Heat and Energy Efficiency Technical Suitability Assessment (HEETSA): scoping consultation

Ministerial Foreword

Over 15 years on from the introduction of Energy Performance Certificates (EPCs), the system is now a core part of understanding and helping make informed choices in relation to a property’s energy efficiency. The Scottish Government wants to continue to ensure that building owners, tenants, landlords and those who might be considering purchasing or renting a building, have even better quality, reliable and accurate information on the building’s energy performance and emissions from its heating system.

That is why we are reforming EPCs and I am pleased to be able to lay new regulations this autumn which will bring an improved rating system and more relevant information for consumers into force during 2026.

I am confident that our reforms will result in a better quality EPC, and ensure consumers can make more informed choices when it comes to important decisions such as whether to insulate their walls or increase the insulation in their loft, or when considering changing their heating system.

But our EPC reforms can only go so far. The Scottish Government has been clear in our consultations on EPC reform, and our response to these, that there are limits to what the EPC can achieve as a standardised, non-intrusive assessment.

The EPC does not take account of things like the condition of a building’s fabric (i.e. walls, roof, windows). It makes certain assumptions about features like wall or floor insulation, and it does not take account of the building’s occupants and their behaviour. The potential improvements suggested by an EPC are based on standardised modelling, and may not necessarily be technically suitable for the building.

We recognise that many stakeholders have expressed genuine concerns during our EPC consultations, and the related consultation on a Heat in Buildings Bill, about the risk that building owners could act to install improvement measures suggested by an EPC which would not be technically appropriate for the building.

That is why we will be clear on the redesigned certificate that the potential improvements suggested by an EPC are always an initial signpost towards more detailed assessment and technical advice where needed. The EPC will clearly state that building owners should always seek further advice from a suitably qualified professional – such as a surveyor or heating engineer or architect – before installing particular measures.

We want to avoid any potential unintended consequences when installing energy efficiency measures and to strengthen confidence in assessments. It is therefore vital that we ensure that assessments are of the highest quality.

That is why I am pleased to set out in this consultation, the Scottish Government’s high level proposals for a Heat & Energy Efficiency Technical Suitability Assessment (HEETSA). This would be a government-authorised and approved process, beyond the EPC, for conducting bespoke assessments of buildings to confirm which energy efficiency and clean heat measures would be technically appropriate and which would not.

Happily, we are not starting from scratch. Initial pre-scoping research that we have commissioned^[1], shows that there is already an emerging retrofit assessment market, where consumers are already accessing assessments from professionals operating with a range of schemes and methodologies such as PAS:2035, BS40104, and the RICS Residential Retrofit Standard.

That research also shows that there are gaps in the market and a need to develop further methodologies and qualifications, particularly in areas such as assessment of the technical suitability of clean heating systems, or of communal measures and heating systems in buildings such as tenements.

It makes a clear recommendation on the need to protect consumers from the risks of poor quality assessment and poor quality advice, which could subsequently lead to poor quality installation. It therefore recommends that there would be genuine benefit to consumers from government establishing a process for authorising and approving methodologies and practitioners, and of commissioning approaches which can fill any gaps.

The Scottish Government welcomes the development of this growing market as a vital source of additional consumer advice beyond the EPC. We now want to seek further evidence and views from stakeholders on how we can ensure that there is a comprehensive range of methodologies and suitably skilled professionals who can offer assessment of the technical suitability of energy efficiency and clean heating system retrofit measures to consumers.

This work could also be important in supporting the proposed Private Rented Sector Minimum Energy Efficiency Standard (PRS MEES)^[2] on which the Scottish Government is consulting in parallel to HEETSA.

I am pleased that we now have the opportunity to work with an emerging market and to help it grow to meet consumer demand as we see building owners improve their building’s energy efficiency and reduce emissions to meet our net zero targets.

I look forward to your engagement with this consultation.

Alasdair Allan

Minister for Climate Action