Jan 22, 2025
Minister for Climate Action: Alasdair Allan
Ministerial Foreword I am pleased to set out the Scottish Governmentâs response to the 2023 Energy Performance Certificate (EPC) Reform Consultation.
EPCs play a key role in Scotlandâs property market, ensuring that current or potential owners and tenants have information on a propertyâs energy efficiency and emissions, and on potential improvements. Over 200,000 are issued every year, engaging with a range of households, workplaces and community buildings across Scotland.
They are therefore a foundation for our Heat in Buildings Programme, and it is essential that they contain the information that consumers need to be able to make informed choices when moving home or considering making changes to their property.
The Scottish Government has a long-standing commitment to improving Energy Performance Certificates (EPCs) and stakeholders such as the statutory Climate Change Committee or consumer bodies such as Which? have long-advocated the need for reforms that ensure EPCs are of higher quality and provide better information that is aligned with net zero policy objectives.
Following an initial scoping consultation in 2021, we consulted again in 2023 on a final package of proposed reforms to improve the quality of EPCs and make them more fit-for purpose in supporting net zero. The Scottish Government is pleased to confirm as part of this Government Response that we will lay revised EPC regulations in Parliament during 2025, with an intention to bring them into force in 2026.
These regulations will introduce an improved EPC rating system which will give consumers better information on the actual fabric energy efficiency of their property and on the emissions and efficiency of its heating system, and on potential improvements they could make to both.
We will also retain the rating on modelled energy costs which consumer testing tells us is so important to them at this time of sustained high energy prices. That user testing has also allowed consumers to tell us how to make the design and accessibility of EPCs better, and we can confirm that introduction of a redesigned certificate will coincide with the regulations bringing the new rating system into force.
An initial version of this redesign is included in this response and will be subject to further testing before regulations come into force.
It is vital that consumers are able to trust the EPC assessment process, and the Scottish Government is therefore pleased to confirm that we will be introducing alongside the new regulations, strengthened operational governance arrangements for the EPC assessor market to enhance quality assurance for consumers.
These arrangements will form part of negotiations with the UK Government and other devolved administrations on assessor skills and qualifications within the UK internal market, and will coincide with the introduction of a new technical infrastructure to replace the current Standard Assessment Procedure with the Home Energy Model calculation methodology, together with a new EPC Register.
Our reforms to EPCs aim to remain aligned with the EU Energy Performance of Buildings Directive, from which EPCs originated across the EU, where it is desirable and feasible to do so. In the period since our consultation on EPC reform closed in 2023, the EU has subsequently adopted the recast Directive in April 2024. Our proposals for EPC reform would already broadly align with the Directiveâs provisions.
One area where the EU has strengthened the Directive is around quality assurance controls to audit the accuracy and reliability of certificates. This will see existing desk-based random sampling of certificates now supplemented by verification through onsite inspections. The Scottish Government believes this development across the EUâs member states is welcome to ensure the highest levels of EPC quality for consumers â particularly vital if EPCs are evidencing any proposed mandatory standards. We therefore plan to align with these requirements through establishing new audit and inspection arrangements when the revised operational governance arrangements commence.
Before laying the new regulations, we will require to undertake further consultation on the level of EPC lodgement fees, which have not been revised since 2017, and will need to be updated to support the costs of establishing the new technical infrastructure for the Register and calculation methodology.
Subject to those discussions with the UK Government and other devolved administrations, we expect to bring the new regulations, new EPC rating system and redesigned certificates into force during 2026.
In the related consultations on proposals for a Heat in Buildings Bill and Social Housing Net Zero Standard, we also considered the role that EPCs could play in supporting mandatory standards. The Scottish Government is still considering its response to these consultations and will set out its position separately, when responding to them, on how EPCs could support proposed mandatory standards.
It is right that we make these reforms to EPCs to ensure they are fit-for-purpose for the future. I am confident that the decisions set out in this Scottish Government response will make lasting improvement to the EPC system and ensure that it provides more relevant information to Scotlandâs consumers for many years to come.
Alasdair Allan
Minister for Climate Action
adoption of a new EPC rating system for domestic buildings, which will give clearer information on the fabric energy efficiency of a property; the emissions, efficiency and running costs of its heating system; and the cost of energy to run the home to standardised conditions; adoption of a new EPC rating system for non-domestic buildings; adoption of a redesigned EPC certificate, based on a first phase of user testing, and to be followed by a second phase prior to regulations coming into force; reduction of the validity period of EPCs from 10 to five years to ensure consumers have more up-to-date information; development of a new dynamic EPC user interface to sit alongside the published EPC; introduction of strengthened operational governance arrangements for EPC assessors and Approved Organisations to enhance quality assurance for consumers; establishing a new technical infrastructure to replace the current Standard Assessment Procedure (SAP) with the new UK Home Energy Model (HEM) calculation methodology, together with a new EPC Register; continuing to work with the UK Government and devolved administrations where we share elements of the EPC regulatory system across the UK internal market Rating system and redesigned Domestic and Non-Domestic certificates We will introduce a new set of ratings to appear on the Domestic EPC. These will include a Heat Retention Rating to provide information on how well-insulated the home is, on an A-G scale. Alongside this will be the Heating System Type Rating, showing the current and potential emissions category of the main heating system, thermal efficiency and running costs. The EPC will also include the Energy Cost Rating which will be based on the cost of energy to run the home to standardised conditions and will be in line with the current Energy Efficiency Rating or SAP Rating.
We are finalising how we intend to show these ratings on the redesigned EPC, including through user testing and refinement with consumer groups. The designs set out in the response show a potential approach, based on consumer testing carried out during 2024. We will continue to engage with users to refine these further in advance of regulations coming into force.
Alongside the design and ratings, we have set out our revised approach to EPC ârecommendationsâ. We have listened to stakeholders who told us that we need to be clear on the basis on which advice is provided in an EPC and therefore we will rename these suggested actions as Potential Improvement Options.
We will also reform Non-Domestic EPCs to provide clearer information about buildings, in line with our consultation. We will introduce a new set of non-domestic EPC ratings. These will include the Energy Efficiency Rating based on modelled emissions from regulated energy use[1], responding to businessâ calls that this should be in line with the rating system used elsewhere in the UK. Alongside this the EPC will show the buildingâs Direct Emissions based on modelled direct emissions from regulated energy use. The EPC will also show the buildingâs Energy Demand under standardised conditions. We will display these new ratings on a redesigned Non-Domestic certificate.
Operational Infrastructure Alongside these changes to the content and design of EPCs, we will also reform the Technical and Operational Infrastructure that underpins the quality of the EPC system. We will replace the current Standard Assessment Procedure (SAP) with the new Home Energy Model (HEM) calculation methodology, together with developing a new EPC Register that can interface with the UK Governmentâs cloud calculation service for HEM.
We will reduce the validity period of EPCs from 10 years to five to ensure people receive more up-to-date information about buildings they are considering buying or renting. We are undertaking further research to consider how an interactive EPC could benefit users. We will modernise the provisions in regulations relating to sharing non-personal data, to allow stakeholders to develop tools to use EPC data, including organisations such as Registered Social Landlords to more easily see how their stock changes over time.
We are finalising our review of the current Operational Framework that governs the delivery of EPCs in Scotland to ensure that assessments are undertaken to the highest quality standards by competent and qualified assessors. We will implement reforms through a revised Operational Framework to come into force alongside the revised regulations in 2026. We are working with other governments across the UK to agree a common approach to issues around accreditation, skills, and quality assurance.
Our response sets out our position on EPC reform. In the related consultations on proposals for a Heat in Buildings Bill and Social Housing Net Zero Standard, we also considered the role that EPCs could play in supporting mandatory standards. The Scottish Government is still considering its response to these consultations and will set out its position separately, when responding to them, on how EPCs could support proposed mandatory standards.
We intend to lay regulations during 2025 to bring these changes into force in 2026. This timetable will give time for the assessor market and those in the property letting and conveyancing sectors to prepare for these changes. We have listened to stakeholdersâ calls for the introduction of the UK Home Energy Model to be used as the basis for reformed Domestic EPCs, and so the final date on which the regulations come into force will be dependent on when HEM becomes available. We are liaising closely with the UK Government on this issue and anticipate regulations coming into force in the second half of 2026.
In order to bring these reforms into place, we will shortly issue an additional technical consultation on proposed changes to EPC lodgement fees. This will set out the increases to the EPC lodgement fee which we think will be needed to meet the cost of developing and maintaining the new technical and operational infrastructure to underpin the revised regulations, and ensure a regulatory system of the highest quality.
