The Scottish Government published independent analysis of its consultation on domestic Energy Performance Certificate metric reform on 23 January 20251. The analysis covers views gathered on what could be achieved in the reform of EPC regulations and the reform of Energy Performance Certificates1.
On the proposed set of ratings to display on the reformed EPC, slightly greater numbers of respondents disagreed than agreed, and opinions between organisations and individuals were polarised. A majority of organisations agreed with the proposed ratings compared with only a significant minority of individuals. Among organisations, the highest levels of agreement came from local authorities, those involved in the EPC process and in the construction sector, and utility organisations. A total of 252 respondents gave reasons for their answer or made further comments at this question1.
A majority of respondents thought the fabric rating should not include domestic hot water heat demand. The analysis states that this was because of inconsistent data and the lack of a relationship to fabric heat losses. Of those answering the first part of the question, 147 gave their views, while 105 responses addressed reasons why the metric should include domestic hot water heat demand1.
There was general agreement with mapping the fabric rating against an A to G scale, and majority agreement that more prominence should be given to the energy efficiency features of a home. On the latter question, 221 respondents provided further details1.
"Slightly greater numbers of respondents disagreed with the proposed set of ratings to display on the reformed EPC than agreed (Q1)"
The analysis records that the types of organisation with the highest levels of disagreement included those involved in the EPC process, housing providers, local authorities and third sector organisations. Among organisations, those with the highest levels of agreement were EPC process, housing providers and local authorities' respondents1.
| Question | Finding |
|---|---|
| Q1: proposed set of ratings | Slightly more disagreed than agreed; organisations and individuals polarised |
| Q3: domestic hot water in fabric rating | Majority thought it should not be included |
| Q4: fabric rating on A to G scale | General agreement |
| Q5: prominence for energy efficiency features | Majority agreement |
Concerns raised included the accuracy of data and the methodology used to arrive at the ratings, with requests for measurements to be a real world indication of performance. A small minority feared extra costs from the surveying required to obtain the additional ratings, and noted a lack of information as to what the extra EPC costs to homeowners and house-sellers might be1.
Almost all comments about heating system type were critical in nature. A significant minority of mainly individuals cited concerns about heat pumps, including the practical challenges and expense of purchase and installation, perceived inefficiency, and unsuitability for many houses1.
Why it matters for households
The EPC is the document a householder meets when buying, selling or renting a home, and its ratings shape what improvements are identified and how a property is described. The consultation analysis shows that the proposed replacement metrics drew more disagreement than agreement overall, with individuals notably less supportive than organisations. For a home's energy independence, the fabric rating is the measure intended to describe how much the building itself limits heat loss, separate from the heating system. The majority view against folding domestic hot water heat demand into that rating reflects a stated concern that it does not relate to fabric heat losses1.
The analysis also records concerns about data accuracy and about how ratings will be calculated, and a lack of information on what additional surveying might cost homeowners and house-sellers1. How many Scottish properties sit below EPC rating C, and how long a Scottish domestic EPC remains valid, are separate matters covered in the site's guides on Scotland's housing stock and EPC ratings and how long a Scottish domestic EPC is valid.
What happens next
The publication states that the government is working to introduce achievable measures for EPC reform1. No further dates are given in the analysis. Enquiries are directed to EPCenquiries@gov.scot1.