Scottish EPC reform delayed to 30 April 2028

The Scottish Government has confirmed that regulations introducing new-style Energy Performance Certificates, validity periods and rating systems in Scotland will be amended to come into force on 30 April 2028, rather than 31 October 2026¹. The change, set out in a factsheet published on 27 August 2026 and dated 24 August 2026, applies to both domestic and non-domestic EPCs¹. It follows what the government describes as extensive engagement with the UK Government and the EPC assessor industry, after a delay to reforms was announced during March 2026¹.

The majority of the Energy Performance of Buildings (Scotland) Regulations 2008 and the current EPC system will remain in place until Spring 2028, at which point the outstanding provisions of the Energy Performance of Buildings (Scotland) Regulations 2025 enter into force¹. The government says the revised timeline reflects a shared implementation plan agreed with the UK Government and the assessor industry, allowing time for the UK Home Energy Model and supporting infrastructure to be finalised and for assessors to be trained¹. The UK Government has publicly committed to implementing its own reforms during "the second half of 2027" and had not reached final decisions at the point at which the Scottish Government had to introduce amending regulations to prevent the 2025 Regulations coming into force on 31 October 2026¹.

Lodgement fees charged by the Keeper of the Register will still 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 properties¹. Provisions establishing the new Scottish EPC Accreditation Scheme and the appointment of Approved Organisations came into force on 1 January 2026 and remain in force; the scheme stays open to new applicants, who will be appointed ahead of the remainder of the 2025 Regulations coming into force¹. The remainder of the 2025 Regulations stays as approved by the Scottish Parliament in December 2025, and the government states there is no other change to the substance of reforms consulted on in 2021, 2023 and 2025, with a final Government Response published in October 2025¹.

Transitional arrangements under Regulation 38, as amended, give properties being sold or let, other than short term lets, up to a one-year grace period running from 30 April 2028 to 30 April 2029, ending earlier if the property is sold or let before then¹. During that period, either valid EPCs and recommendation reports issued under the 2008 Regulations or valid EPCs and property reports issued under the 2025 Regulations may be used¹. If a property is sold or let again within the transition period, a new-style EPC and property report will then be required¹. After 30 April 2029, only the new-style EPC will be allowed for sale or let¹.

Short term let properties, of which Scotland has approximately 30,000, get a full one-year grace period in which to obtain a new-style EPC¹. The government says this allows the sector a more evenly spaced transition and should minimise disruption to the market¹. For large non-domestic buildings covered by Regulation 13, buildings affected can continue to display the old-style EPC they currently display under the 2008 Regulations until the end of its validity period, or until 30 April 2033, after which a new-style EPC must be obtained and displayed².

"regulations introducing new-style EPC certificates, validity periods and rating systems in Scotland will now be amended to come into force on 30 April 2028"

Why it matters for households

An EPC is the document that records a home's energy performance and underpins decisions about insulation, heating and glazing, so the timetable for replacing the current certificate matters to anyone buying, selling, letting or improving a home in Scotland. The delay means the certificate a household holds today, issued under the 2008 Regulations, keeps its existing form and rating system for longer, and the EPC Regulations and the Reform of Energy Performance Certificates framework that governs it is unchanged in substance. For a home in Scotland, the practical effect is that the point at which a new rating system and redesigned certificate become mandatory for a transaction has moved to 30 April 2028, with a further year of mixed use after that. The higher lodgement fee from 31 October 2026 is a cost that sits with whoever commissions an EPC, and it applies regardless of the delay to the certificates themselves. Households in the private rented sector, where the government says around 31% of stock turns over each year, and owners of short term lets face the same backstop date of 30 April 2029¹. The Scotland's Housing Stock and EPC Ratings picture, and the devolved powers set out in Energy and Buildings Policy in Scotland: Devolved Powers Explained, are unchanged by this amendment. Nothing in the published material sets out new energy efficiency standards for privately rented homes in Scotland beyond the existing standards for privately rented homes.

What happens next

Lodgement fees rise on 31 October 2026¹. The new Scottish EPC Accreditation Scheme remains open for applicants, with appointments made before the remainder of the 2025 Regulations come into force¹. The audit regime is to be tested and available for assessor training during 2027¹. The outstanding provisions of the 2025 Regulations come into force on 30 April 2028, with the transition period for sales and lets running to 30 April 2029 and the display requirement for large non-domestic buildings running to 30 April 2033¹. The government says it will run a communications and marketing campaign for the property market and the public, with full details of the phased UK-wide go-live to be planned and communicated as the programme progresses¹.

Sources2 cited

1. 24 August 2026 - Energy Performance Certificate Reform: updates - gov.scot, gov.scot
2. Energy Performance Certificate Reform: updates - gov.scot, gov.scot