Ministerial Foreword 3. EPC Rating System In our consultation on EPC reform, we proposed changes to improve the EPC rating system for both domestic and non-domestic buildings.
3.1 Domestic EPCs We Asked We proposed to revise the information displayed on domestic EPCs by expanding the current ratings, renaming them to make their purpose clearer, and reporting other relevant information. This would provide a more holistic view to current and potential homeowners. We proposed to reform domestic EPC ratings to present the following headline set:
Fabric Rating â setting out the current modelled fabric performance of the building in terms of its heat loss in standard conditions, in kWh/m2/year, calculated through the SAP assessment Heating System Type Rating â clearly identifying the main heating system installed in the dwelling and whether or not it is zero direct emissions, and rating the cost and thermal efficiency of the system Cost Rating â setting out the current modelled annual costs of running the building based on the SAP assessment, and how these costs could change as a result of measures recommended. This is the same as the Energy Efficiency Rating (EER) currently displayed on EPCs Alongside these headline ratings, we also intended to report in a separate section:
Emissions Rating â setting out the current modelled total emissions from the building in kgCO2e/m²/year. This is the same as the Environmental Impact Rating (EIR) currently displayed on EPCs. Energy Indicator â reporting the modelled energy use of the dwelling in kWh/m2/year. In addition to ratings, we proposed to display the basic fabric energy efficiency features (such as whether the dwelling has cavity wall insulation or loft insulation) more prominently.
We asked the following questions on these proposals:
Do you agree with the set of metrics that we propose to display on the reformed EPC?
Are there additional metrics that you think should be included on the EPC, or metrics that you do not think should be included?
Considering our proposal to include a Fabric Rating on EPCs, do you think this metric should include domestic hot water heat demand?
Do you have a view on the way that the Fabric Rating mapped against a scale, for example, how âAâ or âGâ rated performance is determined?
Do you agree with our proposal to give more prominence to the energy efficiency features of the home (such as the depth of loft insulation)?
You Said The consultation analysis published alongside this Scottish Government response highlighted the following key findings and themes given by respondents to the five questions above.
Key Findings
Across the questions asked in this section, many issues tended to emerge repeatedly. The main findings were as follows:
Slightly greater numbers of respondents disagreed with the proposed set of ratings to display on the reformed EPC than agreed (Q1) Respondents requested more information on the costs and suitability of improvements as an addition to the ratings (Q2) A majority of respondents felt that the fabric rating should not include domestic hot water heat demand (Q3) General agreement with mapping the fabric rating against an âA-Gâ scale (Q4) Majority agreement that more prominence should be given to the energy efficiency features of a home (Q5) Key themes
Supportive statements from organisations that the proposed set of ratings are sensible General agreement with the need to raise the profile of fabric efficiency, though difficult to quantify More disagreement than agreement with domestic hot water demand being included in the fabric rating. This was because of inconsistent data and the lack of a relationship to fabric heat losses Equal support for aligning the fabric rating A-G scale with the current energy efficiency rating (EER), and for setting the bands independently of the EER Next most frequent themes
General agreement with using a 0-100 rating for the energy cost rating as monetary values will vary over time Requests for a rating to reflect the overall carbon emissions and embodied carbon Disagreements with including, or suggested amendments to, the heating system type, and requests for further detail regarding heating system classifications Concerns over the rating methodology and data accuracy, amid calls for real life fabric, energy consumption and heating system data Concerns over the accuracy of assessments (e.g. obtaining the correct information) Other themes
More consideration needed of the type of home in setting ratings, in particular regarding âhard to treatâ properties Calls to make the ratings and EPCs clear and easy to understand for non-experts in how they are presented and assessed, along with greater information provision and publicity Concerns mainly from individuals over the affordability of energy-related upgrades and improvements The accuracy of data â both in the inputs used in an EPC assessment and in the data reported by the certificate â was highlighted as a key limitation of the proposed ratings system. The accuracy of EPCs and their ratings is critical both to offer a robust assessment tool for policy and to ensure the public have confidence in the EPC system. We intend to improve the accuracy of both the input and output data by working with the UK Government on improvements to the calculation methodology (through replacing SAP with the Home Energy Model) and implementing the results of our review of the Operating Framework that underpins the quality of EPCs in Scotland.
We did not propose to introduce ratings or information based on the operational or metered energy use of a building, however we did say that we would monitor developments in this space and would consider the potential advisory role of information based on metered energy use. Any change to existing methodologies to incorporate meter data would be significant, and would likely need to be undertaken at a UK level.
As part of our proposed move to the more accessible, digital format for EPCs we have also now commissioned research to scope out the potential content for a new dynamic EPC User Interface. This would include interactive features allowing consumers to input different variables in terms of their behaviour and preferences, to understand the likely impact that this would have on their energy use â more details are set out below in section 6 below on Actual Energy Use Data.
We Will Do Domestic EPC Ratings The Scottish Government has reflected upon the consultation feedback and we have decided that we will introduce the following ratings on domestic EPCs:
The Heat Retention Rating, this will provide new information on the fabric energy efficiency of the home â i.e. how well insulated it is. We have changed this name from the âFabric Energy Efficiency Ratingâ upon which we consulted. This is because consumer testing indicated that the âFabric Ratingâ could be hard for people to understand. The rating would be based on the modelled energy required to heat the dwelling to set temperature conditions (in kWh/m2/year). This rating will be set out on an A-G scale as detailed below, and will show a current and potential rating. The Heating System Type Rating, which will show the current and potential emissions category, thermal efficiency, and running costs, of a homeâs heating system The Energy Cost Rating will be based on the cost of energy to run the dwelling to standardised conditions. This will continue to be modelled based on UK-wide fuel cost factors and normalised climate data to provide a point of comparison across Scotland and the UK. This will show a current rating, and a potential rating showing the impact of installing insulation measures and moving to the lowest running cost, non-polluting, heating system. We are finalising how we intend to show these ratings on the EPC, based on further user testing and refinement with consumer groups. The designs set out in Certificate Redesign below show a potential approach, based on our first phase of consumer testing so far. We will continue to engage with users to refine these further in a second phase of user testing between now and regulations coming into force in 2026.
Heat Retention Rating We have decided to create a new rating based on the efficiency of the buildingâs fabric. Rather than call this the Fabric Rating as proposed in the consultation, we instead will call this the âHeat Retention Ratingâ. This is because focused user testing suggested the name Heat Retention Rating is clearer to the public and easier to understand. This rating will reflect how well the dwelling retains heat, based on its insulation level and other characteristics. This rating will be shown on an A-G scale in the following bands, as set out below:
EPC Bands⯠Heat Retention Rating kWh/m2/year⯠Basis A 30 or less High level of energy efficiency⯠B 31 to 70 High level of energy efficiency⯠C 71 to 120 Good level of energy efficiency D 121 to 215 Lower level of energy efficiency E 215 to 301 Lower level of energy efficiency F 302 to 350 Lower level of energy efficiency G 351 or more Lower level of energy efficiency We have developed this rating scale with the intention that band C represents a good level of energy efficiency, broadly in line with the fabric performance of houses in band C of the current cost-based rating. By using the level of performance of the existing EPC C as the benchmark for the Heat Retention Rating band C, we will ensure that, as far as possible, most properties achieve a similar Heat Retention Rating band as their current EPC band. Bands A and B reflect high heat retention performance, while bands below C will show increasingly worse performance.
This approach is intended to maintain a level of equivalence between the Heat Retention Rating and existing cost-based EER rating. Research conducted on behalf of the Scottish Government shows that for a sample of Scottish dwellings, around 80% of homes that are currently in cost-based EPC EER band C also achieve band C in the new Heat Retention Rating. For all properties, we anticipate that around 15% would move to a better band while 10% would move to a worse band. In total, around 40% of the sample reached EPC C or better.
This means that whilst the distribution of the new Heat Retention Rating does not exactly match the distribution of the current cost-based EPC Energy Efficiency Rating, we have ensured that it is as close a match as possible. With our decision to reduce the validity period of EPCs to five years for new EPCs issued after the new EPC regulations come into force, over time increasing numbers of properties will move to the new rating system.
We know that EPC ratings will change, and acknowledge that some home and building owners and landlords will have aimed to reach the current EPC C in good faith. It will be for those policies and regulations which use EPC ratings to determine, in consultation with stakeholders, how best to manage this change. We will continue to engage in those discussions ensuring a workable and fair solution is found, where required.
