Social housing in Scotland that falls below EPC band D should not be re-let to social tenants from December 2025, according to Scottish Government guidance for social landlords on the Energy Efficiency Standard for Social Housing post 2020 (EESSH2). The restriction is subject to temporary specified exemptions1.
The guidance sets out two milestones. The first EESSH milestone required social landlords to meet a minimum Energy Efficiency rating for each social rented home by 31 December 2020, with the target varying by dwelling type and heating fuel. Under the SAP 2012 methodology, that target ranged between a rating of 47, in EPC band E, for an oil heated house, and 69, in EPC band C, for a gas heated flat1. A second milestone, confirmed in June 2019, requires social rented houses to meet EESSH2 by December 20321.
The 2032 milestone is defined as:
"All social housing meets, or can be treated as meeting, EPC Band B (Energy Efficiency rating), or is as energy efficient as practically possible, by the end of December 2032 and within the limits of cost, technology and necessary consent."
A house that is as energy efficient as practically possible, within the cost, technology and necessary consent, complies with EESSH2. The guidance states that a significant proportion of social housing cannot be brought up to band B with existing technology at reasonable cost, and that the necessary consent of tenants and owners may be hard to obtain. Landlords should assess houses or groups of houses they judge cannot reach band B, showing why further improvements are technically non-viable, not cost-effective or unlikely to secure consent1. The guidance also states there should be a process for reviewing any decision that improvement to band B is not technically possible at least once every five years1.
On cost, the guidance records that it could cost a total of £3.4 billion to bring 62% of Scottish social housing up to EPC band B using existing technology1.
The re-letting restriction sits alongside the 2032 target. The guidance states that no social housing is to be re-let below EPC Band D from December 2025, subject to temporary specified exemptions1. The EESSH was introduced in March 20141.
Scope covers self-contained homes provided for social rents, including sheltered housing, vacant property, property marked for demolition and secure tenancies under the mortgage to rent scheme. Excluded are houses purchased by former tenants, hostels with common facilities for food preparation, intermediate or mid-market rents, mortgage to shared equity, commercial sub-lets and amenity blocks for Gypsy/Traveller sites1.
| Milestone | Requirement | Date |
|---|---|---|
| EESSH1 | Minimum rating per home, from 47 (band E, oil heated house) to 69 (band C, gas heated flat) | 31 December 2020 |
| Re-letting restriction | No social housing re-let below EPC band D, subject to temporary exemptions | December 2025 |
| EESSH2 | EPC band B, or as energy efficient as practically possible | End of December 2032 |
Why it matters for households
For a social tenant, the re-letting restriction affects the homes that can be offered to new tenants rather than the tenancy someone already holds. A home below band D that becomes vacant after December 2025 should not be re-let unless a temporary exemption applies, so the pool of available social housing may shift towards better-rated properties. The 2032 milestone sets the direction for the whole social stock: band B, or the best that cost, technology and consent allow. Because the standard is measured through EPCs and SAP ratings, the practical effect for a household is a home that is cheaper to heat for the same level of warmth, which bears directly on energy independence and exposure to fuel bills. The guidance also notes that SAP is a model and that modelled performance may not match a building's actual performance, and that some measures proposed by an EPC may not suit traditional construction1.
What happens next
The 2032 milestone will be supported by a formal review in 2025 to assess progress and confirm additional requirements. Air Quality and Environmental Impact will be included as part of the review, and the guidance states that no detriment to Environmental Impact should be incorporated in the assessment of performance from 20251. The document is draft guidance, version 2.2, dated November 2020, issued to support Scottish Housing Regulator consultation planning1. Arrangements in Scotland differ from the standards that apply in Wales and from the rules covering the private rented sector.