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

Section 2: Engagement and information gathering

Engagement approach

As we continue our policy development on HEETSA, the Scottish Government is conducting our engagement in several phases:

• 2023-24 – pre-scoping evidence-gathering:
• Consultation on the Heat in Buildings Bill proposal of the initial concept of HEETSA (November 2023-March 2024)
• Additional evidence-gathering workshop with informed experts to discuss and critique the initial concept for HEETSA (July 2024)
• Independent research report on scope of HEETSA^[4] (May 2025), with workshops held with wide range of stakeholders to inform this (December 2024)
• 2025 – scoping approach:
• Initial public consultation on scope of HEETSA (June to August 2025)
• consultation analysis and finalisation of detailed proposals for Ministerial agreement (autumn-winter 2025-2026)
• 2026 – preferred approach:
• final consultation on preferred approach (summer 2026)
• Ministerial decision on final approach to HEETSA (autumn 2026)
• 2027 – creation of framework:
• laying any regulations or developing guidance for HEETSA requirements (winter 2026-27)
• process for bodies to apply for Ministerial approval of methodologies and approval of professional skills and qualifications (if adopted) (summer and autumn 2027)
• 2028 – implementation of framework:
• HEETSA guidance or regulations in force (beginning of 2028 – this would allow HEETSA to support things like exemptions when the proposed PRS minimum energy efficiency standard regulations come into force)

Internal Scottish Government engagement and engagement with wider public sector

Internal Scottish Government engagement

The Scottish Government has an established internal working group for heat in buildings assessment, which covers both EPC reform and the development of HEETSA. This involves colleagues from the Scottish Government’s:

• Directorate for Energy & Climate Change (teams responsible for Heat in Buildings regulation (such as the proposed private rented sector minimum energy efficiency standard and Social Housing Net Zero Standard), Heat in Buildings delivery programmes, (such as Warmer Homes Scotland and Area-Based Schemes), Heat Networks and public sector heat decarbonisation;
• Directorate for Local Government & Housing (teams responsible for Building Standards, Housing (such as colleagues leading the review of Home Reports), Fuel Poverty)

UK Government / Devolved Administrations

The Scottish Government engages formally with the UK Government and devolved administrations through existing working groups on EPC reform and through the Memorandum of Understanding (MoU) which is currently being finalised. The UK Government is also an observer on our assessment External Reference Group (ERG) (see below) and Monmouthshire Council (from Wales) is a member of our assessment subgroup of the Heat in Buildings Strategic Advisory Group (SAG) (see below). UK Government officials also participated in the initial stakeholder expert workshop on HEETSA in July 2024.

Wider Public Sector

We have engaged with the wider public sector throughout the initial pre-scoping evidence-gathering phase, with the workshop in July 2024 attended by representatives of Historic Environment Scotland, Fife Council, Trading Standards Scotland and Skills Development Scotland. During the evidence-gathering in December 2024 for the independent report on HEETSA, a wider range of public sector representatives were involved. This included local authorities (Aberdeen City, East Lothian, Highland, Midlothian, Scottish Borders), COSLA, Consumer Scotland, Historic Environment Scotland, Scottish Futures Trust, Skills Development Scotland, South of Scotland Enterprise, and Trading Standards Scotland. COSLA, Consumer Scotland and the Association of Local Authority Chief Housing Officers (ALACHO) are also members of our heat in buildings assessment External Reference Group which meets regularly and allows us to keep key stakeholders informed of policy development on EPCs and HEETSA. The Scottish Futures Trust and Monmouthshire Council are also members of our Assessment Subgroup of the Heat in Buildings Strategic Advisory Group (SAG) (see below).

International

The Scottish Government has formal relationships with the Government of Denmark (through a memorandum of understanding which covers heat in buildings) and with the Government of Ireland (with the Sustainable Energy Authority of Ireland being members of our Assessment Subgroup of the Heat in Buildings Strategic Advisory Group (SAG) (see below). We are continuing to seek their views and input into the development of HEETSA.

Business & Third Sector engagement

Given the breadth of business and third sector groups impacted by our proposals for EPC reform and for HEETSA, the Scottish Government has also established formal working groups at official level, to provide a forum for ongoing stakeholder engagement and challenge to help refine our proposals – an External Reference Group and an independently-chaired Assessment Subgroup of the Heat in Buildings Strategic Advisory Group.

External Reference Group

The External Reference Group ensures that those working within the current EPC system (assessors, approved organisations, surveyors issuing Home Reports, building regulations officers/ local authority officers, etc.) are kept informed on progress and able to give views (i.e. to advise, inform, and discuss). It meets regularly throughout the year when relevant, to be kept abreast of progress in development of the regulations and will continue to do so when they are implemented.