Heating System Type Rating We received feedback in response to our consultation that the previously proposed Heating System Type categories were too simplistic and did not support innovation as they did not display the difference in running cost impact between systems in the same category. We have taken this feedback into account by:
Splitting the emissions categories further to include ârenewableâ and âhybridâ as distinct categories[3], and Reporting a rating for the running cost of the system, so that the benefits of high performance systems can be clearly recognised. The Heating System Type Rating will display information on current and potential emissions, thermal efficiency, and running costs. Together, this information provides a full picture of the systemâs current performance, and recognises potential technologies and products that have a lower emissions impact and running cost.
Emissions Category This rates the type of system in respect of its emissions. We will use the following broad categories which will be coloured to reflect their impact:
Table 1: Heating system type categories Category Description and examples Clean Electric (heat pump, storage heaters, direct electric), solar,âŻhydrogen, heat network Renewable Bioenergy (wood logs, wood pellets, liquid biofuels, bio-LPG etc.) Hybrid Systems combining an electric system and polluting system (or an electric system with a bioenergy component) Polluting Gas, oil, coal etc. fired heating systems Running Costs The performance of the system in running cost terms will be shown on an A-G scale. This will reflect how much it currently costs to use the system to heat the home to standardised conditions, and the potential impact of moving to a non-polluting system (where relevant). This will help provide clearer information to home owners and tenants on how moving to non-polluting heating systems will impact on the cost of heating their homes. The heating system running costs will be taken into account by the Energy Cost Rating calculation.
Thermal Efficiency The efficiency of the system in terms of thermal efficiency, on an A-G scale. This means how effective the heating system is at using fuel or energy to produce heat. This is based on the ratio between energy input and heat output.
Energy Cost Rating We have decided to retain the current Energy Efficiency Rating (often referred to as âthe EPC ratingâ or âSAP ratingâ) and rename this as the Energy Cost Rating. The Energy Cost Rating will be consistent with the current Energy Efficiency Rating[4]. This makes it more obvious that the rating is based on cost, and so would show how changes to the heating system or fabric affect the cost of running the home.
We received feedback in response to our consultation, and in testing of our proposed changes to the rating system with consumers, that information modelling âcurrentâ and âpotentialâ costs of running a home is particularly important to them. By continuing to include this renamed rating this will provide a comparative assessment of current and potential running costs to home owners and tenants, and support government policies in seeking to remove poor energy efficiency as a driver of fuel poverty.
Secondary Indicators We have decided that we will continue to include additional indicators over and above the three headline ratings, as set out below. We think that the primary ratings above provide a holistic view of the performance of a home, however, these additional indicators will provide information for interest groups who told us that this information would be useful. This includes commercial and academic users.
Table 2: Secondary indicators to be shown on the domestic EPC Indicator Measures Units Purpose Status Emissions Indicator Total direct (e.g. from a gas boiler) and indirect (e.g. from generation of electricity used in building) emissions. kgCO2e/m2/year Used for statistics Maintains consistency with UK EPC Retained Energy Use Indicator Energy used for regulated[5] purposes kWh/m2/year Supported by stakeholders as useful information New Primary Energy Indicator Energy use multiplied by a primary energy factor represent transmission losses kWh/m2/year To allow comparison with EU countries Retained We are aware that the UK Government has also now consulted on a range of other secondary indicators that could be included on EPCs in England and Wales. Once we understand the approach which will be taken by the UK Government, the Scottish Government may also include these indicators in the final design of the reformed EPC, in order to ensure that Scottish buildings can participate in any future UK-wide funding schemes where these indicators may determine eligibility.
EPC Improvement Measures (previously ârecommendationsâ) In addition to ratings, the EPC also provides ârecommendationsâ or improvement measures. We have reflected on stakeholder feedback both to this consultation and in other forums about the limits to the use of EPCs in making robust recommendations for buildings. As such, and reflecting the role for EPCs that we proposed as a basic source of information about buildings that signpost potential next steps, we have decided to rename ârecommendationsâ on EPCs as âPotential Improvement Optionsâ.
This change, alongside explanatory text, will help clarify the limits to what an EPC assessment can tell a building owner â i.e. it can give them factual information about elements of the building which require further investigation before a decision is taken to act. We will ensure that the âpotential improvement optionsâ are accompanied by clear advice on any sources of funding for these measures. They will also include clear advice on any requirement to meet mandatory standards that may be introduced in the future, such as those included in the Scottish Governmentâs consultation on proposals for a Heat in Buildings Bill and Social Housing Net Zero Standard. We are still considering our response to those consultations and will give further information on any potential role for EPCs as part of that response.
In addition, we recognise that the EPC can only provide indicative information about potential measures.
We do not want the Potential Improvement Options shown on the EPC to be mistaken for a detailed retrofit assessment so the EPC will also advise that further retrofit advice should be sought before specifying or instructing work.
We have listened carefully to stakeholder feedback on the limits to the role of EPC recommendations and on the need to protect consumers against any risk of installing measures that are not technically suitable for the building. We have begun work to review current retrofit assessment methodologies, with a view to endorsing existing frameworks, or developing new processes if required. We have proposed to develop a Heat & Energy Efficiency Technical Suitability Assessment (HEETSA) which would approve both retrofit assessment methodologies and retrofit assessors which are capable of providing more detailed technical advice beyond the EPC. We will set out further information on our decision on how to approach HEETSA in the response to the consultation on proposals for a Heat in Buildings Bill.
Potential Heat Retention Improvement Options As part of our reforms we will change the logic[6] used to determine which potential improvement measures appear on the EPC. We intend that the logic by which the EPC prioritises measures for consideration, and then selects them, will follow the logic which we would expect to be set out by any regulatory standards for energy efficiency, and would prioritise measures that are likely to be lowest in cost first. We intend to engage with expert stakeholders as we finalise this approach before the revised EPC regulations come into force.
Table 3: Illustrative approach to Potential Heat Retention Improvement Options Potential Measure Prioritisation Considered when Show if Loft insulation Dwelling has an accessible pitched roof with no insulation or some insulation between joists No insulation, or
Mineral quilt â¤150 mm
PIR/PU boards â¤75 mm
Assumed or referenced roof U-value in assessment is greater than 0.35 W/m2K
Cavity wall insulation Dwelling constructed pre-1984 and cavity wall identified as âas builtâ Assumed or referenced wall U-value in assessment is greater than 0.7 W/m2K Replacement glazing Single glazed or pre-2003 glazed units present Less than 80% of windows are identified as low emissivity (2003 or later) IGUs. Potential Heating System Improvement Options We have also reflected on feedback that the improvement measures generated in the EPC assessment and shown on current EPCs are sometimes at odds with net zero policies â i.e. where fitting a gas boiler is recommended rather than a clean heating system, because the cost of gas is significantly cheaper than electricity (even although a heat pump may be three times as thermally efficient). On this basis, EPCs do not normally currently present clean heating systems such as heat pumps as a potential improvement option.
We have therefore decided to change the way in which the EPC suggests potential improvements to heating systems. Where a polluting heating system is present in a home, the EPC will set out potential improvement options to move to a non-polluting heating system on a technology-neutral basis.
The EPC will then signpost the need to seek further detailed assessment advice to determine the most appropriate type of system for the dwelling. This would include sign posting to a Technical Suitability Assessment (HEETSA), and will also indicate potential sources of funding. (More information about this Technical Suitability Assessment will be set out in the Scottish Governmentâs response to the consultation on a Heat in Buildings Bill).
The EPC calculation methodology will apply basic logic to determine whether each of the systems above are appropriate, and therefore should be shown on the certificate, in a similar way to the current process (RdSAP appendix T). For example, an individual bioenergy system would not be suggested for a top floor flat.
This approach provides a simplified message to the public when making choices about their options to upgrade their heating system, clearly indicates potential options and the option likely to have the lowest running cost, and advises that further advice is sought before a system is chosen.
Certificate Redesign Many stakeholders noted that introducing additional ratings and indicators has the potential to complicate the EPC. We have noted this concern, particularly as the primary audience of the EPC is the general public so the EPC is only useful if the public understand what it is telling them. For this reason we have undertaken a first phase of work to redesign the EPC based on user testing and feedback. The results of that initial phase of testing are set out in Figures 1-5 below. That work is ongoing and will move into its second phase following publication of this Government Response.
In the first phase, The Energy Saving Trust contracted CIVIC to research and design proposals for a new Scottish EPC.
Initial phases of user research have been completed to provide options for the redesign of EPCs in Scotland. This work reviewed EPCs from other nations across the EU, included stakeholder workshops and carried out user testing. It captured certificate requirements and iterated potential designs and features that can be further developed and implemented.
