EESSH: The Energy Efficiency Standard for Social Housing in Scotland

The first EESSH milestone required social landlords to meet an energy efficiency rating equivalent to EPC band C and D by 2020³. A successor standard, EESSH2, set a further target: all social housing meets, or can be treated as meeting, EPC Band B (Energy Efficiency rating), or is as energy efficient as practically possible, by the end of December 2032 and within the limits of cost, technology and necessary consent¹. Under EESSH2, no social housing is to be re-let below EPC Band D from December 2025⁴.

The standard is monitored by the Scottish Housing Regulator, which has paused the collection of data on EESSH until after the conclusion of the Scottish Government's review of EESSH2¹. That review is the live question for landlords and tenants: the standard has been in place for many years and is currently being reviewed for consistency with net zero targets, with a consultation completing in 2024⁵.

What EESSH is and who it applies to

EESSH applies to the social rented sector in Scotland. Its scope is self-contained homes, including a full range of facilities for the use of occupiers, provided for the purpose of social rents⁴. That definition covers the homes let by local authorities and registered social landlords rather than the private rented sector or owner-occupied housing.

The distinction matters because Scotland runs separate regulatory routes for each tenure. Private landlords fall under the Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations, and the Scottish Government's own impact assessment notes that 34% of private rented properties are EPC band D and 14% of the stock is rated EPC band E, F or G³. Social landlords, by contrast, answer to EESSH and to the Scottish Housing Quality Standard, which was introduced in February 2004 and required all social landlords to ensure that all their dwellings pass the SHQS by April 2015⁶.

Funding routes also split by tenure. The Home Energy Scotland Grant and Loan Scheme helps eligible homeowners pay for energy efficiency improvements and clean heating systems⁷, and is open to all domestic owner-occupiers in Scotland⁸. For private landlords, the Private Rented Sector Landlord Loan is available in addition to Area Based Scheme grants to support landlords which are ineligible for ABS to install energy efficiency and renewable energy measures to reduce the EPC rating of the property in line with Scottish Government Regulations⁹. Social housing providers have their own route through the Social Housing Net Zero Heat Fund, which is open to social housing providers with projects that will be delivered in Scotland².

For a household, the practical point is that EESSH is not something a tenant applies for or opts into. It is a duty on the landlord, and the tenant experiences it through the condition of the home.

When EESSH was introduced and the first milestone

Scotland has had energy efficiency standards in place for social housing since 2014². The first EESSH milestone required social landlords to meet an energy efficiency rating equivalent to EPC band C and D by 2020³. That milestone is the anchor for everything that followed: it established the principle that a social landlord's stock has to clear a defined energy threshold, not merely be habitable.

The 2020 milestone sat alongside the older Scottish Housing Quality Standard, which had already required all social landlords to ensure that all their dwellings pass the SHQS by April 2015⁶. The two standards work on different axes. The SHQS is about the state of the home; EESSH is about its energy performance. A dwelling can pass one and fail the other, and in 2024, 54% of dwellings failed to meet the SHQS⁶.

The successor standard, EESSH2, moved the target upward. All social housing meets, or can be treated as meeting, EPC Band B (Energy Efficiency rating), or is as energy efficient as practically possible, by the end of December 2032 and within the limits of cost, technology and necessary consent¹. The wording carries its own qualification: the target is bounded by what is practical, affordable and consented, which is why the standard is expressed as a band with a fallback rather than an absolute requirement.

The minimum standard: SAP 60-69, equivalent to EPC band C or D

EESSH's milestones are written in EPC bands, and EPC bands are built from SAP scores. The band boundaries matter for anyone reading a landlord's compliance statement. Band C runs from 69 to 80 on the EPC scale¹⁰. The first EESSH milestone, an energy efficiency rating equivalent to EPC band C and D, therefore spans a wide range of underlying SAP scores rather than a single pass mark³.

Scotland's housing stock sits close to that boundary. Under SAP 2009, the median EE rating in 2022 was 71, which is equivalent to Band C¹¹. A separate Scottish House Condition Survey publication gives the same period's median as 70, also equivalent to Band C, and notes this is an increase from 62 in 2010, which is equivalent to band D¹². The two figures differ by a single point and both describe the same year; both are reported here.

The most recent figure is lower. In 2024, the mean energy efficiency rating of the Scottish housing stock under SAP 2012 (RdSAP v9.93) was 68.1⁶. That is a mean rather than a median, and it is calculated under a different SAP version, so it is not directly comparable with the 2022 medians. What it shows is that the average Scottish home sits just below the band C threshold of 69, which is precisely the territory EESSH was designed to move.

For a social landlord, the practical consequence is that compliance is a stock-wide exercise. A landlord with a large proportion of older stock has to lift individual dwellings across a band boundary, and the gap between 68.1 and 69 is small in number but expensive in fabric.

