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

Governance

This section sets out the expected working relationship between Approved Organisations and the Scottish Ministers.

6.1 Appointment of Approved Organisations

6.1.1 AOs will be approved by the Scottish Ministers to operate for the period indicated in their letter of appointment. As set out in Regulation 11(2)(b) of the 2025 Regulations, the terms of this approval may be subject to such conditions and limitations, including as to duration, withdrawal of approval and the matters mentioned in Regulation 11(3), as the Scottish Ministers consider appropriate.

6.1.2 If an appointed AO wishes to expand the categories for which they are appointed, they must contact the Scottish Ministers to discuss this variation.

6.1.3 As part of the approval process, prospective AOs must provide a 3 year business plan. As a minimum, this should contain the following:

• breakdown of operational costs and anticipated income streams
• estimated EPC numbers
• estimated numbers of potential assessors; and
• geographic area within which the membership will operate

6.1.4 During the future re-appointment process, an updated business plan must be provided to the Scottish Ministers upon request.

6.1.5 Re-appointment of AOs will be dependent upon compliance with the requirements set out in this document.

6.1.6 The Scottish Ministers will monitor compliance across the following key areas:

6.1.7 In instances where compliance is not achieved, the Scottish Ministers will record this information and this will be taken into consideration during future AO re-appointment processes. A scoring matrix may be used to help determine whether or not an AO should be re-approved.

6.2 Reporting requirements

6.2.1 AOs must complete and return quarterly reports to the Scottish Ministers, detailing relevant information and data for energy assessors and EPC activity. This is in addition to the aforementioned annual financial reporting.

6.2.2 As a minimum, these reports will seek information on:

• new assessor information
• audit outcomes
• complaints
• appeals
• disciplinary actions
• cases of fraud or suspected fraud

6.2.3 The Scottish Ministers reserve the right to publish the summaries of these reports on an annual basis.

6.3 Audit of Approved Organisations

6.3.1 Each AO will be subject to audit by the Scottish Ministers, or by an organisation appointed on their behalf, every 12 months.

6.3.2 A programme for audit will be developed by the Scottish Ministers, and notice of audit will be provided at least 2 months in advance.

6.3.3 Information to support the audit process, including reporting requirements, will be defined and provided to AOs.

6.3.4 AOs must:

• allow monitoring of operations periodically to ensure that it continues to meet the terms of its approval. This includes access to their operations and records for audit; and
• maintain records in a form that allows audit of the successful implementation of the functions set out in this document

6.3.5 Records may be kept either electronically or on paper, and AOs must demonstrate to the Scottish Ministers’ auditors how such records can be retrieved if necessary. Back-up data must be stored in such a way that it can be reasonably expected to survive instances which might affect the original material stored by the AO (for example, fire or theft).

6.4 Approved Organisations’ complaints

6.4.1 AOs must have an independent complaints process for their members who are dissatisfied with the conduct of the AO. This should be available at no cost to the member.

6.4.2 AOs must have an independent complaints process for other stakeholders who are dissatisfied with the conduct of the AO. This should be available at no cost to the stakeholder.

6.5 Adjustments or modifications to the accreditation scheme

6.5.1 The Scottish Ministers reserve the right to periodically review and update the Scottish EPC Accreditation Scheme, and to impose such conditions or limitations as they consider appropriate as specified by Regulation 12 of the 2025 Regulations.

6.5.2 Ultimate decision-making authority on the requirements of the Scottish EPC Accreditation Scheme, and the conditions or limitations of appointment for an AO, rests with the Scottish Ministers, in accordance with Regulations 11 and 12 of the 2025 Regulations.

6.5.3 The Scottish Ministers, in exercising that authority, will establish a forum with AOs to allow the AOs to put forward suggestions for adjustments or modifications to the Accreditation Scheme, and for the Scottish Ministers to inform AOs of their intention to introduce modifications.

6.5.4 The frequency of this forum will be agreed with AOs at the earliest opportunity, and this document will be updated to reflect that decision.