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Scotland's Climate Change Plan – 2026-2040 - BRIA

Business and regulatory impact assessment (BRIA) of the climate change plan (CCP) 2026 to 2040.


Section 2: Engagement and information gathering

2.1. Whole of Plan Engagement

This subsection details engagement on issues pertinent to the overall CCP. Engagement undertaken within individual climate change sectors has been detailed on a sector-by-sector basis.

2.2. Engagement approach

The Scottish Government laid a draft Plan in Parliament on 6 November 2025. This began a statutory scrutiny period of 120 days through which the Scottish Government sought the views of parliament on the overall trajectory of decarbonisation, the package of policies and proposals being put forward, and the wider impacts of both of these.

The Scottish Government also conducted a 12-week public consultation and engaged with key stakeholders throughout the scrutiny period to seek wider views on the draft Plan and its associated documents. During this period the Scottish Government also delivered a programme of public engagement through our ‘trusted messenger’ organisations to make the consultation as active and inclusive as possible.

The Scottish Government has engaged and consulted extensively in preparing this Climate Change Plan and in the development of climate change mitigation proposals more generally. This has involved national and regional engagement in sectors across the Scottish economy and in relevant policy areas and through multiple different fora, stakeholder groups and processes which are described in greater detail below, in particular relating to engagement with business and the third sector.

Parliamentary, public and wider stakeholder views provided during this period have influenced the final Climate Change Plan and the content of this Business and Regulatory Impact Assessment.

The Climate Change Plan brings together a range of policy interventions, both new and existing, that are intended to tackle the climate change crisis through reduction of emissions and delivery of a just transition to net zero. Many of these interventions have already been subject to an impact assessment process or will undergo an assessment as they progress. Engagement throughout the climate change sectors on an individual policy level may have been undertaken separately to the development to the Climate Change Plan, particularly for pre-existing policies. Nonetheless, previous engagement on individual policies informs the work undertaken as part of the Climate Change Plan development and has therefore, been included in this document.

2.3. Climate Change Plan Advisory Group

The Scottish Government has routinely engaged with the Climate Change Plan Advisory Group (CCPAG), which has been fundamental in developing the Climate Change Plan. CCPAG members include opposition MSPs and other political representatives, public sector officials, representatives from industry and trade unions, environmental NGOs and academics.

Regularly engaging with and through the CCPAG has ensured that the views of all represented stakeholders actively inform the creation of the plan and has enabled the Cabinet Secretary for Climate Action and Energy to consider a range of perspectives and expertise in policy development for the Climate Change Plan.

The CCPAG has sought to understand and advise on the scale of the challenge inherent in meeting Scotland’s carbon budget targets, particularly in relation to public finances and the Scottish economy and express views on possible solutions. Further, the CCPAG has met to discuss options for managing the challenges and risks and maximising the opportunities and benefits of the Plan’s proposed policy approaches including co-benefits across sectors and linkages to climate change adaptation and other policies, and to advise on priorities on areas required by the Plan not included in previous plans: such as setting out an estimate of the costs and benefits associated with its policies and Just Transition considerations when preparing the plan.

The Scottish Government met with the CCPAG in two official-led workshops during the scrutiny period to discuss the delivery and financing of the mitigation actions contained in the Plan. The CCPAG also met in a Ministerial-led meeting to discuss the key themes heard in these workshops.

2.4. Internal SG engagement/engagement with wider Public Sector

2.4.1. Internal SG engagement

The Climate Change Plan is a whole-of-government document that has been co-created across Scottish Government and involved the participation of and engagement with many policy areas including through our Climate Deputy Director Network and Global Climate Emergency Programme Board. This has assisted in ensuring that the policies and proposals have been designed in a way that takes into account wider impacts on society at an early stage. Key areas of internal Scottish Government engagement have involved:

  • Directorate for Agriculture and Rural Economy,
  • Directorate for Environment and Forestry,
  • Directorate for Energy and Climate Change,
  • Directorate for Population Health,
  • Transport Scotland,
  • Directorate for Marine,
  • Scottish Exchequer, and
  • Scottish Forestry.

During the draft CCP scrutiny period the Directorate for Energy and Climate Change engaged with directorates across the Scottish Government to gain a better understanding of how different climate, nature and environment based strategies might interact with each other and to foster greater delivery mechanisms for the policies contained in those strategies.

2.4.2. Wider Public Sector

Engagement across the wider public sector on elements of the Climate Change Plan has involved:

  • Scottish Environment Protection Agency,
  • NatureScot,
  • Zero Waste Scotland,
  • Scottish Fiscal Commission,
  • Scotland’s enterprise agencies,
  • Just Transition Partnership,
  • Just Transition Commission,
  • Climate Change Committee,
  • COSLA,
  • Local authorities,
  • Sustainable Scotland Network (SSN), and
  • SOLACE.

The Scottish Government’s engagement with Highlands and Islands Enterprise, Scottish Enterprise, and South of Scotland Enterprise during the scrutiny period of the draft Plan demonstrated the how business and industry may experience impacts differently due to their varying landscape and population density.

Engagement during the draft Plan consultation period includes a dedicated local authority workshop series, organised and conducted in partnership with SSN, COSLA and SOLACE to seek feedback on the draft Climate Change Plan from a broad range of local authority representatives and to develop relationships with local authority representatives as key delivery partners of the Climate Change Plan. The workshop series was conducted from a place-based lens, with attendees noting that businesses may experience differential impacts on delivering climate mitigation action depending on the extent of the rurality of a given area. For example, installing EV charging points in rural areas was noted as an area where businesses may experience more challenging financial pressures due to the distance between each installation.

These discussions identified an interest in delivery bodies to be included in implementation plans and proposals for strengthening partnership working.

2.4.3. UK/Devolved Administrations

There has been ongoing engagement between Scottish Government and UK Government (e.g. DESNZ, DEFRA, Department for Transport) at both ministerial and official levels throughout development of the Climate Change Plan. This has ranged from periodic information sharing in the case of devolved policy areas to more closely joined up engagement in areas such as the development of the UK Emissions Trading Scheme (UK ETS). The Scottish Government has engaged with the UK Government and the Devolved Administrations at the ministerial level via the Inter-Ministerial Groups on Net Zero, Energy and Climate Change, and on Environment, Food and Rural Affairs, and at official level in Four Nation discussions.

