The Scottish Government published its response to a consultation on EPC reform in January 2025, following a consultation held in 20231. The response introduces the Heat Retention Rating, a new measure based on the fabric efficiency of a building, meaning how well its structure retains heat1.
The reform sits within a wider programme of energy and buildings policy in Scotland, where responsibilities are split between devolved and reserved powers1. Consumer Scotland, in an investigation into the energy efficiency and low-carbon technologies sector published in June 2025, described the planned EPC reforms as "a welcome chance to shift from passive ratings to practical, trusted information that empowers consumers to make improvements"1.
"In 2023, the Scottish Government consulted on proposals to reform EPCs, publishing its response in January 2025"
The same investigation found that over half of all homes in Scotland do not have a good standard of energy efficiency when measured by the fabric efficiency of the building1. It also reported that the Scottish Government previously estimated the total cost of converting all of Scotland's building stock to zero emissions by 2045 at around £33 billion, with the average total cost to convert a home to a heat pump around £14,0001.
The Heat Retention Rating is a fabric-based measure, which places it alongside other fabric measures that improve an EPC rating such as insulation and glazing. What an EPC measures, and how a fabric-based rating differs from the existing rating, is set out in the site's guide to what an EPC measures.
| Item | Detail |
|---|---|
| Consultation held | 2023 |
| Response published | January 2025 |
| New measure | Heat Retention Rating (fabric-based) |
The sources do not set out the full list of measures covered by the response, the rating scale for the Heat Retention Rating, or the date it takes effect. Those details have not been reported in the material available.
Why it matters for households
An EPC is the document that records how a home performs and is used in decisions about buying, selling, renting and upgrading a property. A rating built on fabric efficiency describes how well the building itself holds heat, rather than how it is heated or powered. For a household, that distinction matters because fabric measures such as insulation and glazing are the parts of a home's performance that stay with the building, while heating systems and tariffs can change.
Consumer Scotland's investigation found that cost, uncertainty and disruption are major barriers to uptake of renewable energy and insulation technologies, and that many consumers remain unclear about which options suit their homes1. It also found that government schemes which reduce upfront cost barriers are central to enabling uptake, and that the range of support at present may be confusing1. The investigation did not evaluate the merits of specific public grants and support schemes1.
For homes in Scotland, the practical effect of a fabric-based rating depends on how it is used in energy efficiency standards for privately rented homes in Scotland and in any future condition attached to owner-occupied properties. The sources do not state how the Heat Retention Rating will interact with those standards.
What happens next
Consumer Scotland reported that the Scottish Government set out plans in April 2025 for a forthcoming Heat in Buildings Bill, expected to be introduced later that year, retaining the 2045 target for decarbonising home heating with a greater focus on affordability and fairness, especially for those in fuel poverty1. It also reported that in November 2023 the Scottish Government published initial consultation proposals for a Heat in Buildings Bill, and that in April 2025 it announced revised proposals1.
Separately, Consumer Scotland reported that from April 2025 heat network consumers in Scotland have access to additional support, with greater protections coming in 2026, and that from January 2026 Ofgem will become the regulator for heat networks across Great Britain1.
