Which? responded on 10 October 2025 to the Scottish Government's update on reforming Energy Performance Certificates, saying the reform plans address problems its research has identified with the certificates. Sue Davies, Which? Head of Consumer Protection Policy, said the information EPCs provide is "too often inaccurate, out of date or difficult to understand"1.
"The Scottish Government's reform plans are a step in the right direction to address these issues with clearer rating systems, practical information for consumers and measures to improve accuracy and reliability."
The Scottish Government's revised EPC regulations will introduce a new operational governance framework intended to strengthen quality assurance, including a new onsite audit and inspection regime to add to existing checks, according to the statement1. Which? said the changes are timely given household concern about energy bills and the challenge of moving to low-carbon heating, describing the move as support for consumers who want to save money and improve their home's energy efficiency1.
Which? has previously published work on EPC reform and on gaps in data from EPC audits, and has warned that the certificates are unreliable and in need of reform1. The statement does not set out the detail of the new rating systems, the timetable for the regulations coming into force, or how the onsite audit and inspection regime will operate. Those points have not been reported in the material published alongside the response1.
Why it matters for households
An EPC is the document that records how a home performs on energy, and it feeds into decisions about what an EPC measures and what a household is told about its own property. If the rating is inaccurate or out of date, the household is working from a wrong picture of its home, whether it is considering insulation and glazing improvements or trying to understand why its bills are what they are. Scotland's EPC rules sit within devolved building and energy policy, which differs from the regimes in England and Wales, so changes made in Edinburgh apply to homes in Scotland rather than across the UK1. The proposed onsite audit and inspection regime is aimed at the accuracy and reliability of the certificates themselves, which is the part of the system a household cannot check for itself. Which? frames the reform as relevant to energy independence at home because a certificate that reflects a property's real performance is the starting point for any decision about improving it1.
What happens next
The revised EPC regulations will bring the new governance framework into force, including the onsite audit and inspection regime1. No date for that has been given in the statement, and no further timetable for the reform programme has been reported1.