Scottish Government has routinely pressed for UK Government action on policy areas of key interest to Scottish people, communities and businesses. For example, the Scottish Government has asked for greater action to reduce electricity costs at the UK level, in line with Climate Change Committee advice.[2] Through these discussions the other administrations are more aware of Scotland’s decarbonisation policies and the linkages to reserved policies.

2.5. International

The main aim of the Climate Change Plan is to reduce emissions of Greenhouse Gases in Scotland. Scottish Government officials have occasionally engaged with counterparts in other countries as the Climate Change Plan has been developed, to share knowledge and to participate in broader climate initiatives such as those undertaken through the Conference of Parties (COP) process.

2.6. Business/Third Sector engagement

Business and third sectors were one of the groups targeted in the public consultation which invited views on the draft CCP and impact assessments. Throughout the scrutiny period the Scottish Government also engaged with a number of representative business, financial and third sector organisations on the overall Plan to gain feedback on what it means to them and their members, and to seek suggestions on improvements to the final Plan, including groups such as:

  • Business in the Community,
  • Confederation of British Industry,
  • Scottish Chamber of Commerce,
  • Nesta (formerly National Endowment for Science, Technology and the Arts),
  • Poverty Alliance,
  • Scottish National Investment Bank,
  • National Wealth Fund,
  • Prosper, and
  • Association of British Industry.

2.6.1. Agriculture

In the agriculture sector we have engaged with our key stakeholders including: The Scottish Crofting Federation (SCF), The National Sheep Association (Scotland) (NSAS), The Scottish Beef Association (SBA), National Farmers’ Union Scotland (NFUS), Quality Meat Scotland (QMS), NatureScot (NS), Royal Society for the Protection of Birds (RSPB), Scottish Rural College (SRUC), James Hutton Institute (JHI) Scottish Land and Estates (SLE), Scottish Environment LINK, Soil Association (SA), Scottish Tenant Farmers Association (STFA), World Wildlife Fund (WWF) and Scottish Agricultural Organisation Society (SAOS). These stakeholders can represent both islands and the mainland.

Agriculture Engagement for the Climate Change Plan

Informal evidence sessions with key stakeholders were held in summer 2024, followed by a roundtable session in May 2025 with agricultural and land use stakeholders. Engagement continued with key agriculture stakeholders throughout the Climate Change Plan public consultation and Parliamentary scrutiny period in Winter 25/26. Several policies and proposals under the Agriculture Reform Programme (ARP) and other wider agriculture policy and strategy actions will include further stakeholder engagement as appropriate.

Agriculture Reform Implementation Oversight Board Engagement

The Agriculture Reform Implementation Oversight Board (ARIOB) includes a balanced representation of farming, geographical, and environmental interests. Members were appointed to provide the necessary breadth of expertise to support policy reform, incorporating recommendations from farmer-led groups to:

  • Cut emissions across agriculture,
  • Support sustainable, high-quality food production,
  • Address climate and biodiversity crises, and
  • Design a new system and approach.

Engagement through the ARIOB generally takes place via quarterly in-person meetings (with a hybrid option for remote attendance). Ad hoc interim meetings, typically online, are held as needed. Members also receive relevant updates, surveys, and materials for comment via email.

Food and Agriculture Stakeholders Taskforce Engagement

Engagement with the Food and Agriculture Stakeholders Taskforce (FAST), including meetings between the FAST Chair, have helped shape the development of land use policies in the Plan.

Livestock Genetic and Performance Improvement Stakeholder Group

The Livestock Genetic and Performance Improvement group was established in February 2024 to explore the role of livestock genetic and performance improvements in supporting reduced emissions intensity from the Scottish livestock sector, taking into account its effect on food production and economic growth. The group is supported and chaired by Scottish Government officials and includes representatives from National Farming Union Scotland (NFUS), Scottish Beef Association (SBA), Quality Meat Scotland (QMS), Scottish Agriculture Organisation Society (SAOS), Scotland’s Rural College (SRUC) and others.

Across seven meetings to date, the group have focused their discussion on three improvement metrics, identified as having the highest potential to reduce emissions, including: Age at Slaughter, Age at first Calving and Calving Intervals. Consideration of these issues has informed agriculture policies that maintain food production while reducing emissions.

Scottish Suckler Beef Support Scheme Reform Engagement

Engagement for Scottish Sucker Beef Support Scheme (SSBSS) reform has been conducted through a stakeholder group that met during 2023–2024. An updated version of this group continues to be used for digital correspondence.

Bilateral Engagement and Wider Communication (Primarily via ARP)

Engagement also takes place through bilateral meetings with stakeholders. Wider communications, detailed below, are principally about informing stakeholders rather than engaging them directly:

User Research

Under Testing Actions for Sustainable Farming (TSF), over 50 in-person interviews were conducted with farmers and crofters (2022–2023), and nearly 1,000 responded to a TSF survey (July–August 2022).

Small Business Engagement

Engagement with small businesses typically occurs through representative bodies such as NFUS, SBA, QMS, and the Scottish Crofting Federation (SCF).

Supporting Advisory Groups

  • Academic Advisory Panel (AAP): provides scientific expertise and evidence.
  • Agriculture Policy Development Group (APDG): assists with policy detail development and includes representatives from NFUS, Scottish Environment LINK, and an independent expert with government and industry experience.

2.6.2. Business and Industrial Process

Scottish Government invited representatives from across the energy intensive industrial (EII) sectors, academia, public sector agencies and central and devolved government to a stakeholder workshop to provide views on several industrial decarbonisation and Negative Emissions Technologies (NETs) policy proposals. Workshop outputs have informed the development of policies within the Climate Change Plan.