Users were clear that the current EPC was dated, cluttered and unengaging. The EPC was criticised for being text-heavy and not easy to understand.
The design proposals include:
Addition of new ratings and associated information A to G rating graphics which are well understood and retained Property diagrams and icons developed to aid understanding Content included in âblocksâ to maintain consistency across formats Developed in line with accessibility standards The amount of text has been significantly reduced Testers provided consistent positive feedback on the design proposals confirming this was more modern, easier to understand and quickly told users what they needed to know.
Initial versions of the final design following phase one of the user testing are set out in Certificate Redesign below. We are finalising how we intend to show these ratings on the EPC, based on further user testing and refinement with consumer groups. The designs below show a potential approach, based on our consumer testing so far. These will be refined further through a second phase of user testing between now and the new EPC regulations coming into force.
Figure 1: Potential redesigned EPC front page ratings section Front page of the redesigned EPC showing heat retention rating, heating system rating, and energy cost rating Figure 2: Potential redesigned EPC summary information This image is of a page of the property report that will accompany an EPC. It shows that heat is lost through the floors, windows, walls and roof. It also highlights the rating of the wall, roof, floor and windows Figure 3: Potential redesigned EPC heat retention improvements section This image is of a page of the property report that will accompany an EPC. It shows the potential insulation improvements that could be made to this property. Figure 4: Potential redesigned EPC heating system information section This image is of a page of the property report that will accompany an EPC. It shows the current heating system and potential alternatives. For these systems it shows the estimated efficiency, estimated running costs, estimated emissions and estimated installation costs Figure 5: Potential redesigned EPC further information section This image is of a page of the property report that will accompany an EPC. It provides further information about suggested improvements. Summary â Domestic EPCs
We Will Do:
Heat Retention Rating, based on how well the building retains heat â i.e. its heat demand / fabric efficiency Heating System Type Rating, comprising ratings for the emissions category, thermal efficiency and running cost Energy Cost Rating, based on the total cost to run the property (in line with the current Energy Efficiency Rating / EPC Rating) 2. Introduce a set of secondary metrics to provide information for those interested in particular aspects of the buildingâs performance.
Renaming them to âpotential improvement optionsâ (to be clearer about their purpose and nature) Changing the logic used to display potential improvement measures to focus on improving the buildingâs Heat Retention Rating (i.e. its fabric) Adopting a technology-neutral approach to highlighting and providing basic information about potential non-polluting heating systems. 4. Redesign the EPC so that the information it displays is accessible, clearer, and more engaging.
3.2 Non-Domestic EPCs We Asked We proposed to reform non-domestic EPCs to focus on the reduction of direct emissions. The variety of building types and activities in Scotlandâs non-domestic building stock mean that it is challenging to identify decarbonisation pathways that can be used across all buildings â on this basis we have focused on providing information about the direct emissions and energy use of the building rather than breaking ratings down into component parts as in the domestic certificate. We proposed the following ratings for non-domestic EPCs:
Energy Efficiency Rating (A to G) (1-100 based on kg of CO2e/m2/yr) â based on modelled emissions from regulated energy use[7] relative to a reference building to align with the rating system used across the UK; Direct Emissions (kg of CO2e/m2/yr) â the buildingâs modelled direct emissions from regulated energy use to allow a focus on the decarbonisation of individual buildings. (For buildings which only use grid electricity this will be zero); Energy Demand (kWh/m2/yr) - the buildingâs modelled regulated energy use under standardised conditions to allow comparisons between buildings. Alongside this, we proposed to display the heating fuel type and heating system type more prominently on non-domestic EPCs[8]. This is intended to reflect the importance of moving away from polluting heating systems. This would be accompanied by text noting any relevant regulatory standards.
We proposed different sets of ratings for the domestic and non-domestic EPC. As noted above, this is because domestic and non-domestic EPCs are not comparable and the energy efficiency context of each sector is different. By this we mean that while fabric energy efficiency improvements are a key part of reaching net zero in the domestic sector, other upgrades may need to be prioritised in some areas of the non-domestic sector due to the varied nature of the buildings and their different uses which can be a significant factor on the level of the buildingâs emissions. This means that focusing on the total direct emissions and energy use is more appropriate than focusing on heat demand.
We have not proposed changes to the Section 63 assessment process, Improvement Plans, or Display Energy Certificates ahead of the Scottish Governmentâs response to our consultation on proposals for a Heat in Buildings Bill.
We asked the following questions on these proposals:
Yes/No/Donât know
Please explain you view further
Should have additional metrics, please explain your view further
Should not be included, please explain your view further
You Said Key Findings
Across the questions asked in this chapter, the same issues tended to emerge repeatedly.
Around one in three respondents agreed with the set of ratings proposed to display on non-domestic EPCs (Q6) Key themes
Advantages outlined for these ratings included the provision of a clear understanding of the ratings and how they feed into the EPC score. They are a good range of measures to improve building performance. It was also felt these would provide a good foundation for other workstreams and should help incentivise stakeholders to make buildings more energy efficient The current ratings are sufficient and no change is needed Views were positive on having a relative Energy Rating that would align with the rating system used in other parts of the UK There were some calls for consistency between domestic and non-domestic EPCs to help reduce complexity There were concerns over the potential costs of retrofit changes, with some requests for additional grant funding to be made available Next most frequent themes
The new non-domestic EPC ratings should help to counteract some of the perceived poor quality of data provided under the current ratings Some respondents preferred the use of real data rather than modelled data and felt this would provide a more accurate reflection of a buildingâs performance. There were also some requests for the actual energy costs to be provided rather than being based on standard modelling There were some comments that it can be difficult to set ratings for non-domestic buildings because of the variety of building types and uses across the country A number of additional ratings for display were suggested by respondents There was some criticism over a âone-size-fits-all approach, as usage of buildings varies considerably. Additionally, it was felt that some listed buildings and older properties would need to be assessed on an individual basis We Will Do The Scottish Government has reflected on the feedback and will implement the revised ratings proposed in the consultation. A key concern raised by businesses in both the consultation and other forums was that the current Scottish non-domestic EPC ratings in Scotland do not currently align with those used in the rest of the UK[9]. This difference is not well understood by the public, and as a result the different rating scales cause confusion to business working across the UK.
In line with our consultation proposal, we intend to address this concern by introducing a rating comparable to the Asset Rating used across the rest of the UK. This would be based on a comparison of the total emissions of the building compared to those of a reference building (a hypothetical building with similar dimensions and usage, but built to a specified standard).
We have noted concerns raised in feedback that showing different ratings on domestic and non-domestic EPCs (as is currently the case) could be confusing and will address this in the design and messaging used on non-domestic EPCs. We will do this by making clear on the EPC the meaning of each rating. As noted in the section above our view is that different ratings are needed on non-domestic and domestic EPCs to reflect the different contexts in which they operate.
Several comments related to concerns over the potential use of ratings to implement proposed HiB regulations. The EPC reform consultation did not include proposals for the use of EPCs in minimum standards or regulations. We consulted separately in 2023 on proposals for a Heat in Buildings Bill. We are still considering our response to that consultation and will give further information on any potential role for EPCs as part of that response.
We have decided to introduce the following ratings and indications on to non-domestic EPCs, in line with the rating system set out in our consultation:
Energy Efficiency Rating (A to G) kgCO2e/m2/year â based on modelled emissions from regulated energy use[10] relative to a reference building to align with the rating system used across the UK; Direct Emissions Rating (kgCO2e/m2/year) â the buildingâs modelled direct emissions from regulated energy use to allow a focus on the decarbonisation of individual buildings. For buildings which only use grid electricity, or are connected to a heat network, this will be zero; Energy Demand Rating (kWh/m2/yr) - the buildingâs modelled regulated energy use under standardised conditions to allow comparisons between buildings. The Energy Efficiency Rating will follow the same rating scale as the Asset Rating used on non-domestic EPCs in England, Wales, and Northern Ireland â an A-G letter based on a 1-100 scale, with kgCO2e/m2/yr also shown. This will allow this rating to be used interchangeably across the UK, which was a key concern we heard from stakeholders responding to the consultation.
The Direct Emissions Rating will provide information about the direct emissions of the building. This allows buildings that use only clean systems for heating, cooling, lighting and ventilation to clearly show this. We do not intend to take account of polluting processes, including process heating, in this indicator, as process heat is regulated separately. We are considering our approach to any proposed regulatory standards for non-domestic buildings in our response to the consultation on proposals for a Heat in Buildings Bill.
The Energy Demand Rating will provide information about the regulated energy use of the building under standardised conditions. This provides another point of comparison for buildings.
