The Scottish Government published a consultation on 25 July 2023 setting out proposals to reform domestic and non-domestic Energy Performance Certificates in Scotland1. The consultation covers EPC metrics, the purpose and validity period of certificates, the EPC format and quality assurance procedures1. It follows an initial consultation on EPC reform launched in 2021, the results of which were published in 20222.
The government states that the current metrics and ratings are not fit for the purpose of driving improvement. In the ministerial foreword it says:
"However, the metrics and ratings EPC s currently use are not appropriate to drive the improvements that we need in the fabric of our homes and to move to zero direct emissions heating systems in our homes and buildings."
For domestic EPCs, the government proposes three headline metrics: a Fabric Rating showing modelled fabric performance in kWh/m2/year; a Cost Rating, which is the current Energy Efficiency Rating renamed; and Heating System Type, identifying the installed system and whether it meets a proposed Zero Direct Emissions Heating standard2. Two further metrics, an Emissions Rating and an Energy Use Indicator, would be displayed but not as headline metrics3. Heating systems would be classified by efficiency, with heat pumps listed as high efficiency zero direct emission heating, modern electric storage heaters and heat networks as zero direct emissions plus, direct electric heating and hydrogen as zero direct emissions, and gas boilers, hybrid heat pumps and biomass heating as systems with direct emissions3.
For non-domestic EPCs, the government proposes an Energy Efficiency Rating based on modelled emissions relative to a reference building, a Direct Emissions figure in kg CO2e/m2/year, and an Energy Demand figure in kWh/m2/year2. The consultation notes that the current absolute Energy Performance Rating on Scottish non-domestic EPCs cannot be compared with Asset Ratings in England and Wales4.
Additional proposals applying to both types of EPC include reducing the validity period from 10 years to five, moving to a webpage format with interactive links, expanding public access to current and historical EPC records, and updating auditing requirements through a risk-based approach2. The consultation states that the government does not propose to amend or replace the SAP and RdSAP methodologies at this time, citing the UK Government's planned SAP 11 update, which is planned to be launched in 20254.
| Proposed domestic headline metric | What it shows |
|---|---|
| Fabric Rating | Efficiency of the building fabric, A to G and kWh/m2/yr |
| Cost Rating | Running cost per year, A to G with 1-100 rating |
| Heating System Type | System classification, zero direct emissions or not, and efficiency |
Source: Scottish Government consultation, tables 2 and 33
Why it matters for households
An EPC is required when a building is sold or let to a new tenant, and has formed part of the Home Report since 20082. Once lodged on the Scottish EPC Register, a certificate is currently valid for ten years or until replaced4. The proposed reduction to five years would mean certificates are renewed more often, and the government says this is so tenants and owners have the most up to date information5.
The proposed metrics change what a certificate measures. The current Energy Efficiency Rating is based on modelled running cost normalised to floor area, which the consultation says can favour gas heating over electric heating because of fuel prices, and can mean insulation shows a smaller improvement in a gas heated home than an electric one4. A separate Fabric Rating would report heat loss rather than cost, which the government says is primarily intended to support any future fabric energy efficiency standards3. The consultation also notes that EPC assessments are non-intrusive visual surveys using standardised occupancy assumptions, and that the certificate is not a substitute for in-depth professional retrofit advice4.
The proposals sit alongside wider plans. The consultation states that, subject to consultation, a Heat in Buildings Bill would seek powers to require domestic buildings to meet a minimum fabric energy efficiency standard equivalent to EPC C by 2033 and to prohibit the use of direct emissions heating systems in domestic and non-domestic buildings by 20452. Scotland's buildings account for around a fifth of emissions, against legally binding targets of net zero by 2045, with interim reductions of 75% by 2030 and 90% by 2040 relative to 1990 levels2.
What happens next
The consultation states that, following the consultation, the government intends to introduce revised Energy Performance of Buildings (Scotland) Regulations to the Scottish Parliament in Winter 2023-24, subject to the necessary legislative vehicle being in place, which would mean revised EPCs can come into force shortly afterwards2. The government adds that it will review the UK Government's timeline for SAP 11, planned for launch in 2025, which may provide a more appropriate point to introduce the reformed EPC2. No closing date for the consultation is given in the pages reviewed.
Sources5 cited
- Energy Performance Certificate (EPC) reform: consultation - gov.scot, gov.scot
- 1. Introduction - Energy Performance Certificate (EPC) reform: consultation - gov.scot, gov.scot
- 4. Proposals - Energy Performance Certificate (EPC) reform: consultation - gov.scot, gov.scot
- 2. Current EPC System in Scotland - Energy Performance Certificate (EPC) reform: consultation - gov.scot, gov.scot
- EPC reform | Changeworks, changeworks.org.uk