The Scottish Government published its response to the 2023 consultation on Energy Performance Certificate reform on 21 January 2025, setting out the changes it intends to make to EPCs in Scotland1. The reforms include a new rating system for domestic and non-domestic buildings, a redesigned certificate, a reduction in EPC validity from ten years to five, and replacement of the Standard Assessment Procedure (SAP) with the UK Home Energy Model (HEM)1.
For domestic properties, the new ratings will include a Heat Retention Rating, showing on an A-G scale how well insulated a home is, a Heating System Type Rating covering the current and potential emissions category of the main heating system, thermal efficiency and running costs, and an Energy Cost Rating based on the cost of energy to run the home to standardised conditions2. The Energy Cost Rating will be in line with the current Energy Efficiency Rating or SAP Rating2. Non-domestic EPCs will carry an Energy Efficiency Rating based on modelled emissions from regulated energy use, a Direct Emissions figure and an Energy Demand figure under standardised conditions2. The suggested actions currently shown on EPCs will be renamed Potential Improvement Options2.
The validity period will fall from 10 to five years "to ensure consumers have more up-to-date information"1. The government also plans a new dynamic EPC user interface alongside the published certificate, strengthened governance arrangements for EPC assessors and Approved Organisations, and a new EPC Register that can interface with the UK Government's cloud calculation service for HEM1.
"Subject to Parliamentary approval, the new regulations, new EPC rating system and redesigned certificates are expected to be brought into force during 2026."
The response states an intention to lay regulations during 2025 and anticipates them coming into force in the second half of 2026, with the final date dependent on when HEM becomes available2. A revised Operational Framework will come into force alongside the revised regulations in 20262. A further technical consultation on proposed changes to EPC lodgement fees will follow1. The government says it is still considering its response to the separate consultations on a Heat in Buildings Bill and a Social Housing Net Zero Standard, and will set out its position on how EPCs could support proposed mandatory standards separately2.
| Proposed change | Detail |
|---|---|
| Validity period | Reduced from 10 years to five1 |
| Domestic ratings | Heat Retention Rating, Heating System Type Rating, Energy Cost Rating2 |
| Non-domestic ratings | Energy Efficiency Rating, Direct Emissions, Energy Demand2 |
| Calculation method | SAP replaced by the UK Home Energy Model1 |
| Expected in force | During 2026, subject to Parliamentary approval1 |
Why it matters for households
An EPC is the document a householder meets when buying, selling or renting a home, and its ratings shape what a buyer or tenant can tell about a property before committing. The proposed Heat Retention Rating would separate how well insulated a home is from how it is heated, so fabric performance and heating system performance would be read as distinct pieces of information rather than combined into one number2. The Heating System Type Rating would show running costs and thermal efficiency alongside emissions, which speaks directly to the cost of operating a home rather than only to its carbon output2.
Shortening validity from ten years to five means an EPC issued under the current rules will age out sooner, and a fresh assessment will be needed more often where a valid certificate is required1. The government states that EPCs in Scotland remain a source of information only, unlike in other parts of the UK where they are linked to minimum energy efficiency standards1. That distinction matters for any household weighing whether an EPC rating will carry legal consequences, because on the current position in Scotland it does not.
The move to the Home Energy Model changes the calculation behind the certificate rather than the building itself, and the timetable depends on HEM becoming available2. Until regulations are laid and approved, the existing EPC system continues to apply.
What happens next
Regulations are intended to be laid in the Scottish Parliament during 2025, with the changes coming into force in 2026, anticipated in the second half of the year and dependent on HEM availability2. A technical consultation on EPC lodgement fees is to follow1. The government has not reported a date for that consultation, nor for the second phase of user testing on the redesigned certificate1.