The UK Government consultation on proposals to amend the existing minimum energy efficiency standards (MEES) for domestic private rented sector (PRS) properties in England and Wales closed on 2 May 20251. The proposals would require properties to achieve EPC band C before being let, applying to new tenancies from 2028 and to all tenancies by 20301. The UK Government introduced MEES for domestic PRS properties across England and Wales in 2015, setting a requirement to reach EPC band E1.
The Scottish Government's own consultation on PRS MEES, which ran alongside a partial business and regulatory impact assessment, also closed on 2 May 20251. Scotland currently has no MEES for PRS properties, meaning landlords can rent properties that meet any EPC banding1. The Scottish Government intends for regulations to apply to new tenancies from 2028 and to all privately rented homes by the end of 20331. It is seeking views on a proposed cost cap of £10,0002.
The Scottish proposals would use a reformed EPC Heat Retention Rating (HRR) band C as the minimum standard, rather than the existing EPC rating1. The Scottish Government is reforming EPCs so they focus on the energy efficiency of the building fabric and give better information on the emissions and efficiency of the heating system1. New EPC regulations are to be laid in autumn 2025 and brought into force during autumn 2026, depending on the UK Government's timetable for the development of the Home Energy Model1.
The Scottish Government's impact assessment sets out the scale of the task in the PRS. Around 19% of Scotland's total emissions come from the heating systems used in its building stock1. Of PRS homes in Scotland, 74% currently use gas boilers and 7% use oil boilers1. In the PRS, 48% of properties are rated EPC band D or lower, and the sector has the highest percentage (14%) of EPC band E, F or G rated properties compared with the social rented sector (5%) and owner occupied sector (11%)2. The proportion of social rented properties with EPC band C or better increased from 53% in 2016 to 69% in 2023, higher than the PRS at 52%1.
"The outcome of introducing PRS MEES is for all properties, as far as possible, in the domestic PRS to meet an EPC HRR band C, unless exempt, by 2033."
Why it matters for households
For tenants in the private rented sector, the proposed standards are intended to improve the energy efficiency of the homes they live in. The Scottish Government states that improving energy efficiency can reduce energy demand, making a home easier and quicker to heat and keep warm, and can have a positive impact on reducing energy bills1. It also notes that the PRS has high numbers of people living in fuel poverty (44%), and that the lowest rates of fuel poverty are associated with higher energy efficiency standards2.
For a household's energy independence, the practical effect of a MEES is that the property itself must meet a minimum fabric efficiency standard before it can be let. The Scottish Government's proposed HRR focuses on the building fabric and how well it retains heat, so it would not be affected by changes to the heating system1. This means the standard addresses the home's demand for energy, rather than the fuel or technology used to supply it. The Scottish Government states that fabric improvements can also help prepare properties for the use of certain clean heating systems that require good levels of energy efficiency2.
The Scottish Government has not reported the outcome of the England and Wales consultation, nor whether the UK Government will proceed with the proposed 2028 and 2030 dates1. The Scottish Government's own consultation on the draft regulations closed on 29 August 20252.
What happens next
The Scottish Government intends to lay new EPC regulations in September 2025, to come into force in autumn 20262. The PRS MEES regulations are drafted to come into force on 1 April 2028, with a backstop date of 31 March 20332. During the period from 1 April 2028 to 31 March 2033, the prohibition on letting a sub-standard property would not apply to a landlord continuing to let under an existing tenancy to an existing tenant2. The Scottish Government is also consulting on the scope of a potential Heat and Energy Efficiency Technical Suitability Assessment1.