We engage directly with the Industrial Decarbonisation Research and Innovation Centre (IDRIC) including by attending their annual Policy Forum which brings together stakeholders from industry, academia, government and trade unions to explore key enablers of industrial decarbonisation in the UK. It combines research insights, industry reflections, and discussion around current barriers and future policy priorities.

Through delivery of the Scottish Industrial Energy Transformation Fund (SIETF) we engaged directly with Scotland’s enterprise agencies (Scottish Enterprise, Highlands and Islands Enterprise, South of Scotland Enterprise) to understand the wider demand for industrial decarbonisation investment from across manufacturing and energy industries. This market intelligence is used to consider the design of future programmes.

NETs officials focus on engagement with key industry stakeholders who can support deployment of NETs at the pace and scale required to support Climate Change Plan targets, based on opportunities highlighted in the NETs feasibility study published in November 2023. This includes industry groups representing high potential for early deployment of NETs such as the DAC coalition and the Anaerobic Digestion and Biogas Association.

The Scottish Government is engaging extensively on Carbon Capture Utilisation and Storage (CCUS). There has been extensive engagement with the wider Scottish Cluster via a series of workshops, forums and seminars, often hosting in tandem with Scottish Enterprise, covering topics to enable development like planning and permitting.

At Grangemouth, engagement is coordinated through the Grangemouth Future Industry Board which brings together Government, industry and local stakeholders to plan the site’s long-term transition. CCUS forms a critical element of these discussions, ensuring that decarbonisation pathways are aligned with industrial strategy and just transition goals.

Alongside project and place-based forums, Government works with research partners to provide evidence for policy design. Engagement also includes with statutory bodies on seabed leasing, ensuring regulatory processes support decarbonisation objectives.

During the draft Climate Change Plan scrutiny period the Scottish Government engaged with food and drink industry representatives including the Scotch Whisky Association and Food and Drink Federation.

The Scottish Government’s policy position on hydrogen was set out in the Hydrogen Action Plan (HAP) which was subject to a BRIA process and can be found here: Hydrogen Action Plan BRIA. Since the publication of the HAP we have established the Scottish Hydrogen Industry Forum chaired by Scottish Ministers and composed of senior industry stakeholders, to provide insight, raise awareness of challenges and inform developing policy to help the realisation of the Scottish Government’s hydrogen ambitions. Views and priorities of this sector have been taken into account when developing and finalising the CCP policy package.

For the heat in buildings proposals that relate to non-domestic buildings, extensive engagement has been undertaken, including public consultations (on the Heat in Buildings Strategy, 2021 and proposals for a Heat in Buildings Bill, 2023–24); and roundtables with businesses, NGOs, and building owners. Further consultation and subsequent impact assessments will be needed to accompany any future regulations introduced and the publication of the Heat in Buildings Strategy and Delivery Plan.

2.6.3. Buildings (Residential and Public)

Extensive engagement has been undertaken with businesses and the third sector, including public consultations (on the Heat in Buildings Strategy in 2021 and proposals for a Heat in Buildings Bill in 2023–24); roundtables with businesses, NGOs, and building owners; and ongoing engagement with local authorities, regulators, and UK Government. Further consultation and subsequent impact assessments may need to accompany future regulations when introduced and for the publication of the Heat in Buildings Strategy and Delivery Plan in 2026.

In late 2025 Scottish Ministers asked the Regulatory Review Group (RRG) to advise on the sequencing, timing and interdependencies of key reforms relating to housing quality, emissions and standards, to support delivery and manage impacts on supply. The RRG input was helpful in informing our approach to Heat in Buildings regulations and reform. More details are available here: Regulatory Review Group - gov.scot. We are continuing to discuss these matters with the Group.

In May 2025 stakeholder events regarding heat networks proposals took place, including attendees from across industry. Prior to this, industry were engaged through the Stakeholder Engagement Groups formed to advise on implementation of the Heat Networks (Scotland) Act 2021. The advice from these groups also helped inform the proposals.

The Scottish Government also undertook a series of roundtables in August 2025, chaired by the Cabinet Secretary for Housing, with three key groups of stakeholders:

  • Businesses and Investors,
  • Non-Governmental Organisations, and
  • Non-Domestic Building owners/operators.

This supplements ongoing close work with the official level Heat in Buildings Strategic Advisory Group.

In January 2025 we published an analysis of the ‘Delivering net zero for Scotland's buildings – Heat in Buildings Bill’ consultation.[3]

More recently, the Cabinet Secretary visited the Energy Training Academy, hosted by Nesta and SNIPEF, with installers, skills providers and heat pump manufacturers. The discussion was positive and constructive, demonstrating the sector’s clear readiness to scale up and underscoring the need for a stable and predictable policy environment.

2.6.4. Energy Supply

We have engaged with key business and industry stakeholders regularly since 2023. Principally, this has included regular meetings between Scottish Government officials and SSEN, the owner of all island generator sites, including power stations on Shetland, Orkney, Lewis, South Uist, Barra and Islay. These meetings have shaped the development of our proposals focused on reducing emissions from these two areas, while maintaining a strong and resilient electricity network. Officials have also coordinated with policy leads for island communities, including around the soon to be updated National Islands Action Plan. Officials have met and continue to engage with SSE, the operators of the Peterhead gas-fired power plant (CCGT) – though these meetings do not focus on the live planning application which is with Energy Consent Unit (ECU) officials and ministers for decision.

Officials have coordinated the development of proposals for this chapter with officials from the ENFOR directorate, to ensure policies around Energy from Waste reflect wider priorities around reducing waste, enabling a circular economy and decarbonising residual waste. The waste management section of the Climate Change Plan BRIA contains further information on this topic. Evidence informing EfW proposals came from a range of sources including the Circular Economy and Waste Route Map; the Independent Review of Incineration and Scottish Government response to the review; the interim authority response and analytical annex from the consultation on UK Emission Trading Scheme expansion to waste.

We have likewise coordinated with colleagues working on the business and industrial processes chapter regarding the Acorn Project and Scottish Cluster. Our proposal on Acorn has been shaped by their evidence and input, including around when the Scottish Cluster is likely to come online, provided it has the necessary level of UK Government funding and support.

