and marketing campaign to ensure they understand the changes and the updated transitional arrangements, which are detailed below.

Timeline for reform and UK-wide shared implementation plan

This revised timeline for reform reflects the shared implementation plan that has been agreed with the UK Government and with the EPC assessor industry since announcing a delay to reforms during March 2026. We believe there is a credible timeline for reform which ensures that there is sufficient time for the UK Home Energy Model and supporting infrastructure to be finalised and for the assessor industry to then be trained and ready to implement the reforms so that they launch successfully in the property market.

The shared implementation plan also allows for the work that the Scottish Government has already set in train (to design, build and test the new EPC Register, statutory calculation methodology, design and implementation of new onsite audit regime and establishment of the Scottish EPC Accreditation Scheme) to continue in parallel before the new regulations come into force.

The plan will see the Scottish and UK Governments taking a phased transition to ‘go-live’ of EPC reform across the UK. We will work with industry and stakeholder to plan and communicate the full details as the programme progresses.

The UK Government has publicly committed to implementing its reforms during ‘the second half of 2027’ and is continuing to work with industry on the detailed implementation arrangements. The UK Government has not reached final decisions on this at the point at which the Scottish Government has to introduce the amending regulations to prevent the 2025 Regulations coming into force on 31 October 2026.

The Scottish Government has therefore decided to plan for the implementation of new EPCs from April 2028 to provide additional contingency within its implementation timetable. This reduces the risk of further amendment to the Scottish regulations, and the uncertainty that this would create for the property market and impacted stakeholders.

In all other respects, the shared implementation plan which will see HEM finalised, the new EPC register and Energy Calculation as a Service (ECaaS) infrastructure built and tested, and the assessor industry trained and ready to issue the new certificates, will remain the same across the UK.

The Scottish Government is committed to investing in the elements of the programme to support consumers. As such, lodgement fees will rise as planned, on 31 October 2026, which will ensure technical and operational infrastructure is ready, and consumers are further protected by the development of an effective audit regime. This work is already in-train and needs to progress in alignment with the UK Government’s development timeline. This means that it will be tested and available for the EPC assessor industry to use for training during 2027, in order to be ready for go-live, in Scotland, in April 2028.

Substance of amendment to the 2008 and 2025 regulations

The Energy Performance of Buildings (Scotland) Amendment Regulations 2026 make minor amendments to the Energy Performance of Building (Scotland) Regulations 2008 and the Energy Performance of Buildings (Scotland) Regulations 2025:

• To allow for the lodgement fee which may be charged by the Keeper of the Register (the Scottish Ministers) for registration of an EPC to increase as already planned on 31 October 2026 from £2.60 to £6.00 for domestic properties and from £12.10 to £15.50 for other properties.
• To amend the date on which the Energy Performance of Buildings (Scotland) Regulations 2025 come fully into force from 31 October 2026 to 30 April 2028 and to alter the dates of saving and transitional provisions in accordance with the amended dates.

There is no other change to the substance of the reforms on which we previously consulted during 2021, 2023 and 2025, and on which we set out our final Government Response in October 2025. The remainder of the Energy Performance of Buildings (Scotland) Regulations 2025 will remain as approved by the Scottish Parliament in December 2025.

Provisions within the 2025 Regulations relating to the establishment of the new Scottish EPC Accreditation Scheme and to appointment of Approved Organisations (Regulations 11 and 12) came into force on 1 January 2026 and these provisions remain in-force. The Accreditation Scheme remains open for new applicants who will be appointed in advance of the remainder of the 2025 Regulations, as amended, coming into force on 30 April 2028. This allows sufficient time for new and existing participants in the market to secure their approval and to plan for their business.

Transitional provisions

During our stakeholder engagement and drafting of impact assessments accompanying the new Regulations, the Scottish Government has identified the need to mitigate potential negative impacts on particular parts of the property market. We have therefore made provisions within the new Regulations (Regulation 38), as amended, for transitional arrangements. The transitional arrangements within the 2025 Regulations, as amended, are now as follows:

Buildings for sale or let (other than short term lets)

Regulation 5 makes provisions for a valid EPC and property report to be provided both when the building is advertised for sale or let (to prospective buyers or tenants) and when it has subsequently been sold or let (to the buyer or tenant).

We recognise that EPCs are provided as part of a live property market in which transactions will already be underway on the day on which the new Regulations come into force, or where landlords or sellers may have already commissioned and paid for EPCs in advance of advertising their property for sale or lease or may be relying on an existing EPC in order to complete their transaction.

