The Scottish Government has confirmed it intends to lay revised Energy Performance Certificate regulations during 2025, with the intention of bringing them into force in 2026, in its response to the 2023 consultation on EPC reform, published on 21 January 20251. The reformed certificates will use the Home Energy Model (HEM) as the calculation methodology rather than RdSAP1.
The government said the timetable gives the assessor market and the property letting and conveyancing sectors time to prepare, and that the specific commencement date depends on when the new UK Home Energy Model becomes available to calculate the new EPC ratings1. It said it is liaising closely with the UK Government, which expects the Home Energy Model to be introduced as the basis for calculating EPC ratings in the second half of 20261. The response states that most respondents preferred aligning EPC reform with the move to HEM over introducing regulations sooner under the current RdSAP methodology, to avoid two significant changes at short intervals1.
"we intend to lay revised EPC regulations during 2025, with the intention to bring them into force in 2026"
The response also sets out changes to the operational framework for EPCs in Scotland1:
| Measure | Detail |
|---|---|
| Validity period | Reduced from 10 years to five |
| Format | Modernised Scottish EPC design, moving to a web page format |
| Data sharing | Clearer provisions allowing non-personal EPC data to be shared |
| Quality assurance | Updated operational framework, including exploration of enhanced auditing such as on-site and smart auditing |
| Lodgement fees | Review of the fee associated with lodging EPCs, set out in a related technical consultation to follow |
On technical infrastructure, the government said HEM introduces new processes for the EPC Register, including a cloud calculation service called Energy Calculation as a Service (ECaaS)1. It said operational arrangements for HEM EPC assessments are yet to be established and agreed with Approved Organisations, and that further detail will come in a forthcoming technical consultation on how lodgement fees can support development of the new Register and calculation methodology1. The response also notes that legislation covering EPCs was introduced across the UK in 2008, that energy performance of buildings legislation is devolved in Scotland and Northern Ireland while competition law and consumer protection law are reserved, and that new governance arrangements between the four nations will be set out in a Memorandum of Understanding still being finalised1. On EU alignment, it states the recast Energy Performance of Buildings Directive was adopted in April 2024, and that the Scottish Government aims to align with its requirements for EPCs where possible, including enhanced independent audit and inspection requirements1.
Why it matters for households
An EPC is the document that records a home's energy rating, and it is required when a property is sold or let. The changes confirmed here affect how that rating is produced, how long it lasts and how it is presented. Moving from RdSAP to the Home Energy Model means ratings will be calculated under a different methodology, so a home's rating may not be directly comparable with one issued under the current system. Shortening the validity period from 10 years to five means certificates will need to be renewed more often, and the move to a web page format changes how the certificate itself is viewed and shared. For households, the practical effect is on the paperwork attached to buying, selling or renting a home, and on the reliability of the rating as a guide to a property's energy performance. The response does not set out new minimum efficiency standards for owner-occupied homes; the confirmed measures concern the certificate and its supporting infrastructure. The wider framework sits within energy and buildings policy in Scotland, and the reform process is covered in EPC regulations and reform.
What happens next
A related technical consultation on how lodgement fees can be used to support development of the new Register and calculation methodology will follow the government response1. Revised Energy Performance of Building regulations are to be introduced in 2025 to bring reformed EPCs into effect in 2026, pending confirmation from the UK Government that the Home Energy Model will be available in the second half of 20261. A Memorandum of Understanding between the four nations is being finalised1.