In addition, we will retain the Primary Energy Rating currently on non-domestic EPCs. This indicator provides a point of comparison with other countries across the EU.
The non-domestic EPC will also clearly show a Rating for the main Heating System for the building. This will be based upon the same Heating System Type Rating classification as used on the domestic EPC:
Clean Heating Renewable Bioenergy Hybrid Systems Polluting Heating Initial versions of the final nondomestic EPC design following phase one of the user testing are set out below. We are finalising how we intend to show these ratings on the EPC, based on further user testing and refinement with consumer groups. The designs below show a potential approach, based on our consumer testing so far. These will be refined further through a second phase of user testing between now and the new EPC regulations coming into force.
Figure 6: Potential non-domestic EPC design Potential front page of a new, redesigned non-domestic EPC Summary â Non-Domestic EPCs
We will:
Introduce a reformed set of three non-domestic EPC ratings: Energy Efficiency Rating (A to G) kgCO2e/m2/year, based on modelled emissions from regulated energy use relative to a reference building to align with the rating system used across the UK; Direct Emissions Rating (kgCO2e/m2/year), based on the buildingâs modelled direct emissions from regulated energy use to allow a focus on the decarbonisation of individual buildings. For buildings which only use grid electricity, or those connected to a heat network, this will be zero Energy Demand Rating (kWh/m2/yr) - the buildingâs modelled regulated energy use under standardised conditions to allow comparisons between buildings. Clearly show the main heating system of the building and whether it is a polluting system or not. Show whether a building is in a heat network zone Redesign the EPC so that the information it displays is accessible, clearer, and more engaging. Consider additional reforms when responding to the consultation on a Heat in Buildings Bill.4. EPC Operational Infrastructure We Asked For both domestic and non-domestic EPCs we proposed to:
Clarify the purpose of EPCs; Reduce the validity period from 10 to five years; Modernise the Scottish EPC design format, including moving to a digital webpage format, adding interactive links to signpost further advice and support, and providing links to more tailored recommendations Expand the sharing of non-personal EPC data to allow more effective use of this useful resource, including direct public access to current and historical EPC records (this would also apply to other related certificates, including Energy Action Plans); Improve the assurance behind EPC assessments by updating the auditing requirements with a risk-based, smart auditing approach. The operating requirements for approved organisations and their members would also be updated. Continue to review the use of actual energy use data to inform EPCs, and to continue to consider work that could support the future development of Green Building Passports. Introduce regulations in Winter 2023-24, though we noted that we would review the UK Governmentâs development of SAP11 (now called the Home Energy Model) and consider aligning our EPC reforms with its launch. In line with the above, we also set out that we would work with the UK Government and other devolved administrations in the development of the new Home Energy Model which will replace SAP as the calculation methodology used to generate EPCs. This includes development of the Scottish EPC Register and surrounding infrastructure to support the transition. We asked the following questions on these proposals:
4.1 EPC Purpose and Validity 8. Do you agree with us that the primary role of the EPC should be to provide basic energy efficiency information for the purpose of comparison and act as a prompt to consider retrofit options?
Yes/No/Donât know
Please give details for your answer
Please give details for your answer
Please give details for your answer
Please give details for your answer
4.2 Digital and Accessible EPC Format and Content 12. Do you agree with our proposal that EPCs should move from PDF to webpage format?
Yes/No/Donât know
Please provide further details here
Yes/No/Donât know
Please provide further details here
Yes/No/Donât know
Please give reasons for your view
Yes/No/Donât know
Please give reasons for your view
This could include services that you think EPCs should signpost to, or comments about the use of an API to access the EPC database.
Please explain your view further
4.3 EPC Auditing and Assurance 17. Do you agree with our proposals to review and update the auditing and assurance requirements for EPCs in Scotland?
Yes/No/Donât know
Please explain your view further
Please give details for your answer
Consultation Questions : Legislating for EPC Reform and Timeline
Yes/No/Donât know
Please give details for your answer
4.4 Purpose and Validity Period You Said Key Findings
Across the questions asked in this chapter, the same issues tended to emerge repeatedly.
There was majority agreement that the primary role of the EPC should be to provide basic energy efficiency information for the purpose of comparison and act as a prompt to consider retrofit schemes (Q8) There was minority support for the validity period of EPCs to be reduced from 10 to five years (Q10) Key themes
There were calls for funding packages and grants to be made available for people to undertake retrofit changes that might be suggested on an EPC Concerns that EPCs could be used to force people into undertaking retrofit measures or in preventing house sales (mainly noted by individuals) There were some comments that the decision to obtain a new EPC should be the choice of a property owner. Conversely, some respondents felt there are specific points that would or should trigger the need for a new EPC The reduced validity period should only apply to new buildings. This was because some heating systems or generic retrofit recommendations are perceived to be inappropriate for some housing stock. Allied to this, there were views that EPCs should not provide retrofit options and advice that could contradict a full technical survey A key advantage to a reduction in the validity period of an EPC was that it allows for the provision of more up-to-date and accurate information. However, there were also some calls for EPCs to provide clear, good quality information and signposting to services Next most frequent themes
Suggestions for variable validity periods were suggested by some respondents, depending on the type of property and work already undertaken on a property Some respondents â primarily individuals â felt that EPCs are of limited usefulness and that specialist retrofit advice from other sources is more useful There were some concerns from organisations that changes could have an impact on the housing market in terms of reducing the number of available properties There were some queries over a potential lack of assessors to undertake the necessary work Other themes
EPCs were perceived to be useful for a range of policy areas as well as better targeting of resources for schemes. However, there were some concerns this could lead to higher levels of fuel poverty, given that electrical heating systems are more expensive Some organisations felt the full implications of EPC reform will not be understood until the legislation for the Heat in Buildings Bill is published Some respondents expressed views that the development of SAP 11 and the associated SBEM and RdSAP methodologies need to reflect the impact of market changes We Will Do We will proceed with our proposal to make clear in the messaging around EPCs that they are intended as a basic, standardised assessment and not a substitute for detailed, technical, retrofit assessment and advice. The EPC will therefore continue to signpost consumers towards that more detailed retrofit assessment and advice on which energy efficiency and clean heat measures are suitable, including via the proposed Heat & Energy Efficiency Technical Suitability Assessment (HEETSA) which we are considering in response to the consultation on proposals for a Heat in Buildings Bill.
We will redesign the EPC as set out at the Certificate Redesign section above. As part of our proposed move to the more accessible, digital format for EPCs we have also now commissioned research to scope out the potential content for a new dynamic EPC User Interface. This would include interactive features allowing consumers to input different variables in terms of their behaviour and preferences, to understand the likely impact that this would have on their energy use â more details are set out below in section 6 below on Actual Energy Use Data.
We have considered feedback on our proposal to reduce the EPC validity period. This would reduce the validity period for EPCs from 10 years to five years, though would only apply if the validity period is not overridden by another existing requirement (e.g. where a Government funding scheme requires a new EPC, or where a new EPC is already required as part of a Home Report).
We have decided to reduce the validity period of EPCs to five years. We have decided to introduce these measures because we want to protect consumers and ensure they have the most-up-to-date and relevant information when purchasing or renting a property, or seeking advice on improvements they could make to their building to meet any mandatory standards. We do not think a 10-year validity period is appropriate for EPCs to provide that consumer protection. An EPC that is 10 years old will not provide a potential or current tenant or building owner with up-to-date information about the performance of a building, or be able to take into account any changes that have been made in subsequent years.
Together, these measures will also help track improvement in buildings across the housing stock.
4.5 Digital and Accessible You Said Key Findings
Across the questions asked in this chapter, the same issues tended to emerge repeatedly.
