Scottish Energy Performance Certificate (EPC) Accreditation Scheme: operating requirements

Administration of EPC assessors

This section sets out the minimum requirements that Approved Organisations must maintain for the ongoing administration and management of EPC assessor members.

3.1 Insurance

3.1.1 As set out within Regulation 12(3) of the 2025 Regulations, AOs are responsible “for indemnity arrangements in relation to owners and prospective or actual buyers or tenants”.

3.1.2 AOs must require assessor members (for example, through any Terms and Conditions of membership/ Code of Conduct) to have and maintain suitable insurance cover proportionate to the risks associated with the provision of an EPC for the type and scale of buildings where an assessment is undertaken.

3.1.3 Minimum insurance levels for each claim in relation to any particular EPC are as follows:

Category	Professional indemnity	Public liability	Run-off cover
Domestic – new build	£50,000	N/A	10 years
Domestic – existing	£50,000	£1,000,000	10 years
Non-domestic	£250,000	£1,000,000	10 years

3.1.4 Where AOs do not provide insurance as part of membership (this is not a requirement of appointment as an AOs), they must undertake checks to verify that members maintain insurance cover, including spot checks where there is evidence of a member operating without or with inadequate cover.

3.1.5 Assessors knowingly certifying without the appropriate insurance must result in revocation of authority to produce EPCs. This will include assessor membership of the Scottish EPC Accreditation Scheme being revoked (upon notification by the AO to the Scottish Ministers).

3.2 Assessor Code of Conduct

3.2.1 As set out within Regulation 12(3) of the 2025 Regulations, AOs are responsible “for ensuring that a code is produced and published as regards the conduct required of its members”.

3.2.2 AOs must have in place a published Code of Conduct to which all members are required to adhere to.

3.2.3 The Code of Conduct must include a description of the service level that members of the public can expect from accredited EPC assessors.

3.2.4 The published Code of Conduct must include the following:

a) a requirement to operate only within their assessor competence and act in accordance with the provisions of the relevant NOS

b) a requirement to identify an appropriate level of insurance cover and maintain that cover

c) a requirement to declare any conflict of interest when undertaking the EPC assessor role

d) a requirement to maintain evidence of assessments in sufficient detail to enable audit

e) a requirement to advise all customers of the process to follow if they have a complaint about any aspect of the EPC assessment (including escalation to their AO)

f) a requirement to maintain a record of complaints received in relation to their assessment role and outcome

g) a requirement to notify their AO of any complaints that are unresolved by the EPC assessor within 2 weeks of receiving it

h) a description of activities which are a breach of the code and which will result in disciplinary action

i) a requirement to operate to an appropriate safety standard

j) a requirement to decline offers of gifts, hospitality or inducements that may be perceived as jeopardising the objectivity of an EPC assessment;

k) a requirement to have, and be prepared to show, identification at all times when conducting their duties on site

l) a requirement to cease or not commence an assessment if requested by the building occupier, owner, landlord, or a person acting on their behalf

m) a requirement to not undertake an assessment of a building in which there are unaccompanied children or unaccompanied vulnerable persons

n) a requirement to communicate to the building occupier the purpose and the process of an EPC assessment, and reason for collecting photographs and data

o) a requirement to explain to customers how the resulting EPC can be accessed

p) a requirement to not misrepresent their role as an EPC assessor; and

q) a requirement to do nothing that brings EPCs or the EPC process, the AOs, the Scottish Ministers, or the energy assessment industry into disrepute

3.2.5 AOs must ensure there is a signed declaration of acceptance of this Code of Conduct by their assessor members.

3.3 Operational record of assessor activity

3.3.1 To support both operation and audit, AOs must maintain records for applications and activities of current and previous EPC assessor members, detailing all operational processes applied to members and to outcome of such processes.

3.3.2 As a minimum, records must include the following details of assessor activity:

• ongoing insurance cover
• ongoing CPD record
• results of quality assurance checks and any remedial actions required of assessors
• assessor communications with AOs and responses; and
• customer queries, complaints, or claims, and any remedial action required of assessors

3.3.3 The level of detail required should provide AO staff with a clear audit trail for any complaint, query, quality assurance check, or CPD return.

3.3.4 It is the responsibility of AOs to ensure that the requirements of the relevant Data Protection legislation, and other legislation relevant to the form and content of data stored, are met.

3.4 Continuous Professional Development (CPD)

3.4.1 AOs must ensure that EPC assessors members undertake relevant training to support the ongoing development of the assessment services they offer, including when requested to or specified by the Scottish Ministers under the terms of its approval of the Scottish EPC Accreditation Scheme.

3.4.2 While there is no minimum required length of time per annum for CPD specified by the Scottish Ministers, the Scottish Ministers reserve the right to introduce this (if deemed necessary) at a later date.