The Scottish Government regularly engages with a range of key stakeholders for the offshore energy transition, including industry bodies such as Offshore Energies UK (OEUK) and Renewable UK (RUK), UK regulators such as the (North Sea Transition Authority) NSTA and Offshore Petroleum Regulator for Environment and Decommissioning (OPRED), Trade Unions and NGOs.

The Climate Change Plan does not outline policies directed specifically towards decarbonisation of the downstream oil and gas sector. However, the Scottish Government has and continues to engage regularly with key stakeholders including: Petroineos, the owner and operator of the Grangemouth finished fuels import terminal, Ineos Olefins and Polymers, Ineos Forties Pipeline System and Shell and ExxonMobil, operators of the Mossmorran industrial complex. We also maintain engagement with Fuels Industry UK, Liquid Gas UK and UKIFDA as and when required. The Scottish Government shall continue to engage constructively with these stakeholders through the transition to net zero to understand how our actions – including those in the CCP – affect them and their members.

2.6.5. Land Use, Land Use Change and Forestry

2.6.5.1. Forestry

Community engagement is a core part of the woodland creation process and Scottish Forestry is committed to further promoting meaningful engagement, in line with the Land Rights and Responsibilities Statement. Individual woodland creation schemes (i.e. the primary way to deliver the intended Land Use, Land Use Change and Forestry (LULUCF) forestry outcomes) are subject to a detailed consultation process, supported by Scottish Forestry’s EIA Public Register and the publication of good practice guidance and training events on community engagement for the forestry sector. Local engagement and dialogue have led to the development of various initiatives to support woodland creation, such as the farmer-led Integrated Trees Network.

The Scottish Government’s Forestry Strategy 2019-2029 identified a number of priority areas for action to help businesses engage in the creation of woodlands and experience the range of benefits they can deliver. Scottish Forestry has supported the Confederation of Forest Industries (Confor) to develop and deliver a programme of stakeholder engagement training, and to work with business to produce good practice guidance on engagement for the sector.

2.6.5.2. Peatlands

In addition to supporting wider engagement through many of the above channels, we have engaged broadly across peatland restoration and horticultural peat interests as follows.

Peatland restoration

NatureScot Peatland ACTION have engaged with businesses through their Update and Conversation on Change which outlined proposed changes to how their peatland restoration programme will operate in response to new challenges. Engagement began in October–November 2024 with a stakeholder update and invitation for feedback and has included 1-1 and group stakeholder conversations in early 2025, ongoing webinars and site visits, and expanded training and support schemes through 2025–26. A feedback summary was published in February 2025.

NatureScot presented four key options for future change to businesses: expanding the pipeline of designed and investable projects; targeting public investment more effectively; leveraging private finance to complement public funds; and simplifying processes to accelerate delivery. These options were shared during the engagement period and formed the basis for stakeholder feedback.

The engagement approach aligns with the Business Engagement Principles. NatureScot has demonstrated transparency through clear communication of changes and funding criteria, inclusivity by engaging a diverse range of business types, responsiveness via feedback mechanisms, and support for growth through workforce development and competitive funding models. To ensure broad business representation, NatureScot engaged contractors, land managers, consultants, and investors. Sector representative bodies were involved through events and webinars.

Feedback received from businesses was generally positive. Stakeholders welcomed the competitive funding model and integration of private finance. There were calls for simplification of procurement and application processes, strong support for workforce development, and requests for clearer communication and long-term visibility of restoration opportunities.

Horticultural peat

All of the Peatland ACTION Delivery Partners have engaged with small businesses, for example, through New Entrants Schemes and the Machine Operator Training Scheme, which provided rural trainees with hands-on experience. One-to-one support is offered by project officers, and future plans include continued training and simplified access to funding to support small business participation.

A public consultation, “Ending the Sale of Peat in Scotland”, was carried out between 17 February and 12 May 2023. In total 552 responses were received, including 469 individuals and 83 organisations. Highest representation was seen in relation to horticultural use of peat. Although the focus of the consultation was the sale of peat in horticulture, we also considered other uses of peat that drive its commercial extraction to ensure proportionate action and minimise unintended consequences.

An analysis of responses to the consultation was published on 21 December 2023. Whilst it showed support for a peat sales ban for horticulture, those reliant on peat as fuel in rural or island areas highlighted challenges in transitioning away from peat due to a lack of suitable alternatives or the cost of replacement heating systems. We are mindful of the needs of crofters and islanders and how they might be affected by ending the sale of peat.

Following the “Ending the Sale of Peat in Scotland” public consultation, a series of stakeholder workshops were held in autumn 2024 under the categories of growers (ornamentals); growers (fruit and vegetables); growing media producers; garden centres; retail (including supermarkets and DIY stores); NGOs and wider public service and the potato industry. The information gathered from each event was summarised and collated to inform policy development.

A research project was developed to address some concerns raised in the consultation and stakeholder workshops around trial coordination and availability of suitable alternatives, particularly for certain crops/plants reliant on peat. The ClimateXChange funded researchers conducted 35-40 interviews with growers, growing media producers and others to understand concerns around transition and how they may be overcome. The work will inform policy development, including support needed such as exemptions and associated conditions.

2.6.6. Waste Management

Background

The majority of policies for inclusion in the waste sector package are also actions from Scotland’s Circular Economy Waste Route Map 2030, published in 2024, and have been subject to a BRIA process during development. Some policies in the package have also already been subject to their own assessment process, for example, extended producer responsibility for packaging[4] (pEPR), and the Deposit Return Scheme (DRS) for single-use containers.[5] While previous impact assessments for the Route Map and Circular Economy (Scotland) Act 2024 set out potential impacts, it is intended that further detailed assessment of the impacts and associated evidence is gathered as policies are implemented.