This group is made up of the following external stakeholders (including wider-public sector representatives):

• All six EPC Approved Organisations^[5] (representing the businesses directly impacted by the regulations, which govern the terms of their appointment, and those of their 3,500 members in Scotland)
• Proficiency (trade body representing domestic and non-domestic EPC assessors)
• Property Energy Professionals Association (PEPA) (trade body representing the Approved Organisations)
• Royal Institution of Chartered Surveyors (RICS) (whose members are responsible for issuing Home Reports, of which a large number of EPCs issued form a part)
• COSLA (representing Scotland’s 32 local authorities)
• Association of Local Authority Chief Housing Officers (ALACHO)
• Energy Saving Trust (representing energy advisors and external delivery programmes)
• UK Finance (representing lenders)
• Propertymark (representing estate and lettings agents)
• ESPC (representing conveyancing solicitors)
• Consumer Scotland (representing consumers)
• UK Government (Observers)

Independently chaired Assessment Subgroup of the Heat in Buildings Strategic Advisory Group

The independently chaired Assessment subgroup of the Heat in Buildings Strategic Advisory Group (SAG) was established to provide independent challenge, advice, and expertise to support the Scottish Government. Members were chosen based on their expertise/ experience, and for their independence, as experts who are not directly impacted by any changes introduced through our wider EPC Reform programme.

This group meets roughly quarterly and will continue to meet throughout 2025 (and beyond, as required).

It is made up of the following external stakeholders (including wider-public sector representatives):

• Regulatory Assistance Project (Chair) (representing independent expertise in regulatory design)
• Chartered Association of Building Engineers (representing professional expertise in disciplines across the built environment)
• Citizens Advice Scotland (representing consumer interests)
• Federation of Small Businesses (representing business interests)
• Monmouthshire County Council (representing independent expertise in EPC enforcement within local government)
• Nesta (representing public engagement and user design interests)
• Scottish Futures Trust (independent expertise in infrastructure development)
• Sustainable Energy Authority of Ireland (SEAI) (international expertise in EPC regulatory design and delivery)

Business and third sector organisations have been involved throughout the pre-scoping, evidence-gathering stage of HEETSA’s development with representatives from EPC Approved Organisations (e.g. Elmhurst Energy, Bacra), universities, colleges and research institutions, trade associations (e.g. Association for Decentralised Energy, Homes for Scotland, Property Energy Professionals Association, Scottish Renewables), professional bodies (e.g. Construction Industry Council, Royal Incorporation of Architects in Scotland), third sector bodies (e.g. Community Energy Scotland), utilities (e.g. Scottish & Southern Energy Networks), solicitors, landowners, landlords and housing associations (e.g. Eildon, Hjatland) and skills bodies (e.g. City & Guilds) participating in the December 2024 workshops to inform the independent research report on HEETSA.

During the pre-scoping stakeholder workshop in July 2024, stakeholders considered three themes.

Scottish Government officials held a workshop covering the current retrofit assessment landscape to inform further development of the HEETSA workstream. The workshop included invited experts from across academia, local authorities, and industry. The purpose of the workshop was to understand the current retrofit assessment methodology(s) and any gaps in provision that may require Scottish Government intervention. The workshop was broken down into three group sessions covering the following themes:

· Theme 1 – Technical Suitability Standards, Methods and Competency

This theme covered the suitability of existing methodologies to provide retrofit assessments. Groups discussed the inappropriateness of EPCs for this purpose, pointing to disconnect between cost-focus of the EPC rating and measures to decarbonise buildings. Risks relating to unintended ventilation constraints from insulation and draught-proofing, and installation of technically unsuitable measures were identified (e.g. well-known issues with spray foam) in the absence of proper advice and safeguards. Groups also described a wariness in the public to undertake work due to high-profile issues with some retrofit measures.

· Theme 2 – Establishing a Quality Assurance framework

This theme covered the needs of a quality assurance framework to underpin a technical suitability assessment. Groups noted the clear need for safeguards to protect against unscrupulous or unqualified advice or installations, identified as a gap in the current market. There was discussion of the need for accredited professionals to provide independent advice at all stages of assessment and works – noting the difference between assessors, designers, and installers. Existing methodologies including BS40104 and PAS2030/2035 were identified as good starting points.

· Theme 3 – Protecting consumers’ interests and redress

This theme related to consumer protection. The group noted lack of regulations which could lead to insufficient protection for vulnerable homeowners, with redress and remediation challenging once inappropriate work has been undertaken. The current investigation by Consumer Scotland into deceptive practices in the energy efficiency and clean heating market was noted. The group noted that a database providing detail on performance of monitored installations of measures would improve confidence.

During the December 2024 workshops to inform the independent research report, a range of themes were raised by businesses and third sector groups, which have been recorded within that report^[6].