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

Information and data management

This section sets out the minimum requirements for Approved Organisations in relation to providing, handling and storing data.

5.1 Provision of information for members

5.1.1 AOs must provide their EPC assessor members with access to all documentation which details procedures associated with their role as an EPC assessor and operation as a member of the AO.

5.1.2 This must include support by email and telephone contact points to enable EPC assessor members to seek assistance where matters cannot be resolved by reference to documentation.

5.1.3 AOs must record and analyse enquiries from EPC assessor members to support review and improvement of both procedures and supporting documentation.

5.1.4 AOs must inform EPC assessor members of changes in software requirements and conventions.

5.1.5 AOs must notify, and agree with, the Scottish Ministers, any guidance that they will issue to EPC assessor members, relevant to the assessment activities they are accredited to undertake.

5.1.6 AOs must take all reasonable steps to inform EPC assessor members of known operational disruption (for example, planned EPC Register maintenance) as far in advance as possible.

5.1.7 AOs must allow prospective EPC assessor members access to membership pricing information.

5.2 Provision of information for members of the public

5.2.1 AOs must enable easy access by members of the public to information on the AO, its aims and operation, and its EPC assessor members.

5.2.2 This must include at least the following information:

• full telephone, electronic, and postal contacts for the AO (including contacts for all key members of staff)
• application procedures, requirements for membership, and schedule of all charges related to the production and lodgement of EPCs in Scotland; and
• general information about EPCs, why they are required, how building owners and occupants can make use of the information they provide, national resources for further information, and advice on improving the energy performance of buildings

5.3 Provision of information for enforcement authorities

5.3.1 AOs must co-operate with a request for information from any enforcement authority acting to meet their duty under legislation.

5.4 Minimum requirements for review, record keeping and sharing of data

5.4.1 AOs must review their procedures and documentation on a regular basis to ensure they remain relevant to operations.

5.4.2 As a minimum, this must address changes:

• to meet amended requirements issued by the Scottish Ministers
• arising from changes in the approved calculation methodologies; and
• where improvements are identified by internal review or examples of wider good practice

5.4.3 A summary of such changes must be provided to the Scottish Ministers on an annual basis.

5.5 Data management and protection

5.5.1 AOs and their members must be familiar with and comply with prevailing Data Protection legislation and other relevant regulatory requirements, and also be familiar with and comply with the provisions set out within Regulations 16-20 of the 2025 Regulations.

5.5.2 AOs must notify the Scottish Ministers of a data breach no later than 24 hours after becoming aware of this breach.

5.6 Energy performance data on the Scottish EPC Register

5.6.1 As set out within Regulation 12(3) of the 2025 Regulations, AOs are responsible for:

• “ensuring that energy performance data is sent to the relevant register by members of the scheme”; and
• “requiring members of the scheme to prepare energy performance certificates and property reports using a standard form for each type of document”

5.6.2 In accordance with Regulation 14 of the 2025 Regulations, EPC assessor members must ensure that, prior to issuing an EPC or Property Report, they send energy performance data to the Scottish EPC Register.

5.6.3 AOs must establish an operational procedure for EPC assessor members to send energy performance data to the Scottish EPC Register (including any future simplified procedures or otherwise specified by the Scottish Ministers).  

5.6.4 AOs should have in place procedures which record Report Reference Numbers (RRNs) of the EPCs which have been lodged.

5.6.5 Any software used by AOs must be compliant with the relevant National Calculation Methodology as approved by the Scottish Ministers under Regulation 10 of the 2025 Regulations. An AO’s software must be demonstrated to produce accurate EPCs.

5.6.6 Where an EPC is produced by an AO’s EPC assessor member for an excluded building (as defined in Regulation 2 of the 2025 Regulations), the EPC assessor must accurately record that the EPC relates to an excluded building. The AO must establish an operational procedure for EPC assessor members to record and communicate this excluded status to the Scottish EPC Register.

5.6.7 AOs and their members must comply with the requirement to store assessment data and energy performance data securely, for audit purposes only.

5.6.8 AOs will inform their EPC assessor members that data they collect under the requirements of the 2025 Regulations is for the purpose of producing EPCs and Property Reports only.

5.6.9 The Energy Performance of Buildings (Scotland) Regulations 2025 do not permit AOs or their EPC assessor members to share, sell, or otherwise disclose assessment data or energy performance data in any manner that is not compliant with the requirements of the 2025 Regulations, in particular Regulation 18.

5.6.10 Data obtained by the AOs or their EPC assessor members shall be confidential, where it is not covered by the requirements to provide that information to their AO, to the organisation or individual who has commissioned the work, and for other formal requirements under the 2025 Regulations, including lodging the data on the appropriate Register.

5.6.11 AOs should have access to copies of any software used by their EPC assessor members so that they can undertake quality assurance checks on their work.

5.6.12 AOs are required to make available any documentation to the Scottish Ministers, or their agents, on request and are expected to make quarterly reports to the Scottish Ministers detailing relevant information and data for EPC assessors and EPC activity.