The Scottish Government has published an update to its Energy Performance Certificate reform consultation response, setting out final decisions on EPC reform and confirming it will lay the Energy Performance of Buildings (Scotland) Regulations 2025 in the Scottish Parliament on 10 October 20251. The regulations will come into force on 31 October 2026 and will revoke and replace the existing Energy Performance of Buildings (Scotland) Regulations 20081.
The update adjusts the bandings on the Heat Retention Rating, one of the new ratings on the reformed domestic EPC. The Scottish Government said the Home Energy Model calculation showed that the actual level of energy consumption for 80% of homes currently at EPC Band C was in the range of 91-159 kWh/m2/year, rather than the range of 71-120 kWh/m2/year estimated by BRE1. The government said it commissioned an independent study by Cotality in June 2025, which ran the Scottish housing stock through an initial version of the Home Energy Model1. The adjusted bandings will be used for further detailed modelling between now and the final version of the Home Energy Model, expected during 20261.
The Heating System Rating has been redesigned following further user testing. Instead of using labels such as "clean" or "polluting", the government will now use a single, colour-coded A-G letter1. The Energy Efficiency Rating will also be renamed the Energy Performance Rating1.
Other provisions confirmed in the update include reducing the validity period of EPCs from 10 to five years, and amending EPC lodgement fees to £6.00 for domestic certificates and £15.50 for non-domestic certificates1. The government said it did not propose to make changes to current levels of penalty charges, which are £500 for domestic properties and £1,000 for non-domestic properties1. It will review lodgement fee and penalty charge levels every two years, and review the onsite audit and inspection function within two years1.
"The Scottish Government is pleased to lay the new Energy Performance of Buildings (Scotland) Regulations 2025 in the Scottish Parliament on 10 October 2025."
Why it matters for households
EPCs are required when a building is advertised for sale or let, and form part of the domestic Home Report1. The shift to a new-style EPC means the ratings a household sees when buying, selling or renting will be calculated differently from the current SAP-based system. The Heat Retention Rating bandings have been widened to reflect modelled consumption under the Home Energy Model, which the government says is intended to keep the new Band C as largely as possible equivalent to the current EPC's Band C1. For a home's energy independence, the ratings themselves do not change the fabric of a property, but they shape what information a buyer or tenant receives about a building's performance and what improvements the accompanying Property Report suggests1. The shorter five-year validity period means the certificate on a property will be more recent1. A separate consultation on a potential minimum energy efficiency standard for the private rented sector, which would use the new Heat Retention Rating as a basis for setting the standard, closed at the end of August 2025 and is still under analysis1.
What happens next
The regulations are to be laid on 10 October 2025 and come into force on 31 October 20261. All EPCs issued under the 2008 Regulations will cease to be valid from October 2026, subject to transitional arrangements1. The relevant period is, at maximum, one year, from 31 October 2026 to 31 October 2027, but ends earlier if a property is sold or let before 31 October 20271. After 31 October 2027, only the new-style EPC and property report issued under the 2025 Regulations will be allowed for sale or for let1. After 31 October 2031, all building owners or occupiers covered by Regulation 13 will need to obtain and display a new-style EPC meeting the requirements of the 2025 Regulations1. The government said the two 2025 consultations on the Heat and Energy Efficiency Technical Suitability Assessment and the private rented sector minimum standard closed at the end of August 2025 and are still under analysis before Ministers take decisions1.