The recast EU Energy Performance of Buildings Directive (EPBD) was adopted in April 2024, following proposals made by the European Commission in 20211. The Directive was first adopted in 2002, introducing minimum energy performance requirements and Energy Performance Certificates (EPCs) across the EU for buildings sold, leased or newly constructed1.
The recast Directive aims to contribute to reducing greenhouse gas emissions by at least 60% in the building sector by 2030 compared with 2015, and to achieving a highly energy efficient, zero-emission building stock by 20501. It focuses on increasing renovation rates across the EU, targeting the worst-performing buildings in each country, while allowing member states flexibility to determine which renovation measures suit their national contexts1. It also updates the common framework for calculating the energy performance of buildings, updates requirements for independent control systems for EPCs, and introduces a new requirement for on-site audit and inspection to verify the validity of input data1.
The Scottish Government, in its January 2025 response to the 2023 EPC reform consultation, said it is considering its approach to alignment across the recast Directive and aims to align with its requirements for EPCs where possible, including the enhanced independent audit and inspection requirements1. It said its proposals for EPC reform would already broadly align with the Directive's provisions2. The response also set out plans to lay revised EPC regulations in the Scottish Parliament during 2025, with the intention to bring them into force in 2026, dependent on the UK Home Energy Model becoming available1.
"The recast Directive was adopted in April 2024."
The Scottish Government said it intends to introduce the reformed EPC using the Home Energy Model (HEM) as the calculation methodology rather than RdSAP, and that the UK Government expects HEM to be introduced as the basis for calculating EPC ratings in the second half of 20261. It also plans to reduce the validity period of EPCs from 10 years to five2. The table below sets out the proposed domestic Heat Retention Rating scale2.
| Band | Score | Description |
|---|---|---|
| A | 30 or less | High level of energy efficiency |
| B | 31 to 70 | High level of energy efficiency |
| C | 71 to 120 | Good level of energy efficiency |
| D | 121 to 215 | Lower level of energy efficiency |
| E | 215 to 301 | Lower level of energy efficiency |
| F | 302 to 350 | Lower level of energy efficiency |
| G | 351 or more | Lower level of energy efficiency |
The Scottish Government said around 80% of homes currently in cost-based EPC EER band C also achieve band C in the new Heat Retention Rating2. It said legislation covering EPCs was introduced across the UK in 2008 when the UK was an EU member state, transposing the EPBD, and was retained in UK law following EU exit1. It said the governments of the four nations have agreed new governance arrangements, to be set out in a Memorandum of Understanding being finalised between them1.
Why it matters for households
EPCs are a legal requirement across the UK and underpin information given to buyers and tenants. Over 200,000 are issued every year in Scotland2. The recast Directive's emphasis on renovation rates and on-site verification of EPC input data points to tighter quality controls on the certificates that describe a home's EPC regulations and reform. For households, the practical effect is that the document used to describe a property's energy performance, and the methodology behind it, are both changing. The Scottish Government's plan to move from SAP to the Home Energy Model would change how ratings are calculated, and the proposed reduction in EPC validity from 10 years to five would mean certificates are refreshed more often. The Directive's 2030 and 2050 building goals sit behind national renovation policy, which in the UK is devolved: Energy and Buildings Policy in Scotland and Energy and Buildings Policy in Wales are set by their respective governments, while DESNZ leads for the UK Government. How any of this translates into obligations on individual homes has not been reported.
What happens next
The Scottish Government intends to lay revised EPC regulations during 2025, with the intention to bring them into force in 2026, pending confirmation from the UK Government that the Home Energy Model will become available in the second half of 20261. It said it will shortly issue an additional technical consultation on proposed changes to EPC lodgement fees, which have not been revised since 20172. It also said it is still considering its response to consultations on a Heat in Buildings Bill and a Social Housing Net Zero Standard, and will set out its position separately on how EPCs could support proposed mandatory standards2.