Higher numbers of respondents supported the proposal that EPCs should move from PDF to webpage format (Q12) There was majority support for the proposal to improve signposting to further support and advice schemes on the EPC (Q13) There was majority support for historical EPCs to be publicly accessible on the EPC register (while clearly marked as historic) (Q14) A large minority of respondents felt the EPC register should be accessible by API (Q15) Key themes
Advantages of a webpage format are its accessibility and user-friendliness, greater flexibility and access to ongoing updated and tailored data. It also offers opportunities for data linkage, signposting users to sources of support and advice, and for policymakers to better meet policy targets Signposting to further support and advice schemes was perceived to be useful and could help to increase consumer awareness on energy savings and emissions reductions. There were some suggestions that signposting should be to the Home Energy Scotland advice service rather than directly to service providers. However, if signposting is provided to specific suppliers, this will need to be to independent, competent and reliable service providers However, there were calls for a range of options to meet all needs. This included a capacity to download a hard copy or PDF version, particularly for individuals who do not have internet access or digital skills. There were concerns about lack of internet access and / or digital knowledge for some individuals There some concerns over the potential for data breaches and / or abuse of personal data by marketing companies wanting to cold call potential customers Next most frequent themes
Some criteria were outlined for signposting. This included that it should be appropriate to a buildingâs age and type of property, be up-to-date and clear, user-friendly, concise and unambiguous The provision of historic EPCs was seen to be useful for tracking progression towards net zero and energy savings. However, it was felt these would be more useful to organisations than individuals. It was also felt that changes to EPC ratings would reduce opportunities for direct comparison over time Accessibility by API was seen to be of use primarily for organisations We Will Do We have decided to move to a webpage as the default way an EPC is viewed, from the current PDF format. We have set out our planned EPC Redesign in the Certificate Redesign section above. This follows the current PDF format and we will consider how best to adapt this to webpage format as part of the Register upgrade work. We have noted the need to ensure that the EPC format allows for a printable version, for example to allow it to be included in a Home Report or for people who do not have access to the internet. As will be set out in the forthcoming, related technical consultation following this Government Response, we are now working to design and build a new EPC Register to the latest digital standards for accessibility, which will implement these changes when the revised regulations come into force.
We intend to modernise the data sharing provisions set out in the EPC regulations. We have listened to requests for wider data sharing, particularly from businesses, local authorities, and registered social landlords. We are also working with the UK Government to review responses to its own consultation on EPC reform, and the proposals it made around data sharing, to consider consistency across the UK. The Scottish Government will put in place provisions that allow non-personal data to be shared by the Keeper of the Register, including the EPC Report Reference Number. This will, for example, allow registered social landlords to more easily see the performance of their stock and how improvement programmes change this over time.
It is important to emphasise that this data sharing relates only to non-personal data, and would not include names or other details about the homeowner (which are not stored on the EPC register) or the EPC assessor.
We intend that these provisions will be implemented by introducing live Application Programming Interface (API) access to the EPC register, allowing interested parties to query the register in real time.
As part of our proposed move to the more accessible, digital format for EPCs we have also now commissioned research to scope out the potential content for a new dynamic EPC User Interface. This would include interactive features allowing consumers to input different variables in terms of their behaviour and preferences, to understand the likely impact that this would have on their energy use â more details are set out below in the Potential Future Reform section below on Actual Energy Use Data. 5. Quality Assurance and Approved Organisation Framework You Said Key Findings
A large minority of respondents supported the proposals to review and update the auditing and assurance requirements for EPCs in Scotland (Q17) Key themes
Improvements to auditing and assurance requirements were broadly welcomed, with some comments that the current system does not produce consistency and there are some issues around quality Support for the consistency of high standards and accuracy of information, amid concerns about variations and discrepancies in EPC outcomes Smart auditing was broadly welcomed as being effective Next most frequent themes
Good governance and administration of the system was urged in order to gain consumersâ trust On additional assurance activities, a better system to help ensure the consistency of EPC surveys and assessments was advocated, including better ways of flagging inconsistencies Allied to this there were recommendations for the collection of real performance data Calls were made to ensure that assessors undergo proper training to attain the requisite accreditations and skills Other themes
Support for allowances and flexibility to be provided for traditionally built buildings and for enabling stakeholders to be able to challenge assessments and EPCs Concerns were expressed about extra burdens, costs and regulation on consumers arising from extra assurance requirements Other concerns were a perceived lack of clarity and detail in the auditing and assurance proposals We Will Do We are now finalising our review of the current Operational Framework that governs EPCs in Scotland, to ensure these assessments are undertaken to the highest quality standards by competent and qualified assessors. We want to work with the assessor market and with the Approved Organisations which oversee, accredit and train assessors, to ensure that quality improves further when the revised regulations are implemented.
We will also work with the UK Government where appropriate on issues such as quality assurance of EPC assessors (their skills and qualifications) across the UK, which is covered by UK-wide internal market legislation, following the responses received to the UK Governmentâs consultation on EPC reform[11].
We welcome that key industry bodies themselves recognise the importance of this push to drive higher standards, especially in light of recommendations made over the last decade in the Bonfield review in 2016[12] as well as in the Grenfell Tower inquiry report in 2024[13]. Our review has also taken into consideration recommendations made within the 2019 independent external review commissioned by the Scottish Government[14] itself, relating to quality assurance, and aims to address these (where appropriate).
Our review has also explored how to improve the enforcement of the EPC legislation and consumer redress mechanisms for home and business owners/ tenants.
The objectives of this review have been as follows:
To critically assess the current basis on which organisations accrediting EPC assessors are appointed, and the wider role these organisations play in the market; To critically evaluate the existing mechanisms in place which ensure that EPCs are prepared to the appropriate standard of quality; To critically assess the provisions within the existing EPC regulations and Operational Framework to ensure that consumers are at the centre of the approved organisations and their membersâ business; To critically evaluate the role of the current enforcement bodies (local authorities) in overseeing and implementing the existing EPC regulations; and To critically evaluate the current skills and qualification requirements for EPC assessors, and ensure that consumers across Scotland have access to highly qualified and competent EPC assessors regardless of their location. This review is being underpinned by the following key outcomes:
Satisfied home and business owners, tenants, and users; Achieving a âright first timeâ approach; Opportunities for Scottish business and workers; Supporting our proposed Heat in Buildings Standard and Social Housing Net Zero Standard; Accurate results that people can rely on; Trusted organisations delivering for Scotland; and Delivering best value for money for Scottish consumers. The Scottish Government has engaged with a range of businesses representing the assessor industry, Approved Organisations, local government and consumer groups to gather evidence to help achieve these objectives and realise these outcomes.
We have also established an Independent Advisory Group and External Reference Group (featuring industry, local authority, and consumer representation) to review and agree our proposed approaches to reform. These groups will continue to meet throughout 2025-26 (and beyond, where necessary) to advise and support the Scottish Government to implement reforms.
We have now identified the areas where we think reform is needed, and we will implement these changes through a revised Operational Framework â which will be negotiated and come into force for Approved Organisations and assessors when the revised regulations come into force during 2026.
As noted earlier in this consultation, we also share a common interest with the UK Government and other devolved administrations in agreeing our approach in this area, given that issues such as assessor qualifications and skills are covered by UK internal market legislation. We will work with the other governments to agree a common approach to issues around accreditation, skills and quality assurance, reflecting the approach we set out below in responding to our own consultation, and to reflect on the outcomes of the UK Governmentâs consultation.
Our reforms to EPCs aim to remain aligned with the EU Energy Performance of Buildings Directive, from which EPCs originated across the EU, where it is desirable and feasible to do so. Following closure of the EPC reform consultation period in 2023, the EU has subsequently adopted the recast Directive in April 2024. Our proposals for EPC reform would already broadly align with the Directiveâs provisions.
One area where the EU has strengthened the Directive is around quality assurance controls to audit the accuracy and reliability of certificates. This will see existing desk-based random sampling now supplemented by onsite inspections. The Scottish Government believes this development across the EUâs member states is welcome to ensure the highest levels of EPC quality for consumers â particularly vital if EPCs are evidencing any proposed mandatory standards or eligibility for government delivery programmes.
We therefore plan to align with these requirements through establishing new independent audit and inspection arrangements when the revised operational governance arrangements commence.