How the standard is measured: SAP ratings and revised targets for electrically heated homes

The Standard Assessment Procedure is the calculation engine underneath all of this. SAP stands for Standard Assessment Procedure for Energy Rating of Dwellings¹³. The current approved version for new dwellings in England is version 10.3¹⁴, and Scotland is developing the infrastructure required to adopt the UK Government's Home Energy Model, which is about to replace SAP¹⁵.

That replacement is the most significant change to how EESSH-type targets will be measured. The Energy Performance of Buildings (Scotland) Regulations 2025 set out that the final reformed EPC format and design for domestic buildings will include a Heat Retention Rating, a Heating System Rating and an Energy Cost Rating, as well as carbon dioxide emissions associated with the building and the type of heating system used¹⁶. Each of those three ratings answers a different question:

• The Heat Retention Rating is based on the annual heat demand (kWh/m2) of the building⁸.
• The Heating System Rating shows the home's current heating system⁸.
• The Energy Cost Rating is a standardised rating to reflect the cost of running the home⁸.

This separation is what changes the picture for electrically heated homes. Under a single EPC score, a well-insulated home with expensive electric heating can be dragged down by running costs. Under the reformed format, fabric performance and heating system performance are reported separately, so a landlord can demonstrate that a dwelling's fabric is sound even where the heating system is not yet low carbon.

The Scottish Government has also tested a Heat Retention Rating Band C set between 71 and 120 kWh/m2/year of energy used to heat the home, and found that for a sample, around 80% of homes currently at EPC C also achieved Band C on the Heat Retention Rating¹⁷. That overlap figure is the practical bridge between the old band system and the new one.

Review for consistency with net zero targets

The Scottish Government has said it is currently reviewing the standard to ensure that it is consistent with net zero targets⁵. The Scottish Housing Regulator has paused the collection of data on EESSH until after the conclusion of the Scottish Government's review of EESSH2¹. That pause is the clearest signal that the current target structure is not settled.

The net zero backdrop is fixed. Scotland has committed to reaching net zero by 2045¹⁸, and the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 sets targets to reduce Scotland's emission of all greenhouse gases to net-zero by 2045 at the latest⁹. The interim targets are a 75% reduction by 2030 and a 90% reduction by 2040¹⁹. By 2045 all homes in Scotland must have significantly reduced their energy use¹.

The wider policy framework points the same way. The Heat in Buildings Strategy set out that all homes should meet at least an energy efficiency standard equivalent to an EPC band C by 2033²⁰. The Scottish Government has also said all homes in Scotland should meet at least EPC band C by 2033 "where feasible and cost-effective"¹⁰. EESSH2's EPC Band B target for social housing by the end of December 2032 is therefore more demanding than the general housing ambition, and arrives a year earlier.

EPC reform itself was driven by concerns raised by a number of stakeholders around the relevance, accuracy, and quality of EPCs, and on the need to provide clearer information on net zero climate impacts²¹. The Scottish EPC Accreditation Scheme remains open for new applicants who will be appointed in advance of the remainder of the 2025 Regulations²². For social landlords, the practical effect of the review is uncertainty about which metric will define compliance after 2032: the current EPC band, or the reformed ratings that separate fabric from heating.

What EESSH means for social landlords and tenants

For social landlords, EESSH is a compliance obligation with a funding and delivery problem attached. The target is bounded by cost, technology and necessary consent¹, which means a landlord can be treated as meeting the standard where full compliance is not practically achievable. That fallback is doing real work: Scotland's stock has a mean energy efficiency rating of 68.1 under SAP 2012⁶, and 54% of dwellings failed to meet the Scottish Housing Quality Standard in 2024⁶, so the population of homes needing intervention is large.

The funding landscape for social landlords is narrower than for owner-occupiers. The Social Housing Net Zero Heat Fund is open to social housing providers with projects that will be delivered in Scotland². The Home Energy Scotland Grant and Loan Scheme, administered by Energy Saving Trust on behalf of the Scottish Government²³, is open to all domestic owner-occupiers in Scotland⁸ and helps eligible homeowners pay for energy efficiency improvements and clean heating systems⁷. Home Energy Scotland also provides free and impartial advice to homeowners and landlords²⁴. These routes provide grant and loan funding directly to owner occupiers, as well as private registered landlords for their rented properties⁹, which leaves social landlords relying principally on their own programmes and the social housing fund.

For tenants, the effect is indirect but material. EESSH was introduced to improve the energy efficiency of social housing in Scotland and to help reduce energy consumption, fuel poverty and the emission of greenhouse gases¹. The Energy Saving Trust has found that the Energy Efficiency Standard for Social Housing and its successor, EESSH2, have helped drive improvements in energy efficiency across the sector². A tenant does not apply, does not pay, and does not receive a certificate; the benefit arrives as a warmer, cheaper-to-run home.

What remains outside the household's control is the same as anywhere in the UK: the grid, the supplier, and the price of the fuel the heating system uses. EESSH improves the fabric and the heating system of a social tenancy, but it does not make that tenancy self-supplying. A tenant's energy independence is bounded by the landlord's investment programme and by the wider market.