The Scottish Government announced plans on 10 January 2023 to introduce new minimum environmental design standards for all newbuild housing in Scotland, to meet a "Scottish equivalent to the Passivhaus standard"1. The plan was based on measures set out in Alex Rowley MSP's proposed Domestic Building Environmental Standards (Scotland) Bill3. The Passivhaus Trust states that the announcement committed the government to "make subordinate legislation within two years"2.
Passivhaus is described as an extremely rigorous design standard aimed at making buildings so well insulated and ventilated that they hardly require any additional heating or cooling4. The Passivhaus Trust states that the standard delivers a space heating requirement of 15 kWh/m2/year, against current UK building regulations modelled at 63 kWh/m2/year once a 40% performance gap is factored in, a reduction of 76%2.
The policy has drawn criticism from Scotland's solar trade body. Solar Energy Scotland said the consultation was based on the original, or "Classic", Passivhaus standard, devised decades ago when renewables were rare and expensive, and that solar power is not mentioned at all in it3. It added that the consultation does not go as far on energy efficiency as Passivhaus Classic, and that the standard has been superseded by the "Plus" and "Premium" forms, which mandate the installation of renewable energy3.
"We welcome the Scottish Government's intentions to upgrade fabric and comfort standards and improve quality assurance for newbuild properties. However, we caution against using outdated energy calculations that undervalue on-site generation such as solar power, and the huge opportunities of battery energy storage and smart home energy management."
The Scottish Government's own consultation document states that "There is increasing recognition and application of the standard, which contributes positively to overall energy and net zero objectives"3. The consultation covers both domestic and non-domestic properties3. The Passivhaus Trust reports that a Stage 1 consultation closed on 23 October 2024, that a Scottish Passivhaus Equivalent Working Group consensus report was published in November 2024, and that an interim progress report published in December 2025 set out areas for a Stage 2 consultation1. The Trust states that the Stage 2 consultation has now launched, with a deadline of 16 October 20261.
The New Build Heat Standard came into effect on 1 April 2024, meaning no new homes will be built with direct emission heating systems, including gas boilers and biomass4. Solar Energy Scotland states that under the 2021 changes to building regulations, homes heated with heat pumps can meet the standards with no solar, and that Scotland's share of solar powered homes grew from 9% in 2015 to almost 70% in 20204.
| Standard | Space heating requirement (kWh/m2/year) | Reduction |
|---|---|---|
| Part L1A | 63 | 0 |
| Passivhaus Classic | 15 | 76% |
Source: Passivhaus Trust2
Why it matters for households
The standard being developed applies to newbuild housing, so it does not change the rules for existing homes. Its practical effect for a household is on the fabric of a new home: very high levels of insulation and air tightness, leading to very low energy demand, and an overall energy performance target covering space heating, cooking and appliances3. A home built to such a standard needs less energy to keep warm, which bears directly on running costs and on how much a household depends on bought-in energy.
The disagreement between the two bodies concerns on-site generation rather than fabric. Solar Energy Scotland argues that a home with a heat pump but no rooftop solar carries higher operating costs, and that the proposals specify a standard for energy delivered rather than energy produced on-site3. The Passivhaus Trust's position is that a typical Passivhaus would not necessitate solar4. Scotland has a commitment to boost solar capacity to between four and six gigawatts by 20303. The EU Solar standard, agreed in March 2024, will require solar on all new commercial and public buildings by 2026 and all new residential buildings by 20293. England's Future Homes Standard consultation proposes banning gas boilers and is expected to effectively mandate solar on new homes3. The Passivhaus Trust states the Future Homes Standard was announced in March 2026 and will come into force in March 20282.
What happens next
The Stage 2 consultation on the proposed Passivhaus equivalent policy has a deadline of 16 October 20261. The Passivhaus Trust states it is preparing a detailed response and will run "respond-a-long" webinars1. The exact details of what a Scottish equivalent to Passivhaus would look like are still being finalised2. No commencement date for the resulting regulations has been reported.
Sources4 cited
- Scottish Equivalent to Passivhaus, passivhaustrust.org.uk
- Passivhaus & Building Standards, passivhaustrust.org.uk
- Solar sector concerned over ‘outdated’ Scottish Building Regulations plan • Solar Energy UK, solarenergyuk.org
- Will Scotland’s Future Homes Generate Energy? • Solar Energy UK, solarenergyuk.org