5.1 Conclusions of Operational Framework Review These are as follows:
5.2 Skills and Qualifications We will undertake a joint exercise with the UK Government and other devolved administrations to a) assess the existing skills/ qualifications landscape across Scotland and the United Kingdom and b) make recommendations that can be taken forward to professionalise the EPC assessor industry. We intend that this includes review of the current National Occupational Standards (NOS) relating to energy assessment, to ensure they continue to form the foundation of a skilled, technically competent EPC assessor workforce. We commissioned research, which we will publish alongside the forthcoming technical consultation on EPC lodgement fees, to benchmark against EU best-practice skills requirements, and the findings of this report will help to inform this joint exercise. We will work with our Approved Organisations to a) improve the Continuing Professional Development (CPD) pathways offered to EPC assessors in Scotland and b) ensure potential routes for assessor upskilling are embedded within any revised Operational Framework (for example, those wishing to undertake more detailed technical suitability assessments in future). We are also working to ensure that there is a sufficient pool of competent and skilled EPC assessors available in the market to handle any anticipated increases in the volumes of EPCs needed to be produced to evidence compliance with any proposed, future mandatory standards. 5.3 Enforcement We will continue to work with local government to agree the future arrangements for the discharge of enforcement functions under the revised EPC regulations. This includes working with local authorities across the rest of the United Kingdom to understand best practice and lessons learned, and how these can be adopted in Scotland. We will continue to work with all parties involved in the property sales and letting process to ensure there is a clear understanding of the existing legal requirements around the production of valid EPCs in Scotland, and ahead of introducing the changes set out in this Scottish Government response through new regulations. 5.4 Quality Assurance We have commissioned an independent audit of all Approved Organisations, which is now complete. The results of these audits will help to inform the future Operational Framework. We will take further measures to enhance the existing Operational Framework to improve transparency and accountability, to ensure best value for home and business owners in Scotland. This will include exploring continuous improvement in the discharge of the various functions under the Operational Framework: from reforms to the Approved Organisation appointment process, to enhanced performance management arrangements. We have also revised and expanded the information collected within the Operational Framework annual reports, which all Approved Organisations are obliged to complete and return. This has allowed the Scottish Government to gain a greater appreciation of the challenges facing our Approved Organisations, and will allow us to work together to take targeted action where any common issues are identified. We will also consider what proactive measures can be taken to attract new applicants to become approved under the revised Operational Framework to ensure the market continues to remain competitive. 5.5 Audit and Inspections We will introduce enhanced auditing and inspections requirements to align with the recast Energy Performance of Buildings Directive (2024) â including considering introducing âsmartâ auditing and independent onsite inspection and auditing functions. 5.6 Consumers We will ensure that any revised Operational Framework has the needs of consumers at its core, and we will work with our Approved Organisations to improve transparency around the consumer complaints process. We will continue to improve consumer knowledge with regards to the escalation mechanisms available to them, to ensure consumers have the confidence and knowledge to escalate any complaints or disputes relating to their EPC assessment experience to our Approved Organisations, where appropriate. We will seek to explore - with the UK Government and other Devolved Administrations - the potential for establishing a dedicated Ombudsman function for EPC consumer protection, and whether such function would be necessary to protect consumers both now and in the future.6. Potential Future Reform You Said The Scottish Government did not ask specific questions on actual energy use data and Green Building Passports, however, building on the points above around how improvements to auditing and assurance would help ensure the consistency of high survey standards, a small minority of respondents also commented in favour of using actual or measured energy use in EPC calculations, perhaps alongside the SAP methodology.
A small minority of organisations referred to Building Performance Certificates or Green Building Passports (GBPs). Stated advantages included that they provide more detail than EPCs and focus on more than a fabric first approach. A combination of EPCs and GBPs could offer owners more bespoke advice about their property and provide homeowners with a clear roadmap to decarbonising their property.
We Will Do The Scottish Government continues to recognise the role that actual energy consumption data can provide in supporting better consumer information alongside EPCs. The research which we commissioned on the use of energy consumption data in EPCs has now published alongside this Government Response[15]. In summary, it says that:
Metered energy consumption data could be used in two ways; to provide more accurate information on building fabric performance, and to give an indication of how efficiency energy is used in the building. The report noted smart meter coverage, data access, and technical challenges as potential barriers, particularly in relation to using meter data as part of an asset rating. However, the report noted potential approaches to developing an indicator of operational performance as part of a dynamic, digital EPC.
As part of our proposed move to the more accessible, digital format for EPCs we have also now commissioned research to scope out the potential content for a new dynamic EPC User Interface. This would include interactive features allowing consumers to input different variables in terms of their behaviour and preferences, to understand the likely impact that this would have on their energy use. The research will:
review existing approaches to displaying dynamic and interactive information about home energy efficiency, review evidence regarding the effectiveness of these approaches, and assess the importance of different occupancy variables that impact heat use and energy efficiency. We expect this research to conclude later in 2025 and will use it to inform work to modernise the EPC Register. This work could make use of flexibility offered by the Home Energy Model to customise inputs and outputs.
It is important to note that providing a more dynamic interface for users to interact with the information contained in an EPC, to take account of their lifestyle and behaviour would not form part of what constitutes âthe Energy Performance Certificateâ for legal purposes. It would only be a voluntary âfor informationâ, add-on to the âfixedâ part of the EPC (which would remain as the certificate containing the ratings and potential improvement options, which are based upon standardised, modelled calculations).
We think, however, that interactive elements would provide an additional source of information to help building owners make informed decisions about potential improvements to their building based on the way they use it â such as showing how the benefit of insulation measures will depend on their energy use. 6. Potential Future Reform You Said The Scottish Government did not ask specific questions on actual energy use data and Green Building Passports, however, building on the points above around how improvements to auditing and assurance would help ensure the consistency of high survey standards, a small minority of respondents also commented in favour of using actual or measured energy use in EPC calculations, perhaps alongside the SAP methodology.
A small minority of organisations referred to Building Performance Certificates or Green Building Passports (GBPs). Stated advantages included that they provide more detail than EPCs and focus on more than a fabric first approach. A combination of EPCs and GBPs could offer owners more bespoke advice about their property and provide homeowners with a clear roadmap to decarbonising their property.
We Will Do The Scottish Government continues to recognise the role that actual energy consumption data can provide in supporting better consumer information alongside EPCs. The research which we commissioned on the use of energy consumption data in EPCs has now published alongside this Government Response[15]. In summary, it says that:
Metered energy consumption data could be used in two ways; to provide more accurate information on building fabric performance, and to give an indication of how efficiency energy is used in the building. The report noted smart meter coverage, data access, and technical challenges as potential barriers, particularly in relation to using meter data as part of an asset rating. However, the report noted potential approaches to developing an indicator of operational performance as part of a dynamic, digital EPC.
As part of our proposed move to the more accessible, digital format for EPCs we have also now commissioned research to scope out the potential content for a new dynamic EPC User Interface. This would include interactive features allowing consumers to input different variables in terms of their behaviour and preferences, to understand the likely impact that this would have on their energy use. The research will:
review existing approaches to displaying dynamic and interactive information about home energy efficiency, review evidence regarding the effectiveness of these approaches, and assess the importance of different occupancy variables that impact heat use and energy efficiency. We expect this research to conclude later in 2025 and will use it to inform work to modernise the EPC Register. This work could make use of flexibility offered by the Home Energy Model to customise inputs and outputs.
It is important to note that providing a more dynamic interface for users to interact with the information contained in an EPC, to take account of their lifestyle and behaviour would not form part of what constitutes âthe Energy Performance Certificateâ for legal purposes. It would only be a voluntary âfor informationâ, add-on to the âfixedâ part of the EPC (which would remain as the certificate containing the ratings and potential improvement options, which are based upon standardised, modelled calculations).
We think, however, that interactive elements would provide an additional source of information to help building owners make informed decisions about potential improvements to their building based on the way they use it â such as showing how the benefit of insulation measures will depend on their energy use. 7. Legislating for EPC reform You said Key Findings
Key themes emerging across this question included:
The most supported timeline, albeit by only a minority of respondents, was to align reform implementation with the launch of the Home Energy Model (formerly known as SAP 11) in 2025. This would help avoid confusion, avoid the possibility of further EPC reviews and allow time for the underlying calculation methodology to be adapted for the new ratings However, there were also calls for the reform implementation to take place as soon as possible. This was because of the need to reduce carbon emissions, introducing the proposed Heat in Buildings regulations and promoting growth in the electric heating sector A small minority of respondents suggested dates later than 2025 to allow more time to understand all the potential implications. There were concerns that the proposed timeline options were too soon There were calls for the implementation to be streamlined with the introduction or reform of other strategies for easier integration We Will Do 7.1 Legislation â revised EPC Regulations The Scottish Government can now confirm that we intend to lay revised EPC regulations during 2025, with the intention to bring them into force in 2026. This timetable will give time for the assessor market and those in the property letting and conveyancing sectors to prepare. The specific date at which regulations come into force will be dependent on the date when the new UK Home Energy Model becomes available to calculate the new EPC ratings. We are liaising closely with the UK Government which expects the Home Energy Model to be introduced as the basis for calculating EPC ratings in the second half of 2026.
Most respondents suggested that aligning the introduction of EPC reform with the move to the Home Energy Model (which was previously titled SAP11) would be preferable than introducing regulations sooner using the current RdSAP methodology. This approach minimises the impact on businesses and the public as it means they do not have to adapt to two significant changes to the EPC system at short intervals. We therefore intend to introduce the reformed EPC by using HEM as the calculation methodology, rather than RdSAP.