3.4.3 CPD should be relevant to activity of a member as an EPC assessor and may include specific provisions mandated by the AO, or by the Scottish Ministers, such as:

• reporting practice for assessors (as specified by the AO)
• amendments to EPC methodologies and software upgrades
• access and use of the EPC Register
• developments in construction products and building services as they relate to potential improvement measures
• changes to the Energy Performance of Buildings Regulations (Scotland) 2025 and other legislation or initiatives which have relevance to the assessor role (including updates to the relevant NOS for energy assessment); and
• any other matters deemed relevant by individual AOs or notified by the Scottish Ministers in relation to EPC assessor competence (including changes to audit requirements)

3.4.4 AOs should ensure a record of such activity is submitted on an annual basis by EPC assessor members. These must be made available to the Scottish Ministers, or any auditor acting on their behalf, upon request.

3.4.5 AOs must verify that records are submitted and carry out sample checks (at least 5% of their membership per annum) to verify that CPD activities are relevant to the EPC assessor role.

3.4.6 AOs should also consider (or when requested to do so by the Scottish Ministers) further upskilling opportunities for EPC assessor members, to ensure EPC assessment is an attractive, viable career pathway.

3.5 Assessor complaints and appeals procedures

3.5.1 As set out within Regulation 12(3) of the 2025 Regulations, AOs are responsible “for facilitating the resolution of complaints against members of the scheme”.

3.5.2 AOs must have a published Complaints Procedure, which is applied consistently and responds promptly and efficiently to customer complaints against assessor members or the quality of EPCs.

3.5.3 AOs must have a published Appeals and Disciplinary Procedure in-place in the event that a complaint requires further investigation and action.

3.5.4 AOs must inform EPC assessor members that they are required to have their own complaints procedure, which they must disclose to any stakeholder on request.

3.5.5 As a minimum, an AO’s complaints, appeals and disciplinary processes must include details of:

• initial response to any complaint, information on process to be provided to the complainant and evidence needed to progress investigation and timescale for resolution
• investigative action to be taken, including notifications to relevant parties and checks to determine whether there are any previous complaints against the assessor who is subject of the complaint
• disciplinary hearings and appeals process(es)
• composition of disciplinary and appeals panels and appeals process(es)
• timescale for all actions; and
• processes for any corrective action resulting from investigation.

3.5.6 Where an EPC assessor member has failed to deal with a complaint professionally, the AO has the right to recover costs from the assessor. These terms must be made clear to all EPC assessor members, and it is expected that this will only apply in exceptional circumstances.

3.5.7 Where an EPC assessor member has membership of more than one AO, the EPC assessor member will inform the AO (that the EPC was lodged through) of any complaint.

3.5.8 Where a complaint is found to be vexatious, the AO may refuse the individual access to their complaints process and will disclose such instances to the Scottish Ministers. In these circumstances, the AO must inform the complainant in writing why they consider the complaint to be ‘vexatious’ and why they will not be allowed access to the complaints process.

3.5.9 AOs will not refer individual complainants or their members to the Scottish Ministers for adjudication. Where complaints cannot be resolved to the complainant’s satisfaction, matters must be referred to an independent third party appeals panel for a decision.

3.5.10 Any complaint which involves apparent criminal activity must be reported to the relevant authorities immediately, and the assessor member suspended pending further investigation.

3.5.11 Prospective AOs, as part of the approval process, must demonstrate to the Scottish Ministers how independence is maintained within their complaints escalation process.

3.6 Complaints register

3.6.1 AOs must maintain a register of all complaints sent to them and provide a quarterly breakdown in a format prescribed by the Scottish Ministers.

3.6.2 As a minimum, this will detail the number of complaints received, the status of each complaint, whether this was escalated, and any corrective action taken (including any re-training undertaken by assessor members).

3.7 Disciplinary procedures

3.7.1 AOs must have appropriate disciplinary procedures in place for the following circumstances:

1. audit failure
2. breach of obligations (for example, a lack of appropriate insurance cover or failure to pay membership fees); and/ or
3. failure to be considered a ‘fit and proper person’

3.7.2 Temporary suspension can be applied in appropriate circumstances. Permanent removal (revocation) of membership can be applied in appropriate circumstances. In certain circumstances, the Scottish Ministers must be notified, so action can be taken to suspend or revoke the individual’s membership of Scottish EPC Accreditation Scheme itself.

3.8 Changes to disclosure status

3.8.1 EPC assessor members must supply their AO(s) with an updated Disclosure certificate every 3 years or on request from the AO. 

3.8.2 EPC assessor members must inform their AO(s) of any incidents that would appear on an updated Disclosure certificate. The AO must then determine the relevance of the incident to the assessor’s continued membership.