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

Executive Summary

Purpose and objectives

The purpose of this Scoping Consultation is to set out the Scottish Government’s initial proposals for the scope of a HEETSA and seek stakeholder views on the overall concept of HEETSA and how it relates to other parts of the heat and energy efficiency retrofit landscape.

The Scottish Government’s objective in making these initial proposals is to safeguard consumers by developing a technical suitability assessment which ensures that building owners can understand which measures are appropriate, i.e. identify the ‘right’ measures when improving their energy efficiency and changing their heating systems.

Background

The Scottish Government has legally binding climate change targets to reach net zero by 2045, relative to 1990 levels, and Scotland’s buildings currently account for around a fifth of our emissions. To meet our statutory climate change and fuel poverty targets, we need our homes and buildings to be highly energy efficient, and ultimately to use clean heating systems.

Retrofitting existing buildings to be more energy efficient means they will use less energy. Less heat wasted through poor insulation means fewer greenhouse gas emissions are released into the atmosphere. In tandem, switching to clean heating removes direct emissions from heating our buildings.

The Scottish Government’s Heat in Buildings Programme is taking action to provide advice, support, and funding to building owners and tenants on retrofitting their properties. It will also see us introduce new legislation which will underpin that action.

We recognises that when these new legislative and regulatory requirements are introduced, building owners and tenants will want to understand the specific impacts for their properties, especially where regulations could require them to take action. That means that building owners will normally want to seek the opinion and advice of experts before committing to retrofit new heating systems or energy efficiency measures.

Why HEETSA

While Energy Performance Certificates (EPCs) are a long-established and integral part of the property market in Scotland, they have always had to ensure a large degree of standardisation. We recognise the limitations of this standardised approach. Reforms will make EPCs fit-for-purpose in providing basic, standardised information to building owners and tenants on the energy efficiency of their property.

However, the Scottish Government has received independent recommendations in reports from 2019 and more recently in 2025, on the need to establish greater government oversight of the emerging retrofit assessment market. To ensure effective and tailored advice about buildings is provided, we believe a technical suitability assessment is needed. Such an assessment will help building owners understand what improvement measures and heating systems are technically suitable for a property. This consultation focuses on the role this assessment could play in supporting building owners. It proposes that a Heat & Energy Efficiency Technical Suitability Assessment (HEETSA) be established as an optional additional step ‘beyond the EPC.’

Introducing a government-backed scheme would not remove consumer choice in the market, but would provide additional safeguards, for those consumers who wished to have them, of the assurance of government-backed methodologies and practitioners who were required to operate to government specified quality standards. The results of a HEETSA could be used by consumers to support their eligibility for government funding programmes, lenders’ products, or to evidence compliance with / exemption from regulatory standards. Our proposals for HEETSA could therefore also support the Scottish Government’s parallel consultation on a Private Rented Sector Minimum Energy Efficiency Standard (PRS MEES).

Proposed approach to HEETSA

An independent review for the Scottish Government has concluded that:

• existing assessment methodologies often produce generic recommendations and lack solutions tailored to individual buildings;
• critical factors like building condition, moisture risks, and long-term effectiveness are not recognised;
• there is limited assessor expertise and inconsistencies in assessment outcomes dependant on use of particular methodologies;
• the current assessment market for retrofit projects has significant gaps in evaluating the technical suitability of clean heating and energy efficiency measures.

The Scottish Government believes that the system currently used to ensure that EPCs are prepared consistently and to meet quality standards offers an existing, tried-and-tested model that could be extended to the wider retrofit assessment market – whilst doing so in a way that moves beyond the acknowledged limitations of the EPC. Our initial preference is to replicate the following three features used in the EPC system:

• government approval of methodologies
• government approval of professional standards (skills / qualifications)
• government specification of the format for certification / reporting results of the assessment

We are also exploring whether to include a fourth feature also used in the EPC system:

• government specification of the circumstances in which an assessment is required

Methodologies

We accept these conclusions and are scoping the design of HEETSA to focus on the assessment of dwellings for retrofit, and the identification and evaluation of improvement options. We propose that a technical suitability assessment methodology needs to include:

• Identification of the current state of elements within a building (both fabric and heating system)
• a method for comparative assessment of technically suitable options on a consistent basis for: energy efficiency measures; clean heating systems;
• a method for comparative assessment of the optimal balance between:
  • energy efficiency measures and clean heating systems (where relevant) in consultation with the occupants;
  • individual unit and ‘whole building’ energy efficiency measures in tenements;
  • individual unit clean heating systems vs ‘whole building’ communal clean heating systems in tenements;
• identification of any risks or barriers to retrofit measures

We propose a modular approach to consideration of these issues, depending on the particular building type or occupants.