Engagement approach

Collaboration and partnership have been critical to our progress so far. Our engagement approach to developing policies and proposals for the waste sector chapter has been guided by both the Verity House Agreement and New Deal for Business Group's recommendations and implementation plan[6]. New Deal for Business recommendations informed early stages of policy development prior to the completion of its delivery in April 2024. The actions in the policy package are based on rigorous gathering and assessment of the evidence and an extensive programme of engagement, including two Route Map consultations.[7]

Evidence gathering

The policy package for waste draws upon a wide range of evidence, including published and peer reviewed literature, official waste data for Scotland

published by the Scottish Environment Protection Agency (SEPA), and previous

research by the Scottish Government, Zero Waste Scotland and other parties. Waste sector officials have engaged on circular economy and resources policies through the RRG, for example, on Scotland’s Deposit Return Scheme, the ban on single-use vapes, wider producer responsibility measures, action around single-use items, the Circular Economy Act and the Route Map. The Waste and Resources Sector Forum also provides a platform for strategic engagement and partnership working between stakeholders on key circular economy, recycling and waste management issues.

Policies

Deposit Return Scheme: a range of public and business consultations have been undertaken for the development of the Deposit Return Scheme (DRS) in Scotland.[8] Regulations were amended in 2022, 2023 and 2025 in response to stakeholder feedback, and we continue to engage regularly with the industry-led scheme administrator and obligated businesses throughout the scheme’s implementation. Most recently we have engaged with businesses through the UK-wide DRS Industry Forum. This group provided industry expertise and advice on practical issues related to the operation of the DRS and how it interacted with production, retail, and hospitality industries. The group comprised of trade bodies in the sectors who will have most influence on the scheme’s operation. Further details of the engagement undertaken to support the development of DRS can be found in Section 2 of the BRIA for the DRS amendment regulations published May 2025.

Extended Producer Responsibility for Packaging (pEPR): a wide range of business engagement has been undertaken at both a Scottish and UK level, including an industry sounding board established with the support of INCPEN (Industry Council for Packaging and the Environment), the government’s Advisory Committee on Packaging (ACP), and Defra’s Packaging and Collections Working Group and Resources and Waste Stakeholder Advisory Group. Consultation on the introduction of a four-nations packaging extended producer responsibility scheme (pEPR) took place in 2021, with subsequent consultation on final Regulations in 2023 and ongoing regular engagement with industry groups and local authorities since then.

Single-use cups action: engagement to develop initial policy proposals for action around single-use beverage cups has included meetings of an expert advisory group containing representatives from business, retail, equalities groups, consumer groups, and local authorities.[9] It has also involved engagement with the Regulatory Review Group on initial policy proposals and implementation advice.

Food waste: engagement can ensure any change to legislation is proportionate and accessible guidance is provided. An example is the plan to establish an expert advisory group to enhance policy development on the mandatory reporting of food waste and surplus. We recognise that reporting will be an additional ask on businesses, and that many food businesses work across the UK, so we intend to work with key partners to ensure we are engaging at a Scottish and UK level to maximise potential environmental impact while providing simplicity for the business sector.

Recycling: commercial waste sector actions include a review of compliance with commercial recycling requirement being undertaken by SEPA. We intend to use the review as the starting point for a co-design process with stakeholders to develop further measures to improve commercial waste services to maximise waste prevention, reuse, and recycling. This will involve in-depth engagement with the business community, the Scottish resources and waste sector and other key stakeholders, drawing directly on the expertise held across the sector, on the experiences of different sizes of businesses and organisations, and on the evidence drawn together through key measures like waste compositional analysis and the review of compliance.

Disposal : the Climate Change Plan policy collection for Waste Management includes a package of measures targeting emissions reduction at the point of waste disposal. Through the development of these measures the Scottish Government has and will continue to progress significant engagement with sector representatives and local government. For example, the Residual Waste Plan will be shaped in collaboration with a range of stakeholders. We believe this collaborative approach is vital to draw upon the expertise across sectors and build joint ownership and the confidence needed to invest in infrastructure across the resource recovery chain.

2.6.7. Transport

Different business sectors were engaged during the public consultation on the draft Transport Just Transition Plan that ran between February and May 2025 and contained questions about workers and businesses, with 13 responding formally.

Engagement in the Transport sector which is specific to the Climate Change Plan has included a workshop on road transport and aviation in September.

The wider engagement approach is set out in more detail in the Transport subsection of Section 2: Engagement and information gathering - including the engagement carried out by each modal area, and the types of businesses that the Transport sector engages with in the development of the policies and proposals included in the Climate Change Plan.

Car use

Our approach is informed through the work of three key working groups focussed on governance and delivery plans associated with our successor car use reduction target; communication and engaging on car use reduction targets nationally; and on regulations made under the Transport (Scotland) Act 2001, which enabled discretionary local road user charging schemes to be made should a local authority wish to do so. Membership of these groups varies, however, generally include key stakeholders including Regional Transport Partnerships, SCOTS and COSLA, as well as others in Scottish Government.

Engagement was carried out with business throughout the consultation period for the draft route map, and with stakeholders throughout the development of our updated approach published in the renewed policy statement on car use reduction. As the renewed policy statement restates our commitment to reducing car use, further strategic engagement with business will be undertaken at an individual policy level, for example, as Transport Scotland takes forward regulatory checks on discretionary local road user charging schemes working with local authority partners.

Stakeholder engagement has been pivotal to the ongoing development of car use reduction policy. Our consultation on a draft route map for car km reduction received 679 responses, of which 64 were from organisations and 615 from individuals. These responses formed a key part of the evidence base which formed the basis for our renewed policy statement on car use reduction The consultation analysis and renewed policy statement were published in June 2025.

We have also continued to engage directly with key stakeholders, both directly and through utilising existing mechanisms such as the Mobility and Access Committee for Scotland, the Public Health and Sustainable Transport Partnership, and the National Transport Strategy Delivery Board.

The Scottish Government also developed a draft Transport Just Transition Plan, which was subject to a public consultation to gather feedback, alongside a number of public engagement events held. A total of 123 substantive written responses were received and analysed. This included 68 from organisations. This provided significant further insight into how car use reduction can be achieved in a way that is fair for all in Scotland.

Bus and active travel

For Active Travel, there remains engagement with national, third sector delivery partners, including Walk Wheel Cycle Trust, Cycling Scotland, Cycling UK and Walking Scotland.

