Private rented sector - minimum energy efficiency standard: tenant engagement research report

Executive summary

The Scottish Government is proposing the introduction of a Minimum Energy Efficiency Standard (MEES) applying to properties in the Private Rented Sector (PRS). The aim of this policy is to improve the quality of PRS homes and reduce the energy demand of heating homes, benefiting the environment and PRS tenants where approximately 44% of dwellings are estimated to be in fuel poverty.

A public consultation^[1] into these measures took place between 6^th June 2025 and 29^th August 2025, but tenant voices were under-represented in this process. Therefore, the Scottish Government commissioned Thinks Insight and Strategy to conduct qualitative research with PRS tenants to support the consultation.

This research was designed to ensure PRS tenant views are thoroughly heard as part of the policy development process and that any potential unintended consequences of the policy’s introduction are identified so they can be guarded against. The Scottish Government wanted to hear from tenants across the PRS, including those who might be most impacted by the changes, for example those living in vulnerable circumstances or who live in areas with low PRS housing stock.

The research employed focus groups and interviews with 36 participants, all tenants in the private rented sector. The aims of this research were to:

• Understand tenants’ opinions regarding the proposed MEES across a sample of participants from varying socioeconomic backgrounds and EPC rated properties.
• Identify potential impacts of the MEES to ensure the legislation is effective in its implementation and re-emphasise its expected benefits.
• Explore any concerns regarding the MEES to mitigate negative consequences that may affect tenants and highlight any challenges that may not have been considered previously.
• Understand if there are any groups of tenants that might be more specifically impacted by legislation because of their needs or personal circumstances.

Findings from this research highlight that energy efficiency in the PRS was widely felt to be poor by research participants, due to inadequate and inefficient building infrastructure which does not regulate temperature well. Most participants face challenges keeping a property warm, with poor energy efficiency making high energy bills a key concern for participants in the context of rising living costs. Many reported forgoing heating their homes or relying on short-term fixes that do little to improve their comfort or health.

Though many participants had raised these issues with their landlord, few had seen responses or lasting improvements. Most improvements reported were generally partial or low-quality. Due to the temporary nature of renting, many are reluctant to invest in improvements themselves, or are restricted by landlords withholding permission for works.

While most participants were aware that their landlords should offer a certain standard of living in their properties, they did not recall the specific requirements that are currently placed on landlords in the Scottish Private Rented Sector. When prompted with information on the proposed MEES regulations, most participants understood this as introducing a requirement for landlords to make infrastructure improvements that directly address energy efficiency challenges experienced by tenants. With trust in landlords low, participants responded well to the legal obligation for change that the proposed MEES offer.

Participants expected the proposed MEES to improve the experience of living in their property and directly address challenges around warmth and comfort, bettering living standards. The measures were understood to reduce the energy wasted heating homes, potentially reducing bills and financial pressures on tenants. Through warmer homes, less damp and mould, and decreased stress about paying for inefficient heating, benefits were also expected to include improved physical and mental health. Ultimately, participants saw the proposed regulations as a move towards improving the housing standards in the Scottish PRS.

However, participants were not confident in the positive impact these measures would have on them in practice. Many expressed significant doubts that landlord compliance would be consistently monitored and enforced. There were concerns that the long lead-in period could delay or ultimately prevent improvements, and that exemptions around consent, tenure types, fabric of property, and cost-caps are easily exploitable for landlords who seek to evade compliance.

If enacted, the most pressing risk of MEES identified by participants was a potential loss of affordable housing as landlords pass on costs of improvements, which would price existing tenants out of local rental markets. Lower housing availability was also a key concern if landlords chose to sell their properties or otherwise remove them from the long-term rental market. To a lesser extent, there was also uncertainty that landlords would carry out works to suitable standards, meaning mandated improvements may unintentionally worsen the quality of some properties. Improvements to properties were also expected to cause disruption and displacement, leading to worries about the availability of temporary accommodation and local authority capacity to support disadvantaged tenants.

Participants sought assurances that safeguards to prevent unintended consequences are in place, tenant rights and accountability processes would be clearly communicated, and that advice and support would be available for anyone at risk of being negatively impacted by the introduction of a MEES.