The Scottish Government wants to minimise the risk of any disruption to the smooth functioning of the property market and therefore Regulation 38, as amended, makes transitional arrangements which provides for up to a one-year grace period for properties being sold or let.

These transitional arrangements on buildings for sale or let cover all existing domestic and non-domestic buildings, other than short term lets, particular large non-domestic buildings frequently visited by the public, and newly constructed buildings (see provisions for these other types of properties, below).

The Regulations, as amended, specify a one year ‘relevant period’ within which the transitional arrangements apply:

• The relevant period is, at maximum, one year, from 30 April 2028 to 30 April 2029, but ends earlier if a property is sold or let before 30 April 2029.

The transitional provisions in Regulation 38, as amended, therefore allow that:

• between 30 April 2028 and 30 April 2029, properties being sold or let may continue to use either valid EPCs and recommendation reports issued under the 2008 Regulations or valid EPCs and property reports issued under the 2025 Regulations, as amended.

But they also restrict the length of the one-year transition period for properties sold or let within that one-year period, in the event that they are sold or let again:

• an EPC and recommendation report issued under the 2008 Regulations may be used for the sale or let of a property after 30 April 2028, but if a property is sold or let again within the one year transition period, a new-style EPC and property report issued under the 2025 Regulations, as amended, will then be required.

Regulation 38, as amended, specifies a clear backstop date for the end of the transition:

• after 30 April 2029, only the new-style EPC issued under the 2025 Regulations, as amended, will be allowed for sale or for let.

In practice, from 30 April 2028 onwards, when a building owner commissions a new EPC, assessors will only be able to issue new-style EPCs meeting the requirements of the 2025 Regulations, as amended, but if an old-style EPC meeting the requirements of the 2008 regulations is still valid during the transition period, it can still be used until the end of the transition period, or completion of the sale or let whichever comes first (i.e. the old-style EPC can be downloaded from the EPC Register and used in a property transaction).

From 30 April 2028 to 30 April 2029, we will therefore see diminishing numbers of EPCs previously generated under the 2008 Regulations being used in property transactions. Conversely, we will see increasing numbers of EPCs issued under the 2025 Regulations, as amended. From 30 April 2029, only EPCs issued under the 2025 Regulations, as amended, will be allowed.

The Scottish Government believes this represents a fair transition which will mitigate the following particular impacts:

• a potentially significant increase on day one in the number of EPCs that would be needed for properties which are continuously advertised, such as for short term lets, allowing hosts adequate time to obtain a new 2025-style EPC
• a potentially significant increase in year one in the number of EPCs that would be needed for private rented sector properties, where around 31% of the stock turns over per year, allowing landlords more time to obtain a new 2025-style EPC when advertising a new let
• day one and year one pressure on the assessor market as it adjusts to higher levels of expected demand for new certificates (outlined in the Business & Regulatory Impact Assessment which accompanies the Regulations), allowing demand to be more evenly spread across year one and two from the Regulations’ 30 April 2028 in-force date

By amending the 2025 Regulations 18 months in advance of them coming into force, and by allowing the one-year transition period for sales and lets after they come into force, the Scottish Government believes that it is giving sufficient time for property market actors to adjust to the new requirements. We will engage with all stakeholders in the property market and with the general public through a communications and marketing campaign to ensure they understand the changes. The one-year transitional period will allow more time for the new rating system and redesigned certificate to become embedded and understood within the market before it is required for every property transaction.

Short term lets

We recognise that short term lets are normally continuously advertised and therefore on day one of the new Regulations, as amended, it would not be possible for all hosts to immediately obtain a new-style EPC issued under the 2025 Regulations, as amended. Short term let properties will therefore have a full one-year grace period in which to obtain a new-style EPC. This means that:

• between 30 April 2028 and 30 April 2029, short term let properties may continue to use either valid EPCs and recommendation reports issued under the 2008 Regulations or valid EPCs and property reports issued under the 2025 Regulations, as amended.
• after 30 April 2029, only the new-style EPC and property report issued under the 2025 Regulations, as amended, will be allowed for the letting of a building as a short term let.

As outlined in the BRIA accompanying the Regulations, as amended, this grace period allows the sector to have a more evenly spaced transition to the new-style EPC for Scotland’s approximately 30,000 short term lets, which should minimise any potential disruption to the market.

