Scottish Government officials presented the Government Response on EPC reform to the Regulatory Review Group (RRG) at its meeting on 25 March 20251. The response set out five recommendations1. The presentation followed three public consultations on EPC reform, held in 2021, 2023 and early 2025, and preceded the Energy Performance of Buildings (Scotland) Regulations 2025, which were laid in the Scottish Parliament on 10 October 2025 and are due to come into force a year later in Autumn 20261.
The reforms change what an EPC contains and how long it lasts. The Scottish Government's preferred option replaces the single rating with three: a Heat Retention Rating covering fabric energy efficiency, a Heating System Rating covering type, emissions, efficiency and running costs, and an Energy Cost Rating, which retains the existing SAP-based EE Rating1. The validity period of EPCs falls from 10 to five years1. The regulations also introduce enhanced quality assurance and oversight for EPC assessors and Approved Organisations, including new onsite audit and inspection functions1.
On fees, the Government states that EPC lodgement fees will rise to £6.00 for domestic certificates and £15.50 for non-domestic certificates to cover the £1.27m p.a. costs of this enhanced infrastructure1. Penalty charges are to be retained at the level currently set in the 2008 regulations, with lodgement fee and penalty charge levels reviewed every two years to ensure they remain fair and proportionate1. The Government will also review the operation of the onsite audit and inspection function, within two years of that function first being exercised1. A technical consultation on lodgement fees and penalty charges drew 29 written responses1.
The Government chose to share technical infrastructure with the UK Government rather than build separate Scottish systems. It states that this route avoids £6.5m of upfront capital costs and £0.6m p.a. ongoing operating costs, by sharing technical infrastructure, against an estimated £6.5m in upfront capital costs for the alternative, based on UK Government contracts for methodology and Register infrastructure development1. In summer 2025, a Memorandum of Understanding was finalised between Ministers of the UK Government and other Devolved Administrations1. Independent analysis from June 2025 was undertaken by Cotality1.
"Scottish Government officials presented the Government Response on EPC reform to the Regulatory Review Group (RRG) at its meeting on 25 March 2025."
Why it matters for households
An EPC is required when a building is advertised for sale or let to a new tenant, and on completion of a new building1. It has formed part of the domestic Home Report since 20081. For owner occupiers, the Government says there will be no change in practice, because a new EPC is produced each time a domestic property is advertised for sale to meet Home Report requirements1. The reduced validity period is expected to have its most significant impact on properties for let, where landlords will no longer be able to recycle a valid EPC for up to 10 years to cover new lets, only for a maximum of five1. For non-domestic properties advertised for sale there is no equivalent Home Report requirement, so a new EPC could be needed more often, for buildings sold more than five years after purchase1. Large public buildings, which must always display a valid EPC, will have transitional arrangements1. The higher lodgement fee applies to all EPCs lodged, though the Government says it is a relatively small portion of the total cost of an EPC and is not expected to change how many are lodged1. The three new ratings are intended to give households clearer information on fabric, heating system and running costs, which bears directly on a home's energy independence.
What happens next
The regulations were laid on 10 October 2025 and come into force in October 20261. The Government says that in the months leading up to October 2026 it will ensure key stakeholders and the wider public are informed of how the changes to EPCs will affect them1. A separate consultation launched on 6 June 2025 on proposals to require private rented sector properties to achieve a minimum energy efficiency standard1. The Government says it will continue to monitor and review implementation of the regulations and the associated operational and technical infrastructure within the market on a regular basis1.