The Scottish Government published independent analysis of its consultation on Energy Performance Certificate reform on 23 January 20251. The consultation ran from July 2023 to October 2023 and sought views on wider reforms to domestic and non-domestic EPCs to ensure they are fit for purpose to support future heat in buildings regulations1.
In total, after removing blank and duplicate responses, there were 323 responses, of which 122 were from organisations and 201 from individuals1. The highest number of organisation responses came from representative bodies (31), followed by the construction sector (30), local authorities (19) and housing providers (10)2. The analysis states that organisations tended to be more positive about the suggested proposals than individuals, and that figures cannot be extrapolated to a wider population because the exercise was self-selecting1.
On the proposed ratings, there was general agreement with mapping the fabric rating against an A-G scale, but over half the respondents felt the fabric rating should not include domestic hot water heat demand1. Views were split on whether the fabric rating A-G scale should be aligned to the current energy efficiency rating or set independently1. On the validity period, there was only minority support for reducing it from ten to five years1. Higher numbers of respondents, more organisations than individuals, supported moving EPCs from PDF to webpage format, and there was majority support for historical EPCs to be publicly accessible on the EPC register1. Just under half of respondents, more organisations than individuals, felt the EPC register should be accessible by Application Program Interface1.
The analysis also records that the Scottish Government did not propose that a reformed EPC would force people into undertaking retrofit measures, and that there were no proposals within the consultation to require a change of heating system to an electrical heating system1. It notes a perception among many individuals that EPCs could be used to force retrofit or prevent house sales1.
"The most supported timeline was to align reform implementation with the launch of SAP 11 (now known as the Home Energy Model) in 2025."
The analysis sets out the terms used to describe levels of support, including that "a majority" refers to more than half the respondents but less than three quarters, and "a large minority" indicates more than a quarter but less than half2.
Why it matters for households
EPCs are required when a building is sold or let to a new tenant, and have formed part of the Home Report since 20082. Any change to what a certificate shows, how long it lasts or how it can be accessed therefore touches on the information a householder sees at the point of a sale, a let or a planned improvement. The analysis indicates that the proposal to shorten validity from ten to five years drew only minority support, while proposals on digital format and public access to historical certificates drew more backing1. It also records concerns from individuals about affordability, the practicality of upgrades, and the suitability of a standardised model for traditional stone-built properties, tenements and listed buildings1. The document states that reform was not proposed as a means of compelling retrofit or a change of heating system, while noting that some respondents perceived otherwise1. For a home's energy independence, the practical effect depends on what the reformed certificate measures and when it must be renewed, both of which remain proposals rather than settled rules.
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 place, which would allow revised EPCs to come into use shortly after regulations are introduced2. It will also review the UK Government's timeline for development of the Home Energy Model, which may be a more appropriate time to introduce the reformed EPC2. The analysis records that some organisations felt the full implications of EPC reform cannot be understood until legislation for the Heat in Buildings Bill is published1. No date for the introduction of regulations has been reported.