Scotland's draft Climate Change Plan 2026-2040: business and regulatory impact assessment
Business and regulatory impact assessment (BRIA) of the draft Climate Change Plan (CCP) 2026 to 2040.
Section 2: Engagement and information gathering
Engagement approach
The Scottish Government has engaged and consulted extensively in preparing this draft 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.
The draft Climate Change Plan will now proceed to its statutory consultation period. During this period Parliamentary and wider public views are expected to help feed into the final Climate Change Plan. The Scottish Government will deliver a programme of public engagement to make the consultation as active and inclusive as possible.
The draft 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 will either 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 draft Climate Change Plan, particularly for pre-existing policies. Nonetheless, previous engagement on individual policies informs the work undertaken as part of the draft Climate Change Plan development and has therefore been included in this document.
Internal SG engagement/engagement with wider Public Sector
Internal SG engagement
The draft 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. 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.
Wider Public Sector
Engagement across the wider public sector on elements of the draft Climate Change Plan has included:
- Scottish Environment Protection Agency;
- NatureScot;
- Zero Waste Scotland; and
- COSLA.
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 draft 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.
International
The main aim of the draft 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 draft 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.
Business/Third Sector engagement
The Cabinet Secretary for Climate Action and Energy meets regularly with environmental non-governmental organisations (eNGOs) to discuss progress on Scotland’s climate change commitments, challenges facing the sector and opportunities for collaboration.
Research and Evidence Base
The Scottish Government would like to express its thanks to the following organisations which have contributed views during the development of the draft Climate Change Plan.
The Science Base
The Scottish Government regularly commissions research projects through ClimateXChange (CXC) to explore climate-related topics, identifying opportunities, barriers, costs and benefits. CXC also commissions research and analysis to support the Scottish Government as it develops policies on adapting to the changing climate and transitioning to net zero.
The development of the draft Climate Change Plan has been informed by discussions with the First Minister’s Environmental Council (FMEC) and Scottish Science Advisory Council (SSAC). FMEC advises the Scottish Government on international best practice and the government has sought input from FMEC on its strategic approach to climate change. SSAC is “Scotland’s highest level science advisory body” providing independent advice to the Chief Scientific Adviser for Scotland and to Scottish Ministers. We have run early career researcher workshops with SSAC to support the development of the draft Climate Change Plan.
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 draft Climate Change Plan. CCPAG members include opposition MSPs and other political representatives, public sector officials, representatives from industry, 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 draft 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 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.
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.
Climate Change Plan Engagement
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. The draft Climate Change Plan is now entering its statutory consultation period, during which Parliamentary and public views will inform the final plan. Engagement with stakeholders will continue throughout the Climate Change Plan Parliamentary scrutiny period. Several policies and proposals under the Agriculture Reform Programme (ARP) and other processes will include further stakeholder engagement as appropriate.
Additionally, we have engaged with the UK Climate Change Committee (CCC) and Stop Climate Chaos Scotland (SCCS) as stakeholders across the suite of Climate Change Plan policies and proposals.
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) involves meetings between the FAST Chair and a named ARP official, with other officials attending occasionally. These meetings are usually online, with occasional in-person sessions. Members also receive updates, surveys, and materials for comment via email.
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.
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. Additional ad hoc engagement occurs via meetings, phone calls, and emails.
Bilateral Engagement and Wider Communication (Primarily via ARP)
Engagement also takes place through bilateral meetings with stakeholders, either in person, online, or via email. Wider communications, detailed below, are principally about informing stakeholders rather than engaging them directly:
- Customer Mailings: in July 2024: Letters sent to all farmers and crofters who completed a Single Application Form in 2024, outlining changes for 2025 and where to find further information and support. In June 2025: Letters sent to approximately 19,000 farmers and crofters who completed a Single Application Form in 2025, outlining changes for 2026.
- Events: in 2024, the ARP Road Show attended 26 events across the country to speak directly with farmers and crofters. Attendance at shows and markets will continue in 2025.
- Paid Media: guides to 2025 changes were published in The Scottish Farmer in November 2024 and February 2025.
- Online Content: the Scottish Government funds Scotland’s Farm Advisory Service, which promotes changes through in-person and online events, podcasts, and videos.
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.
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 draft 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.
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.
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.
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 any future regulations introduced and for the publication of the Heat in Buildings Strategy and Delivery Plan in 2026.
Officials have met with the independent Regulatory Review Group (RRG) to discuss Heat in Buildings policy.
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, 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.
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 policies 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 policies 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 draft Climate Change Plan BRIA contains further information on this topic. Evidence informing EfW policies 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 cover waste.
We have likewise coordinated with colleagues working on the business and industrial processes chapter regarding the Acorn Project and Scottish Cluster. Our policy 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 & Decommissioning (OPRED), Trade Unions and NGOs.
The draft 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 & 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.
Land Use, Land Use Change and Forestry
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.