We are not proposing that the technical suitability assessment would cover the design and specification, and installation of measures or the monitoring and evaluation of projects.

We also propose that the Scottish Government should approve methodologies as meeting the requirements of HEETSA, similar to the way we approve methodologies for meeting the requirements of an EPC, but with HEETSA allowing multiple retrofit assessment methodologies to be approved by government.

Skills

The Scottish Government has a clear aim to ensure that the assessors undertaking HEETSAs are properly skilled, qualified, and capable of offering technical advice. We want to ensure that assessors operate to the highest professional standards and can be trusted to make clear recommendations on the benefits of installing the ‘right’ systems and measures, and being aware of the risks of installing the ‘wrong’ ones.

Assessors therefore need to possess technical expertise and be suitably qualified to be able to undertake the assessment and make recommendations on which measures and systems are appropriate, and which are not. This will involve not only expertise and skill in working with HEETSA methodologies, but also the ability to engage with, and understand, the needs and behaviours of the building owners and occupants, to ensure that recommendations are applicable.

We recognise that the range of skills and qualifications available in the retrofit assessment market has developed considerably over recent years. Following the Each Home Counts review of the UK Green Deal, the industry developed PAS2035^[3] and PAS 2038^[4], and more recently, BS40104^[5].

There are a range of existing qualifications and prior experience which could cover many of the proposed dimensions of HEETSA. We are now seeking stakeholder views on the skills, qualification and accreditation processes which would be needed to ensure that assessors were able to offer detailed advice to building owners on technical suitability of heat and energy efficiency retrofit measures.

Certification and Reporting

The Scottish Government wants to ensure that when a technical suitability assessment has taken place, that the findings and the evaluation of improvement options are made available to consumers and presented in a consistent manner. We think that it is important for consumers to have confidence that a HEETSA assessment is comprehensive, considers a required range of issues, and presents these in a standardised way. The Scottish Government would work with digital experts and consumer groups to design a format for a HEETSA certificate or report to create a format which can be easily understood and then acted upon.

We are seeking views from stakeholders on whether a standardised certificate or report for HEETSA is needed and what the benefits or challenges could be in this.

When a HEETSA would be needed

We think that HEETSA is likely to be needed in the following circumstances:

• when a building owner chooses to act on a voluntary basis to make improvements to their building and wants more detailed technical advice (possibly following suggested potential improvement options via the reformed EPC)
• when it is a condition of eligibility for a government funding programme to undertake a more detailed assessment of which energy efficiency measures and clean heating systems would be technically suitable for the building
• when a building owner is required to comply with proposed regulatory standards such as potential Private Rented Sector (PRS) Minimum Energy Efficiency Standard (MEES), and is seeking more detailed technical evidence which could be used to support a request for exemption from the standard, flexibility in meeting its requirements, or an appeal.
• When in communal buildings, owners wish to seek more information on communal options for fabric improvements or potential to move to communal heating systems where individual clean heating options may be limited.

Legal Basis

The Scottish Government has powers under Part 10 of the Energy Act 2023^[6], which we will use as the legal basis for regulations covering the production of Energy Performance Certificates and the assessment methodology and assessor skills requirements which underpin them. These powers would also allow the Scottish Ministers to make regulations covering how buildings were to be assessed and certified, and improvements to be identified and recommended, under HEETSA. They could also be used to specify the circumstances in which HEETSA was required – if stakeholders felt this was necessary, or the Scottish Government could instead issue guidance.

We are seeking stakeholder views on what, if any, legal basis is needed to establish HEETSA, and views on the potential impacts of it being a statutory or non-statutory process.