Officials continue to engage with key stakeholders (Local Authorities; Regional Transport Partnerships (RTPs); Active Travel Delivery Partners) as part of the on-going delivery of the 2025-26 programme and to inform the 2026-27 programmes. All of these contributions can be seen to contribute to the commitments within the Climate Change Plan.

We continue to progress development of our data, monitoring and evaluation framework and processes that have assisted us in responding to the Audit Scotland recommendation to report against the impact of the new delivery models.

Heavy goods vehicles

In 2023 Transport Scotland convened the Zero Emission Truck Taskforce to shape the pathway to the decarbonisation of Scotland’s road freight and logistics sector, underpinning the production of the HGV Decarbonisation Pathway for Scotland in March 2024. This was co-produced by industry and the public sector, describing the main issues and setting out actions for business and government.

As part of the actions for government within the HGV Decarbonisation Pathway, Transport Scotland have established a finance forum, involving extensive discussion between operating companies, the energy sector, the finance sector and government. This identified opportunities and mechanisms for bringing private sector investment into the decarbonisation of road haulage through collaboration within industry and partnership with government.

Transport Scotland subsequently launched a £2 million Market Readiness Fund in 2025 to provide financial support for SME hauliers and encourage the formation of consortia of fleet owners, charge point operators and financiers to conduct analysis and development proposals for HGV decarbonisation projects. It also included targeted support for Scottish SME HGV operators to access analytical support, knowledge and expertise to better understand how to decarbonise their operations.

In parallel, Transport Scotland has commissioned research from Heriot Watt University to map the likely energy demand and location of en route charging infrastructure on Scotland’s trunk road network, with a third version under development. The project involves close collaboration with fleet-owning companies to access vehicle data, as well as with DNOs and NESO to ensure the outputs can inform modelling.

The output of the HGV charging infrastructure work is one of the inputs to Strategic Transport Electrification Group – a forum established to identify how the energy system will need to adapt to the changing demand for charging of zero emission HGVs and liaise with distribution network operators and the National Energy System Operator to gather data to inform future investment decisions.

Since 2019 Transport Scotland has funded the provision of training through the college network to ensure that the workforce has the skills necessary to develop, maintain and operate zero emission vehicles. The programme is run in partnership with the Energy Skills Partnership.

Transport Scotland’s support for skills has evolved in response to ongoing feedback from the sector, including industry participation in the development of the draft Just Transition Plan for Transport. In 2025 Transport Scotland launched the HDV Skills Challenge Fund to encourage the development of projects from the public and private sector to address skills needs in relation to the decarbonisation of HDVs. Transport Scotland also convened a Skills Forum in response to stakeholder feedback to assist with knowledge sharing and is developing a Skills Route Map to 2045 with stakeholders.

Transport Scotland maintains ongoing engagement with the road freight and haulage sector through regular meetings of the Scottish Freight and Logistics Action Group (ScotFLAG) and one-to-one meetings with industry bodies including Logistics UK and the Road Haulage Association, providing an overview of issues affecting the sector.

Transport Scotland are working with the public sector to develop a public sector fleet decarbonisation Action Plan. The Action Plan will include actions related to decarbonisation of the public sector including heavy and specialist vehicles, this work has been informed by a series of workshops with public sector fleet managers, and the final action plan is expected to be published by the end of 2026.

Electric vehicles

The UK Government, as the secretariat for the four nations Vehicle Emissions Trading Schemes legislation, held consultations in 2023 and late 2024 and a mini-consultation in 2025. This has engaged the automotive sector, the public charging sector and has been open to the public. Roundtables with Ministers from all four nations were held 2025 regarding the flexibilities to be introduced to the legislation.

On public Electric Vehicle charging, a consultation ran from February to March 2025 collating over 100 responses. Workshops were held in the central belt and in the Highlands to capture additional input from across Scotland. Via Scottish Futures Trust (SFT), officials meet with the public charging industry on a quarterly basis as well as with the trade body Charge UK.

Transport Scotland drew upon the infrastructure investment expertise of Scottish Futures Trust to look at how the public charging network can be financed and grown at the scale and pace necessary to achieve Scotland’s Net Zero targets. In their 2021 review they identified that it was unsustainable for a public funded model to successfully achieve the required level of coverage necessary to support future demand.

The publication of the draft Vision Implementation Plan in December 2024 sets out a route map to deliver on our vision and ambition to deliver a comprehensive and convenient network that meets the needs of users and is funded by private investment by 2030 largely financed by the private sector. Following its publication, an online consultation alongside two physical workshops in Glasgow and Inverness were held with stakeholders across Scotland and the UK to refine the actions necessary to meet the public charging ambition. The final Vision Implementation Plan is due to be published in 2026.

On the Electric Vehicle supply side, a consultation was launched in December 2024 with the automotive industry regarding flexibilities to the Vehicle Emissions Trading Schemes legislation which includes the ZEV Mandate. Following that consultation, a new policy position was agreed, providing flexibilities while maintaining the headline targets to 2030.

Aviation

The Scottish Government’s Aviation Statement describes the specific actions we will take to encourage decarbonisation and to increase our international connectivity. In developing the Aviation Statement, we consulted with a range of stakeholders, including businesses, operators, and public sector organisations.

The Statement emphasised that the Scottish Government must encourage and complement the sector’s efforts to reduce emissions, while maintaining clear lines of responsibility and accountability for both government and industry. We noted Ministers’ intention to meet regularly with aviation stakeholders to discuss progress on reducing emissions and whether the various decarbonisation strategies that apply in Scotland are working effectively or whether further action is required.

As part of our commitments within the Aviation Statement, Ministers held the first of a series of roundtable discussions with the sector in June 2025. While there has been a great deal of discussion and work on Sustainable Aviation Fuel (SAF), Ministers were also keen to better understand the challenges and opportunities involved with adopting electric and hydrogen flight in Scotland. The event was well received by the sector, and we are now engaging further with stakeholders to define next steps.

