Energy Efficiency Standard for Social Housing post 2020: interim guidance for social landlords

3. What does “temporarily put on hold” mean?

3.1 Temporarily put on hold means:

3.1.1 The 2020 EESSH milestone, or EESSH1, continues to apply.

• The EESSH1 milestone, which social housing should meet since the end of December 2020, continues to apply.
• There are a number of exemptions which landlords can apply to their stock where it is not possible to meet these targets.
• A house must either meet EESSH1 or be exempt from it, to comply with the Scottish Housing Quality Standard.

3.1.2 Landlords are not required to show progress towards EESSH2 milestones.

• Landlords are not required to show that stock meets or is progressing towards EESSH2 milestones in reporting their performance for the reporting years up to March 2027.

3.1.3 SHR has paused collection of EESSH2 data.

• The Scottish Housing Regulator has advised landlords that it will pause the collection of data on EESSH2 until after the conclusion of the Scottish Government’s review when it will consult on indicators for the Annual Return on the Charter that are appropriate to the outcome of the review. It has advised that for now, it will focus on the quality of landlords’ housing condition information and the effectiveness of asset management strategies. So, during business years in which the review is taking place, landlords are not required to submit to the regulator data on the overall performance of their housing stock against either the 2025 or 2032 milestones.
• Landlords should, however, continue to collect data for their own use, including on the following:
• the number of properties in each EPC band at the end of each year; and,
• on the value of investment in energy efficiency improvements in each reporting year.

3.1.4 The date when new 2025 EPC regulations^[8] will be brought into force has been delayed from 31 October 2026 due to the decision of the UK Government to delay its timeline for EPC reform. This is to allow more time to finalise development of the Home Energy Model and other technical infrastructure to allow EPC assessors to be trained to issue new certificates. The Scottish Government shares this infrastructure with the UK Government and our 2025 Scottish regulations are therefore impacted by this delay. In the meantime, the 2008 regulations remain in force until further notice.

3.1.5 The UK Government is working with the devolved administrations and EPC assessor industry to agree a new shared implementation timeline for EPC reform by summer 2026. This will allow the 2025 Scottish EPC regulations to be amended with a new in-force date before 31 October 2026. The new in-force date is now expected to be in the second half of 2027.. When the 2025 regulations finally come into force, landlords will be able to begin collecting information for their properties using the new EPC ratings.

3.1.6 There will be a one year transition period from the point at which the regulations come into force. During this transition period the regulations will continue to allow 2008-style EPCs to be used when advertising properties for let. After the one year transition period, the new 2025-style EPC will be required. The Scottish Government will collaborate with social landlords to agree procedures for data collection and updating of their stock profile during the transition to using the new certificates. We will also work with the sector to develop and introduce new simplified procedures for updating EPCs more frequently to mitigate potential additional effort associated with the reduced EPC validity period of the 2025 regulations.