Reforms to Energy Performance Certificates outlined in draft regulations 

The Energy Performance of Buildings (Scotland) Regulations 2025 have been laid in Parliament with plan to come into force in October 2026. 

These regulations will be the principal vehicle to deliver the reforms to Energy Performance Certificates (EPCs) set out in the Scottish Government’s 2023 consultation. 

In an updated response to the previous EPC consultation, it has also been confirmed that Scottish Government has now developed its initial version of the new calculation methodology for EPCs (the Home Energy Model) which will be used to calculate the new ratings. This has been used to model the likely performance of the building stock against the principal new ratings, confirming revised bandings and a commitment that the new Band C should be as largely as possible ‘equivalent’ to the current EPC’s SAP-based Band C. This is detailed further in the stock modelling research which has been published alongside the draft regulations.  

A communications plan will be developed to ensure key stakeholders and the wider public are made aware of the EPC reforms and how these changes may affect them. 

Expected impacts are also outlined in the Equality Impact Assessment and the Fairer Scotland Duty assessment. 

Key points for SFHA members: 

The Regulations will come into force on 31 October 2026 and will continue to require that a valid EPC exists when: 

• a new building has been constructed;
• when a building is to be sold;
• when a building is to be let to a new tenant 

A one-year grace period will apply meaning that between 31 October 2026 and 31 October 2027, properties being sold or let may continue to use either valid EPCs and recommendation reports issued under the 2008 Regulations or valid EPCs and property reports issued under the 2025 Regulations. 

Developers of new buildings completed on or after 31 October 2026 will be required to give a copy of a valid EPC and Property Report that meets the requirements of the 2025 Regulations to the owner of the building within seven days of submitting a completion certificate to a local authority verifier. 

A new rating system for domestic buildings will be introduced and include the following: 

• Heat Retention Rating (reflecting fabric energy efficiency) – this has been remodelled under the new HEM with bandings adjusted to ensure around 80% of homes that are currently at EPC C would also achieve Band C or better on the Heat Retention Rating 
• Heating System Rating (covering type, emissions and efficiency) – under this system any fossil fuel heating system with direct greenhouse gas emissions could not be rated C or better, and a clean fuel could not be rated worse than C
• Energy Cost Rating (an updated version of the existing Energy Efficiency Rating) – this will largely replicate the previous Energy Efficiency Rating but will now assume s Scottish average climate rather than a UK average 

A new Property Report will set out potential improvement measures that could improve the energy efficiency and lower the energy costs of the building; and potential alternative heating systems which could reduce emissions (and their potential installation and running costs). 

The validity period of EPCs will be reduced from 10 to five years to ensure consumers have more up-to-date information. 

Strengthened operational governance arrangements for EPC assessors and Approved Organisations will be introduced through new accreditation scheme requirements. 

EPC lodgement fees will be increased to £6.00 for domestic certificates, to ensure that they can cover the costs of providing the technical and operational infrastructure to support the EPC regulations and which provide benefit to consumers. 

EPC certificates are also being redesigned – the latest version can be found here however these will be subject to further user testing prior to the new Regulations coming into force.  

Next steps: 

• The Local Government, Housing and Planning Committee will now scrutinise the draft regulations in more detail, building on the evidence session held last month
• Scottish Government will engage with relevant stakeholders, including landlords, in the period in between the Regulations becoming law and coming into force.
• SFHA will be facilitating further engagement with government on the impacts on social landlords and the interactions with the forthcoming Social Housing Net Zero Standard – and invite members to contribute via our Energy and Net Zero forum (next meeting 6th November) or by contacting cdove@sfha.co.uk