The Scottish Government launched a public consultation on Energy Performance Certificate reform in July 2023, closing on 16 October 20231. The consultation covered domestic and non-domestic EPCs and sought views on revised ratings, the purpose and validity period of certificates, their format, and quality assurance1. Independent analysis of the responses was published on 23 January 20251.
There were 323 responses, of which 122 came from organisations and 201 from individuals1. The largest organisation groups were representative bodies (31), the construction sector (30), local authorities (19) and housing providers (10)3. The analysis states that organisations were generally more positive about the proposals than individuals, and that individuals raised concerns about affordability and the practicality of energy upgrades1.
The proposals included reducing the validity period of EPCs from ten to five years, moving certificates from PDF to webpage format, and making historical EPCs publicly accessible on the register1. On the validity period, the analysis found "there was only minority support for the validity period of EPC s to be reduced from ten to five years"1. There was majority support for historical EPCs to be publicly accessible, and just under half of respondents, more organisations than individuals, felt the register should be accessible by Application Program Interface1.
On the ratings themselves, over half of respondents felt the fabric rating should not include domestic hot water heat demand, and there was general agreement with mapping the fabric rating against an A-G scale1. Views were split on whether that scale should align to the current Energy Efficiency Rating or be set independently1. The Scottish Government stated that it did not propose that a reformed EPC would force people into retrofit measures, and that there were no proposals to require a change of heating system to an electrical heating system1.
The National Insulation Association, in a separate response to a UK parliamentary call for evidence, described the Scottish consultation as "encouraging" and supported the proposed metrics and the focus on fabric efficiency5.
"In July 2023, the Scottish Government launched a public consultation on EPC reform, which ended in October 2023."
Why it matters for households
EPCs must be provided when a building is sold or let to a new tenant, and have formed part of the Home Report since 20083. Any change to what a certificate shows, how long it lasts and how it is accessed therefore touches anyone buying, selling or renting a home in Scotland. The proposed fabric rating would describe a dwelling's heat loss under standard conditions, while the cost rating would carry the same meaning as the Energy Efficiency Rating currently displayed4. A shorter validity period would mean certificates go out of date sooner, which the analysis links to more up-to-date information for policymakers and organisations rather than individuals1. Respondents also raised concerns that older housing stock, including traditional stone-built properties, tenements and listed buildings, could be disadvantaged by new ratings1. The Scottish Government has stated that reform would not compel retrofit work or a change of heating system1.
What happens next
The Scottish Government intends to introduce revised Energy Performance of Buildings (Scotland) Regulations to the Scottish Parliament, subject to the necessary legislative vehicle being in place3. It will also review the UK Government's timeline for the Home Energy Model, formerly SAP 113. The most supported timeline among respondents was to align reform implementation with the launch of SAP 11, now known as the Home Energy Model, in 20251. No date for laying the regulations has been reported.
Sources5 cited
- Executive Summary - Energy Performance Certificate reform: consultation analysis - gov.scot, gov.scot
- Energy Performance Certificate Reform Consultation 2023, gov.scot
- Introduction - Energy Performance Certificate reform: consultation analysis - gov.scot, gov.scot
- 1. Introduction - Energy Performance Certificate (EPC) reform: consultation - gov.scot, gov.scot
- Energy Security and Net Zero Committee Call for Evidence: Heating our Homes - National Insulation Association, nia-uk.org