The Scottish Government has confirmed that passage of the New Build Heat Standard (NBHS) regulations through Parliament is expected in spring 2023, ahead of the standard coming into force on 1 April 20241. The proposals were set out in the New Build Heat Standard Consultation: Part II, published in July 2022, which followed the earlier scoping consultation1.
From 1 April 2024, new buildings applying for a building warrant will be prohibited from using direct emissions heating systems to meet their space and hot water heating and cooling demand1. Instead, they must meet that demand using systems that produce zero direct greenhouse gas emissions at the point of use1. This applies to both new domestic and non-domestic buildings, as well as the conversion of existing buildings, and to any installed heating system within the curtilage of the building, both main and any other fixed heating system1.
The Scottish Government states that the standard will remain technology-agnostic1. Its research found that bioenergy systems would not be considered compliant, because combustion of biomass is associated with direct emissions of carbon dioxide, methane and nitrous oxide1. On 100 per cent hydrogen, the findings were inconclusive for direct emissions due to a lack of available real-life data1. The standard will also require that all new wet heating systems are designed to operate at lower temperatures, to be compatible with efficient use of non-direct-emissions solutions such as heat pumps and heat networks1.
For conversions, the regulations would apply only where heating is introduced to the building for the first time, or where an existing heat generator is located within a part of the building that is the subject of the conversion1. There are 10 categories of change that constitute a defined conversion, set out in Schedule 2 to Regulation 431. An EPC will be required upon completion for new buildings after 1 April 2024, as is the case now1. The Scottish Government proposes that the standard will be monitored and enforced through the building warrant process1.
"From 1 April 2024, new buildings applying for a building warrant will be prohibited from using direct emissions heating systems to meet their space and hot water heating and cooling demand."
Why it matters for households
The standard applies to new buildings applying for a building warrant from 1 April 2024, so it does not require changes to existing homes1. For a household buying or commissioning a new build, the practical effect is that the heating system installed will not burn gas, oil or biomass on site, and will instead be a zero direct emissions system such as a heat pump or a connection to a heat network1. Because the standard is technology-agnostic, it does not mandate one particular system1.
The requirement that new wet heating systems be designed to run at lower temperatures affects how a home's heating is specified and how it will perform in use1. The Scottish Government's own research found that only around half of people in Scotland have heard of key non-direct-emissions systems such as heat pumps, and that general understanding at UK level of the link between gas central heating and climate change is around 50 per cent1. It has said a Heat in Buildings Public Engagement Strategy would be published in early 20231.
What happens next
The timeline in the consultation sets out that the Building (Scotland) Amendment Regulations 2022 came into force on 1 December 2022, introducing improved fabric measures for new buildings while continued use of direct emissions heating was allowed1. Passage of the new build standard regulations through Parliament is expected in spring 20231. Regulation of zero direct emissions heating comes into force on 1 April 20241. The Scottish Government has said it aims to have local heat and energy efficiency strategies in place by early 2024, with the first due to be finalised by the end of 2023, and has committed to establishing a dedicated National Public Energy Agency by 20251.