Large non-domestic buildings (frequently visited by the public)

Regulation 13 makes provision that certain large non-domestic buildings which are frequently visited by members of the public must always display a valid EPC in a prominent place that is clearly visible to visiting members of the public.

The Scottish Government recognises the need to mitigate the risk that on day one, several thousand large buildings would immediately require a new EPC. Given the significantly higher costs of preparing an EPC for these more complex non-domestic buildings, and the smaller numbers of active non-domestic assessors available within the market, we do not believe that it would be possible to issue new EPCs at a rate beyond current market capacity.

Regulation 38, as amended, therefore makes provision that buildings which are affected by the requirements of Regulation 13 can continue to use the old-style EPC they currently display under the 2008 Regulations until the end of its validity period, or until 30 April 2033.

This means that if the validity of an EPC issued under the 2008 Regulations expires before 30 April 2033, it will be required to use a new-style EPC. After 30 April 2033, all building owners or occupiers covered by Regulation 13 will need to obtain and display a new-style EPC meeting the requirements of the 2025 Regulations, as amended.

By allowing this five-year grace period, the Scottish Government believes that this will help to smooth the transition for these large and often complex non-domestic buildings to obtain a new EPC.

As with other parts of the property market, the Scottish Government will engage with building owners and occupants covered by Regulation 13, to ensure that they understand the requirement to have a new EPC before the new Regulations, as amended come into force.

New construction

Regulation 6 sets out the requirement for EPCs to be provided upon construction of a new property. This replaces the existing requirements in standard 6.9 of Schedule 5 of the Building (Scotland) Regulations 2004 and brings all legal requirements for the provision of EPCs into one set of regulations.

Developers of new buildings completed on or after 30 April 2028 will be required to give a copy of a valid EPC and Property Report that meets the requirements of the 2025 Regulations, as amended, to the owner of the building within seven days of submitting a completion certificate to a local authority verifier.

As with other parts of the property market, the Scottish Government will engage with developers of new buildings and with local authorities to ensure that they understand the new requirements of Regulation 6 before the new Regulations come into force.

User interface

The Scottish Government’s October 2025 Government Response set out that we would 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. This discovery work is now complete, and we are moving into the implementation stage of the work. We intend for the full design and build of the interactive user interface to complete in 2028.

Updated next steps

Once Parliament has scrutinised and agreed the amending regulations, the Scottish Government will undertake the following next steps:

• engaging further with stakeholders who are directly affected by the regulations: in the Approved Organisations, assessor businesses, estate and lettings agents, conveyancing solicitors, local authorities, landlords, mortgage lenders;
• communicating the changes to the wider public to explain the new rating system and the redesign of the certificate;
• working with government funding programmes and regulatory regimes which rely upon EPCs, to ensure they can take into account changes to the rating system within the operation of their schemes;
• working with the Approved Organisations and EPC assessor community to ensure that all assessors receive training on the new regulations and changes to the certificates and rating systems;
• working with the Approved Organisations, UK Government and EPC assessor community to ensure that assessors receive training on, and testing of, the new calculation software which will be used to record and process data gathered by assessors, using the new Home Energy Model and updated SBEM calculation methodologies;
• commissioning and developing the technical infrastructure (the EPC wrapper) required to implement Scottish EPC reform policy using the Home Energy Model
• completing the 2nd stage joint review of National Occupational Standards (NOS) for EPC assessors with the UK Government and other devolved administrations, and exploring how to strengthen skills and qualifications requirements for EPC assessors operating across the UK internal market through an independent review of the current skills landscape;
• completing user testing of the redesigned EPC;
• testing and launching the new EPC Register, working with the UK Government on the technical infrastructure, to be funded through EPC lodgement fees;
• evaluation and (re)appointment of existing and potential Approved Organisations to the new Scottish EPC Accreditation Scheme, by the Scottish Ministers, when the new regulations come into force;
• establishing a new onsite audit and inspection function within the Scottish Government, to be funded through EPC lodgement fees;
• continuing to work with the UK Government and other devolved administrations to provide UK-wide governance oversight to the assessor market through operation of our joint Memorandum of Understanding;
• continuing to work with industry and stakeholders to develop and pilot a method for a simplified procedure to produce EPCs, and define the circumstances in which this is appropriate;
• developing methodologies to address gaps in the current EPC in assessing the technical suitability of fabric and heating measures; and
• developing an interactive user interface to help consumers make better use of the data gathered through EPC assessments, including through customising the inputs and assumptions to reflect their circumstances and see how improvements might benefit them.