The Scottish Government will introduce Air Departure Tax (ADT) as a devolved replacement for the UK-wide Air Passenger Duty (APD) from 1 April 2027. This is possible due to the development of a new Highland and Island exemption that protects crucial connectivity in the region while complying with the UK Government’s subsidy control regime.

A consultation on the Scottish Government’s ADT proposals was launched on 29 January 2026. The consultation invites comment and evidence from interested parties and is open until 26 March 2026. The contributions received will then be analysed with a response published in due course.

We also continue to engage with UK Government Department for Transport (DfT) colleagues to understand the work of the UK Jet Zero Taskforce’s Task and Finish groups, to ensure knowledge exchange and to avoid unnecessary duplication.

Rail freight

There is ongoing engagement with freight customers and freight and logistics providers through the Scotland Freight Joint Board to inform and understand the impact of our freight growth targets and policies relating to modal shift. Feedback received to date has been positive.

Alongside the rail regulator we monitor and feedback on Network Rail’s progress towards achieving the rail freight growth target. This target (and supporting ones) is governed through the Scotland Freight Joint Board (SFJB) (the main senior rail freight industry group), and the members work collaboratively to produce the required short and longer term plans for growth. The SFJB is chaired by Network Rail and attended by Freight Operating Companies third party logistics providers, key rail freight users, the Rail Freight Group, representatives of the Port Sector, terminals representatives, Logistics UK, the rail regulator and Transport Scotland.

Given the commercial nature of rail freight, Network Rail cannot generate growth on its own, so this collaborative work with the rail industry and key rail freight customers ensures that growth plans are robust and reflect business and commercial realities.

2.7. Public consultation

The draft Climate Change Plan was laid in the Scottish Parliament on 6 November 2025 after which the Scottish Government ran a 12 week public consultation on the draft Plan and its associated impact assessments.

The public consultation generated over 500 responses from organisations and individuals, capturing views from a broad cross section of stakeholder organisations and members of the public. This activity was supplemented by 112 engagement events delivered by the Scottish Government’s partners, reaching more than 1,800 participants. Several of these events focused on targeted groups to ensure inclusion of perspectives from communities of interest with specific needs or backgrounds.

Responses to the public consultation and the public consultation report have been made available online. We have published our response to the public consultation as an annex to the final CCP in a ‘you said, we did’ format.

Independent analysis of the consultation responses delivered the following conclusions related to business impacts:

  • Employment: the impact of the draft CCP for employment and skills must be a key consideration. Stronger financial support is needed for groups such as farmers and oil and gas workers, to support their decarbonisation.
  • Skills: retrofit skills are needed to ensure the effective installation, integration, and maintenance of renewable energy systems. This was closely linked to the need for greater renewable‑energy expertise in rural areas, where limited access to such skills often drives up the cost of transitioning to renewable technologies. Respondents also highlighted construction and building skills, noting the need for renewed training and qualifications for engineers, architects, construction workers, electricians, heat engineers, and mechanics to ensure the transition is delivered and sustained effectively.
  • Financial Assistance: the most frequently cited form of support needed from the government was financial assistance. Respondents, particularly SMEs, though not exclusively, stressed that access to funding must be less bureaucratic and more straightforward, with some calling for sector‑specific and size‑specific criteria to ensure no business is left behind. Respondents emphasised the need for both short‑term and, crucially, long‑term financial support to maintain continuity in just transition efforts.
  • Businesses: the need for clear and enforceable policies that account for sector‑specific challenges. Respondents argued that the absence of coherent, aligned policies undermines confidence and makes it harder for businesses to plan for meaningful progress. This concern was often linked to the view that the draft Plan sets out broad expectations without providing a clear framework for how each industry should adapt its business models or implement the changes required to realise the benefits of net zero.
  • Knowledge exchange: respondents emphasised the importance of inter‑sector knowledge exchange to build a holistic understanding of the interconnected impacts of transition measures.
  • Circular practices: respondents also called for incentives for businesses and charities to adopt circular practices, such as repair, reuse, sharing, and leasing models.
  • Financial support: respondents called for securing lower electricity costs while reducing carbon emissions, as the transition at current cost levels would jeopardise competitiveness and workforce development. This concern was particularly prevalent among small and local businesses, which often face competition from larger organisations that can absorb transition costs more easily. Respondents called for support through various channels, including tax reductions, subsidies, and grants for transition installations, and preferential treatment in procurement for government projects.
  • Guidance: need for guidance and support on best practice for implementing the practical changes industries must make to meet the required changes. Hubs promoting knowledge sharing were also viewed favourably, as well as extracting knowledge from past successfully implemented projects.

The following sub-section outlines consultation to date for particular sectors that has supported and informed the development of the Climate Change Plan.

2.7.1 Agriculture

The main route of public consultation to date for agriculture on the Climate Change Plan has been through the Agricultural Reform Programme. Public consultation was carried out as part of the Agriculture and Rural Communities Bill (now the Agriculture and Rural Communities (Scotland) Act 2024).

The Agriculture and Rural Communities (Scotland) Act 2024 aims to deliver the key ambitions set out in the Scottish Government’s Vision for Agriculture: helping our farmers and crofters to produce more of what we eat more sustainably, to support their essential role in delivering climate mitigation and adaptation, and in biodiversity restoration. In seeking the powers to realise that Vision, the Act enables a payments framework that incentivises a drive towards low carbon approaches to improve the resilience, efficiency and profitability of the sector.

No engagement with the wider public has occurred as part of the Climate Change Plan consultation in Winter 25/26, (given the policies and proposals impact on farmers and crofters only) the public have been able to respond to the agriculture aspect of the plan.

Wider ‘land use’ policies and strategies, such as the draft Bioenergy Policy Statement, the Scottish Biodiversity strategy Agricultural Just Transition plan, and Scotland’s Fourth Land Use Strategy, which link to the Climate Change Plan, have involved consultation with key stakeholders and the public.

2.7.2 Business and Industrial Process

Due to the nature of policies within the industrial sector public engagement is primarily through consultations for draft policies such as our Hydrogen Action Plan.

