The Scottish Government laid the Energy Performance of Buildings (Scotland) Regulations 2025 in the Scottish Parliament on 10 October 2025, setting out its final decisions on reform of Energy Performance Certificates (EPCs) following consultations in 2021, 2023 and 20251. The regulations were originally to come into force on 31 October 20261. A later government update states that they will now be amended to come into force on 30 April 2028, for both domestic and non-domestic EPCs3.
The reforms introduce new ratings, redesign the certificates and change the operational infrastructure behind them2. The new domestic EPC replaces labels such as "clean" or "polluting" with a single colour-coded A to G letter, and renames the Energy Efficiency Rating as the Energy Performance Rating4. The government says the new Band C should be "as largely as possible 'equivalent' to the current EPC's SAP-based Band C"1.
Lodgement fees rise as planned on 31 October 2026, from £2.60 to £6.00 for domestic properties and from £12.10 to £15.50 for other properties3. Penalty charges are unchanged at £500 for domestic properties and £1,000 for non-domestic properties4. Provisions establishing the Scottish EPC Accreditation Scheme and appointing Approved Organisations came into force on 1 January 2026 and remain in force3.
The government attributes the delay to alignment with the UK Government and the EPC assessor industry, following a delay announced in March 20263.
"The Scottish Government has therefore decided to plan for the implementation of new EPCs from April 2028 to provide additional contingency within its implementation timetable."
Transitional arrangements under Regulation 38, as amended, give a grace period of up to one year for properties being sold or let3:
| Property type | Transition period | Backstop |
|---|---|---|
| Sale or let (other than short term lets) | 30 April 2028 to 30 April 2029 | New-style EPC only after 30 April 2029 |
| Short term lets (about 30,000 in Scotland) | 30 April 2028 to 30 April 2029 | New-style EPC only after 30 April 2029 |
| Large non-domestic buildings under Regulation 13 | Old-style EPC usable until end of validity or 30 April 2033 | New-style EPC after 30 April 2033 |
During the transition, properties being sold or let may use either valid EPCs and recommendation reports issued under the 2008 Regulations or valid EPCs and property reports issued under the 2025 Regulations, as amended3. If a property is sold or let again within the one-year period, a new-style EPC and property report will then be required3.
Why it matters for households
An EPC is required when a home is advertised for sale or let, and has formed part of the domestic Home Report since 20081. The delay means the current EPC system, and the majority of the 2008 Regulations, remain in place until spring 20283. A household selling or letting a home before then continues under the existing certificate. The shorter five-year validity period, once it applies, means a certificate held for a transaction will date faster than under the current 10-year rule4. The new ratings are intended to give clearer information on a building's energy performance and emissions, and the accompanying property report sets out potential improvements1. The government has also consulted on a Heat and Energy Efficiency Technical Suitability Assessment as an optional step beyond the EPC, and on a possible minimum energy efficiency standard for the private rented sector using the new Heat Retention Rating; those consultations closed at the end of August 2025 and were still under analysis at the time of the October 2025 response1.
What happens next
Lodgement fees rise on 31 October 20263. The remainder of the 2025 Regulations, as amended, comes into force on 30 April 2028, with the one-year transition running to 30 April 2029 and the Regulation 13 display backstop at 30 April 20333. The government says it will run a communications and marketing campaign for the property market and the public3.
Sources5 cited
- 1. Overview - Energy Performance of Buildings (Scotland) Regulations 2025 - EPC reform consultations: SG response - gov.scot, gov.scot
- Energy Performance of Buildings (Scotland) Regulations 2025 - EPC reform consultations: SG response - gov.scot, gov.scot
- Energy Performance Certificate Reform: updates - gov.scot, gov.scot
- Update to the Energy Performance Certificate reform consultation: Government Response, gov.scot
- Introduction - The Energy Performance of Buildings (Scotland) Regulations 2025, as amended by the Energy Performance of Buildings (Scotland) Amendment Regulations 2026 - Business and Regulatory Impact Assessment (BRIA) - gov.scot, gov.scot