7.2 Technical Infrastructure to support the new EPC Regulations We are also working with the UK Government to understand the technical requirements to adopt HEM and use it to introduce EPC reform. HEM introduces new processes required to be undertaken by the EPC Register (i.e. to run the HEM cloud calculation service â âEnergy Calculation as a Serviceâ (ECaaS))[16].
The operational arrangements for the HEM EPC assessments are yet to be established and agreed with Approved Organisations, though we intend to work to the principle set out above to share technical infrastructure with the UK Government to avoid unnecessary burden on businesses (and, ultimately, EPC costs to the public). Further detail on our proposed approach will be set out in our forthcoming, related technical consultation on how lodgement fees can be used to support the development of this technical infrastructure of the new Register and Calculation Methodology, following publication of this Government Response on EPC Reform.
7.3 Working with the UK Government and other devolved administrations Legislation covering EPCs was introduced across the UK in 2008, in common with other member states, when the UK was a member of the EU. This legislation transposed the EU Energy Performance of Buildings Directive and was retained in UK law following EU Exit. Given that EPCs continue to be a legal requirement across the UK, and given that the assessor market operates UK-wide, and that we share common underpinning technical infrastructure (the Calculation Methodology of SAP / HEM and the Register), the governments of the four nations have agreed new governance arrangements to support our ongoing collaboration.
These arrangements will be set out in a Memorandum of Understanding which is being finalised between the governments. We recognise that whilst legislation relating to the energy performance of buildings is devolved in Scotland and Northern Ireland, there are important aspects such as competition law and consumer protection law which are reserved to the UK Government. Likewise the UK Internal Market Act contains requirements to ensure market access and prevent discrimination in the provision of goods and services or ensure equivalence when it comes to things such as qualifications.
The Scottish Government will continue to cooperate closely with the UKG and other devolved administrations in taking forward policy, legislation and market oversight of EPCs in Scotland. This includes the Scottish Government working jointly with the UK Government to consider our approach to policy making for issues such as quality assurance of EPC assessors (their skills and qualifications) across the UK, following the responses received to the UK Governmentâs consultation on EPC reform[17].
7.4 EU Alignment In addition to ensuring collaboration across the UK within the framework of the UK Internal Market Act, the Scottish Government also has a commitment to maintain alignment with EU law where it is possible and meaningful for the Scottish Government to do so.
The Scottish Government has made a commitment to maintain and advance the high standards that Scotland shares with the EU. The principal legal instrument by which the EU sets out its standards for EPCs is the Energy Performance of Buildings Directive (EPBD).
The EPBD was first adopted in 2002, introducing policies and measures needed to comply with the Kyoto Protocol. The objective of the Directive was to promote the improvement of the energy performance of buildings. This included the introduction of minimum energy performance requirements for new buildings and existing buildings over 1000 m2, and the introduction of Energy Performance Certificates (EPCs) across the EU for all buildings sold, leased or newly constructed.
The EPBD has now been recast[18] again, following proposals made by the European Commission in 2021 to ensure the third of the EUâs emissions which come from the building sector could be reduced, in line with the EUâs European Green Deal objective to ensure the EU achieves net zero emissions by 2050. It aims to contribute to the objective of reducing GHG emissions by at least 60% in the building sector by 2030 compared to 2015, and achieving a highly energy efficient, zero-emission building stock by 2050. The recast Directive was adopted in April 2024.
It focuses on increasing renovation rates across the EU â targeting the worst-performing buildings in each country, whilst allowing member states flexibility to determine which renovation measures are most appropriate to their national contexts. In line with our EPC reform plans, the recast EPBD
updates the common framework for calculating the energy performance of buildings updates the requirements for independent control systems for EPCs aims to increase the reliability, quality, affordability and digitalisation of EPCs enhances data collection and sharing, to improve knowledge on the building stock and awareness on energy consumption in buildings introduces a new requirement for on-site audit and inspection, to verify the âvalidity of the input dataâ. The Scottish Government is currently considering its approach to alignment across the recast Directive and aims to align with its requirements for EPCs where possible, including with the enhanced independent audit and inspection requirements.
Summary EPC Operational Infrastructure
Clarify the purpose of the EPC as a basic source of information about buildings Reduce the validity period of the EPC from 10 years to five, and ensure all tenancies have a valid EPC Introduce a modernised Scottish EPC design and move to a web page format Introduce clearer data sharing provisions allowing non-personal EPC data to be shared in ways that better support organisation and industry to use it Update EPC Operational Framework, following finalisation of our review, to better protect consumers through higher standards of quality assurance â including exploring the introduction of enhanced auditing arrangements (such as on-site auditing and smart auditing) Review the fee associated with the lodgement of EPCâs, (as set out in the related technical consultation which will follow this Government Response), to ensure that they reflect current and anticipated costs of maintaining and enhancing the EPC regulatory regime Continue to develop proposals for the ârealâ data as part of a modernised EPC register. Including thorough research looking at the potential for an interactive EPC user interface Introduce revised Energy Performance of Building regulations in 2025, to bring reformed EPCâs into effect in 2026 (pending confirmation from UK Government that the Home Energy Model will become available in the second half of 2026) Continue to cooperate with the UKG and other devolved administrations in taking forward policy, legislation and market oversight of EPCâs in Scotland, overseen by a new Memorandum of Understanding Aim to align with the revised requirements for EPCâs under the recast EU Energy Performance of Buildings Directive, including for an independent onsite audit and inspection to verify EPC accuracyFootnotes 1 The term âregulated energy useâ means energy used for space and water heating, cooling, pumps and fans, and fixed lighting. It excludes plug-in appliances and cooking. Regulated energy use therefore relates to the buildingâs design, allowing buildings to be compared on a consistent basis.
2 Reforms to the Energy Performance of Buildings regime - gov.uk
3 We will also include a specific category for Peat main heating systems which can combust peat, in the small number of properties where such systems are present. This is in recognition of the unique cultural heritage attached to such systems in parts of rural and island Scotland. This category will not appear on certificates for any property which does not have a Peat main heating system.
4 The current EER calculates a rating for current and potential running costs. It takes into account how well the building retains heat, and the type of heating system used (alongside the cost of lighting and other regulated energy uses). The new Energy Cost Rating will continue to do this, using the Heat Retention Rating and Heating System Rating running costs together (alongside other regulated energy uses), to calculate the overall current and potential Energy Cost Rating.
5 The term âregulated energy useâ means energy used for space and water heating, cooling, pumps and fans, and fixed lighting. It excludes plug-in appliances and cooking. Regulated energy use therefore relates to the buildingâs design, allowing buildings to be compared on a consistent basis.
6 This is the EPC calculation methodology by which particular improvement measures are selected in a particular order. This is currently set out in RdSAP appendix T, but will be amended as part of the migration to the Home Energy Model
7 The term âregulated energy useâ means energy used for space and water heating, cooling, pumps and fans, and fixed lighting. It excludes plug-in appliances and cooking. Regulated energy use therefore relates to the buildingâs design, allowing buildings to be compared on a consistent basis.
8 As is the case for domestic EPCs, we will also include a specific category for Peat main heating systems which can combust peat, in the small number of properties where such systems are present. This is in recognition of the unique cultural heritage attached to such systems in parts of rural and island Scotland. This category will not appear on certificates for any property which does not have a Peat main heating system.
9 A comparable rating to the UK Asset Rating is already present on Scottish non-domestic EPCs, however it is not presented on the front page of the certificate.
10 The term âregulated energy useâ means energy used for space and water heating, cooling, pumps and fans, and fixed lighting. It excludes plug-in appliances and cooking. Regulated energy use therefore relates to the buildingâs design, allowing buildings to be compared on a consistent basis.
11 Reforms to the Energy Performance of Buildings regime - gov.uk
12 Each Home Counts: Review of Consumer Advice, Protection, Standards and Enforcement for Energy Efficiency and Renewable Energy - gov.uk
13 Phase 2 report | Grenfell Tower Inquiry
14 A Review of Domestic and Non-Domestic Energy Performance Certificates in Scotland: Research report for the Scottish Government, Heat, Energy Efficiency and Consumers Unit - Final Report
15 Using metered energy consumption data on Scottish EPCs | ClimateXChange
16 We have decided that replicating ECaaS in Scotland would not be cost efficient and would cause unnecessary burden on the EPC supply chain in needing to ensure assessment software works with two cloud calculation services. As a result we intend that:
The UK ECaaS service will be used to produce Scottish EPCs Scottish EPCs will continue to be hosted in Scotland on a public facing Register 17 Reforms to the Energy Performance of Buildings regime - gov.uk
18 Directive - EU - 2024/1275 - EN - EUR-Lex