2.7.3. Energy Supply

Proposals covering Energy from Waste either have been consulted on publicly or would be consulted on before being delivered. Scotland's National Planning Framework 4 (NPF4) Policy 12 was consulted on as part of the wider NPF4 consultation, which ran from November 2021 to March 2022. In 2024, the UK, Scottish and Welsh Governments and the Department of Agriculture, Environment and Rural Affairs for Northern Ireland jointly consulted on expanding the UK Emissions Trading Scheme to cover emissions from both waste incineration and energy from waste (EfW). Any expansion of the UK Government’s existing Industrial Carbon Capture Waste Business Model to include new projects will be consulted on publicly by the UK Government, following the original consultations to create the business models that support industrial carbon capture (ICC) and waste-based carbon capture. We have committed to develop a Residual Waste Plan by 2027 to ensure the best environmental outcome for materials and set strategic direction for management of residual waste to 2045. This will include a sector-led plan to minimise the carbon impacts of the energy from waste sector. As set out in the waste management section above, to guide this work, the Plan will be shaped in collaboration with a range of stakeholders to draw upon the expertise across sectors

Other proposals within the energy supply sector will include public consultations, where relevant, alongside community engagement for those communities specifically affected by the proposal in question, e.g., in Peterhead or islands. For example, SSEN Transmission’s community engagement for High Voltage Direct Current (HVDC) projects involves early and extensive consultation through public meetings, online feedback, and direct engagement with stakeholders like community councils and local authorities. This approach will continue as we work to reduce reliance on island diesel power stations through supporting establishment of new connections between islands and mainland and explore the use of alternative, non-fossil-fuel based solutions to diesel for back-up supply.

SSE Thermal continue to engage with the community in Peterhead and the surrounding area regarding the development of the Peterhead 2 CCS power station. The Stage 2, formal consultation for the Peterhead CCS Power Station project took place from 23 August to 1 October 2021. SSE plans to continue its public engagement efforts, which will include further community consultations and participation in local events.

Other proposals are aimed at influencing or working with the UK Government and the National Energy Systems Operator (NESO), for example, regarding the Review of Electricity Market Arrangements (REMA) and the Strategic Spatial Energy Plan (SSEP). Public consultations will therefore, be led by NESO or the UK Government. There have been several public consultations ran by the UK Government on REMA, with an initial public consultation published in July 2022. This was followed by a second public consultation in March 2024, ahead of the July 2025 summer update from the UK Government. The SSEP draft will be published for consultation in early 2027.

2.7.4. Land Use, Land Use Change and Forestry

2.7.4.1 Forestry

As stated, the primary mechanisms for public consultation on the Climate Change Plan to date have been an extensive consultation to inform the Scottish Government’s Forestry Strategy 2019-2029, of which woodland creation is a key priority; and the ongoing community engagement and detailed consultation processes for woodland creation in line with the Land Rights and Responsibilities Statement and Scottish Forestry’s EIA public register. Local engagement and dialogue have led to the development of various initiatives to support woodland creation, such as the farmer-led Integrated Trees Network.

2.7.4.2. Peatlands

As noted above, a public consultation on “Ending the sale of peat in Scotland” was carried out from February to May 2023. Of 552, respondents, 8% represented the commercial horticulture industry. Responses show that horticultural peat was seen as essential in propagation and in production of potatoes or mushrooms. Lack of alternatives to peat, higher costs of alternatives, training needed, and potential for increased wastage and crop failure were all identified as barriers to banning the sale of peat for horticulture. Subsequent stakeholder workshops revealed that, whilst major retailers are less concerned about transition, certain growers are yet to identify suitable alternatives to peat and there is concern that the benefits provided by “Environmental Horticulture” may be compromised if peat is phased out of horticulture too rapidly.

2.7.5. Buildings (Residential and Public)

We consulted publicly on proposals for a Heat in Buildings Bill between November 2023 to March 2024, with over 1,500 responses received.[10] In January 2025 we published the analysis of the consultation responses.[11] We also consulted on proposals for regulations introducing a Minimum Energy Efficiency Standard for the domestic Private Rented Sector between June and August 2025. On EPC Reform, the Scottish Government has consulted three times prior to laying the new Regulations (2021[12], 2023[13] and 2025[14]). We have also conducted broader engagement, including sector specific engagement, for example, through the public consultation on the draft Heat in Buildings Strategy, which was published in 2021.

2.7.6. Transport

On car use reduction, engagement was carried out with business throughout the consultation period for the draft route map, and throughout the development of our updated approach published in the renewed policy statement on car use reduction.

The publication of the draft Vision Implementation Plan in December 2024 sets out a route map to deliver on our vision and ambition to deliver a comprehensive and convenient network that meets the needs of users and is funded by private investment by 2030 largely financed by the private sector. Following its publication, an online consultation alongside two physical workshops in Glasgow and Inverness were held with stakeholders across Scotland and the UK to refine the actions necessary to meet the public charging ambition. The final Vision Implementation Plan is due to be published in 2026.

2.7.7. Waste Management

Relevant public consultations in the Waste Management sector have already been conducted. Two Circular Economy and Waste Route Map consultations were conducted in 2022 and 2024, both of which had consistently high levels of support for the proposals. A public consultation on proposals for the Circular Economy Bill was conducted in 2022 (now Act)[15] and in October 2025 a public consultation was held, helping to shape the recently published Circular Economy Strategy.[16] A consultation[17] on initial proposals to tackle the significant environmental impact of single-use drinks cups was also conducted. The analysis of the responses has been published.[18] The Scottish Government undertook a consultation on strengthening approach to household recycling collection services, including the current approach to the rural food waste exemption and the approach to textile recycling.[19] Further, there was a call for evidence to support consideration of extending Scotland’s biodegradable municipal waste landfill ban to potentially include non-municipal biodegradable (and other) waste, published in 2025.[20]

There is a planned consultation following the co-design of the new Household Recycling Code of Practice. Consultation is planned to be launched before the end of 2026 following the conclusion of the co-design process.

Contact

Email: ClimateChangePlan@Gvov.Scot

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