New regulations reforming Energy Performance Certificates (EPCs) in Scotland are due to be laid in the Scottish Parliament in September 2025 and brought into force in autumn 2026, according to the Scottish Government. The reforms will introduce a new rating, the HRR, on domestic EPCs1.
The timetable was set out in a Scottish Government consultation on minimum energy efficiency standards for the domestic private rented sector, published on 6 June 2025 and closed on 29 August 20251. The consultation document states that the draft private rented regulations are designed to use reformed EPCs as the measure for a minimum standard, and that the new EPC regulations are expected in Parliament in September 20251.
The private rented proposals would prohibit the letting of domestic properties that do not meet EPC HRR band C until the landlord has made the relevant energy efficiency improvements1. Implementation would be phased, applying to new tenancies from 2028 and to all privately rented homes by the end of 20331. The draft regulations set out exemptions relating to consent, negative impacts on the fabric or structure of a property, a cost cap, and temporary circumstances1. Local authorities would carry out enforcement and compliance duties, with powers to serve a penalty notice for individual acts of non-compliance, including financial penalties, a publication penalty or both, subject to an appeals process1.
The consultation also seeks views on amending the Energy Act 2011 to increase the maximum fine that could be imposed within regulations to £30,000, which the government says is intended to ensure consistency in powers across the UK1. The draft regulations are based on regulations laid but withdrawn in 2020, with amendments for consultation feedback, renewed climate change and fuel poverty targets, and inflation since 20201.
"At the time of this consultation, EPC s are being reformed in Scotland, with new EPC regulations due to be laid in Parliament in September 2025 and brought into force in autumn of 2026."
| Measure | Proposed date |
|---|---|
| New EPC regulations laid in Parliament | September 2025 |
| New EPC regulations in force | Autumn 2026 |
| PRS minimum standard, new tenancies | From 2028 |
| PRS minimum standard, all privately rented homes | By the end of 2033 |
Why it matters for households
The HRR rating will replace the current EPC measure on domestic certificates, so the band shown on a home's certificate will be produced on a different basis once the reforms take effect. For Scotland's housing stock and EPC ratings, that changes how a property's position against any minimum standard is judged, including for the properties below EPC rating C.
The private rented proposals apply to landlords rather than owner occupiers, but they set the direction for how energy performance is measured and enforced in Scotland. Tenants in the private rented sector would see the standard applied to their homes on the phased timetable, starting with new tenancies in 2028. The detail of the EPC regulations and the reform of Energy Performance Certificates therefore affects what a certificate means for any household, whether buying, renting or improving a home.
What happens next
The consultation closed on 29 August 2025, with responses to be published on consult.gov.scot1. The new EPC regulations are due to be laid in Parliament in September 2025 and brought into force in autumn 20261. The private rented minimum standard would then apply to new tenancies from 2028 and to all privately rented homes by the end of 20331. The Scottish Government has not reported a date for the laying of the private rented regulations themselves.