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 and the New Deal for Business. 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.
The majority of regional and local engagement on peatland restoration is undertaken by intermediaries and our delivery partners including NatureScot, the two National Parks, Forestry and Land Scotland and Scottish Water. There is an expectation that where private investment is a factor in projects that the Principles for Responsible Investment in Natural Capital[2] are followed including community engagement. The Scottish Land Commission has issued on this and supports a good practice programme. This also evaluates the extent and quality of community engagement in land use projects.[3] on this and supports a good practice programme. This also evaluates the extent and quality of community engagement in land use projects.
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.
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. Potential impacts on key business stakeholders will continue to be assessed as part of this process, and we will continue to take forward engagement and collaboration in line with the principles of the New Deal for Business.
Engagement approach
Collaboration and partnership have been critical to our progress so far, and we can only be successful if everyone plays their part – government, households, communities, charities and businesses. Our engagement approach to developing policies and proposals for the waste sector chapter has been and will continue to be guided by both the Verity House Agreement and New Deal for Business Group's recommendations and implementation plan. 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.[6]
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 Regulatory Review Group, 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 has also recently been reestablished and 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.[7] 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 & 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[8]. 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 to be 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 draft 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, to guide the development of the Residual Waste Plan, we will establish an advisory panel. We believe this collaborative approach is vital to draw upon the expertise across these sectors and build joint ownership and the confidence needed to invest in infrastructure across the resource recovery chain.
Transport
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. All of these contributions can be seen to contribute to the commitments within the draft Climate Change Plan.
We continue to progress development of our data, monitoring and evaluation framework and processes that will assist in us responding to the Audit Scotland recommendation to report against the impact of the new delivery models by end 2025.
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. The taskforce held a series of meetings, established working groups and commissioned research and analysis. These underpinned the production of the HGV Decarbonisation Pathway for Scotland in March 2024, 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, culminating in a meeting in March 2025. 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. A first version of the research was published in September 2024 with a second iteration in March 2025 and 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 by Transport Scotland 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 and shaped by the standards set by the Institute of the Motor Industry (IMI) and other relevant bodies.
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. These meetings provide an overview of issues affecting the sector, including sustainability of 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 heavy and specialist vehicles, this work has been informed by a series of workshops with public sector fleet managers, and the draft action plan is expected to be published late 2025.
Electric vehicles
The UK Government, as the secretariat for the four nations Vehicle Emissions Trading Schemes legislation, held consultations back in 2023 and again in late 2024 and a mini-consultation in the summer of 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 earlier in 2025 regarding the flexibilities to be introduced to the legislation later in that year.
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.
On the public charging side, 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 the route map to approximately 24,000 additional public charge points 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 by the end of 2025.
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 in April 2025 providing flexibilities while maintaining the headline targets to 2030. In 2027 a statutory review of the legislation will be performed looking beyond 2030 to 2035.
Aviation
The Scottish Government’s Aviation Statement, published in 2024, 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. 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.
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.
Public consultation
Following the laying of the draft Climate Change Plan in Parliament, the Scottish Government will run a public consultation on the Plan. This will cover the policies and proposals included in the Plan, and its associated impact assessments, including the BRIA. Public engagement events and activities will be delivered to make the consultation as active and inclusive as possible.
Responses to this consultation will be analysed and considered, in order to improve the final Climate Change Plan.
This section outlines consultation to date for particular sectors that has supported and informed the development of the draft Climate Change Plan.
Agriculture
The main route of public consultation to date for agriculture on the draft Climate Change Plan has been through the Agricultural Reform Programme. Public consultation was carried out as part of the Agriculture and Rural Communities Bill.
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.
Wider ‘land use’ policies and strategies, such as the draft Bioenergy Policy Statement, the Scottish Biodiversity strategy and Agricultural Just Transition plan have involved public consultation, and any further such strategies such as the next Land Use Strategy, will be subject to wider public consultation as they are developed.
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.
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 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. Officials will establish a Residual Waste Advisory Panel to draw upon the expertise across sectors. The Plan will be published in 2027, with an interim report due in 2025/26. We are committed to working closely with sector representatives in the development of the Plan.
Other policies within the energy supply sector will include public consultations, where relevant, alongside community engagement for those communities specifically affected by the policy 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 policies 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 2026.
Land Use, Land Use Change and Forestry
Forestry
As stated, the primary mechanisms for public consultation on the draft 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.
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.
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[9]. 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[10], 2023[11] and 2025[12]). 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.
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 the route map to approximately 24,000 additional public charge points 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 by the end of 2025.
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)[13]. A consultation is being undertaken on the circular economy strategy and a monitoring and indicator framework, ahead of publication in 2026. A consultation[14] 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.[15] 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.[16] Further, there was a call for evidence to support consideration of extending Scotland’s upcoming biodegradable municipal waste landfill ban to potentially include non-municipal biodegradable (and other) waste published in 2025.8
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@gov.scot