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Scottish Government responds to 2023 EPC reform consultation

The Scottish Government has confirmed higher EPC lodgement fees, a shorter certificate validity period and a new rating system, with regulations due in Parliament during 2025 and in force in 2026.

A newspaper on a kitchen table beside a model of rules and regulation

The Scottish Government has set out its final decisions on Energy Performance Certificate reform, confirming in January 2025 that it will lay revised EPC regulations in Parliament during 2025 with the intention of bringing them into force in 20261.

The fee consultation followed the earlier reform consultation of 2023. The government states that it sought views on the future funding of key elements of Scotland's EPC regulatory regime, and that this was the first time it had consulted on lodgement fee levels since 20172. It also states that penalty charges have not been reviewed since 20092.

The confirmed fee levels are set out below.

Certificate typeNew lodgement fee
Domestic EPC£6.00
Non-domestic EPC£15.50

The government says it will amend EPC lodgement fees within the regulations to £6.00 for domestic certificates and £15.50 for non-domestic certificates, and that the fees will fund a new EPC Register, a new calculation methodology and a new onsite audit and inspection function within the Scottish Government2. It will retain EPC penalty charges at the level currently set in the 2008 Regulations, and will review both fee and penalty levels within two years of the regulations coming into force2. It will also review the onsite audit and inspection function within two years to see whether it remains fit for purpose2.

"Amend EPC lodgement fees within the regulations (to £6.00 for domestic certificates and £15.50 for non-domestic certificates)"
Scottish Energy Performance Certificate Register Lodgement Fees and Penalty Charges2

On the wider reforms, the government response of January 2025 confirms a reduction of the validity period of EPCs from 10 to five years, to ensure consumers have more up-to-date information1. It confirms that the current Standard Assessment Procedure will be replaced by the new Home Energy Model calculation methodology, alongside a new EPC Register1. A new domestic rating system will be introduced, including a Heat Retention Rating on an A-G scale, a Heating System Type Rating and an Energy Cost Rating1. The response states that around 80% of homes currently in cost-based EPC EER band C also achieve band C in the new Heat Retention Rating1. Over 200,000 EPCs are issued every year1.

The government says it plans to bring the new Regulations into force in the second half of 2026, to align with the introduction of the UK Home Energy Model Calculation Methodology2. The changes to lodgement fees will be introduced through the Energy Performance of Buildings (Scotland) Regulations 20252. The government also states that it is aligning with changes to the EU Energy Performance of Buildings Directive made in 2024, which will require onsite audit of EPCs across the EU2.

Why it matters for households

An EPC is the document a buyer, seller, landlord or tenant sees when a property changes hands, and it is the reference point for any future minimum energy efficiency standard. A shorter validity period of five years means the certificate attached to a home will be more recent, but it also means certificates will need renewing more often than under the current 10-year rule1. The lodgement fee is paid when a certificate is lodged on the register, so the confirmed increase to £6.00 for a domestic certificate is a cost that sits within the assessment process rather than a separate charge2. The government states the fee will pay for the register, the calculation methodology and the audit function, which it describes as supporting improvements to EPC accuracy and reliability2. For a household weighing up EPC Regulations and the Reform of Energy Performance Certificates, the practical change is that the rating on the certificate will describe fabric efficiency, heating system and running costs separately rather than through a single number1. How many Scottish homes sit below the current band C is set out in Scotland's Housing Stock and EPC Ratings.

What happens next

The revised EPC regulations are to be laid in Parliament during 2025, with the government intending to bring them into force in 20261. The fee changes will come through the Energy Performance of Buildings (Scotland) Regulations 2025, with the government planning to bring the new Regulations into force in the second half of 20262. Fee and penalty levels, and the onsite audit and inspection function, are to be reviewed within two years of the regulations coming into force2. The government has not reported a date for that review beyond the two-year window2.

Sources2 cited
  1. Energy Performance Certificate Reform Consultation: Government Response, gov.scot
  2. [Scottish Energy Performance Certificate Register Lodgement Fees and Penalty Charges