The Scottish Government has confirmed that reformed Energy Performance Certificate (EPC) regulations are due to be laid in Parliament in September 2025 and brought into force in autumn 20261. The reforms will introduce a new rating, the Heat Retention Rating (HRR), on domestic EPCs1. The HRR is a fabric based rating that provides information on how well a property retains heat, that is, how well insulated a home is, in contrast to the current main EPC rating, the Energy Efficiency Rating, which also takes account of the cost of energy2.
The regulations sit alongside proposals for minimum energy efficiency standards (MEES) in the domestic private rented sector in Scotland, set out in a consultation published on 6 June 2025 that closed on 29 August 20251. Under those proposals, landlords would be required to install energy efficiency measures to reach EPC HRR band C, as far as possible, before letting a property2. The draft regulations propose a prohibition on the letting of domestic properties which do not meet EPC HRR band C until the landlord has made energy efficiency improvements as provided for by the regulations1. Implementation would be phased, applying to new tenancies from 2028 and to all privately rented homes by the end of 20331.
"The HRR will be shown on reformed EPC s, which are due to be introduced in Autumn 2026."
The draft regulations set out exemptions relating to consent; negative impacts on fabric or structure of property; cost cap; and temporary exemptions1. 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 sought views on amending the Energy Act 2011 to increase the maximum level of fine that could be imposed within regulations to £30,0001.
The Scottish Government is working with the UK Government on the new EPC methodology, the Home Energy Model (HEM), and anticipates HEM and associated infrastructure to produce HEM EPCs will be in place in the second half of 20262. The partial business and regulatory impact assessment states that its figures are based on information from current EPCs and are therefore subject to change2. A final BRIA is to be published alongside the final regulations2.
| Measure | Date |
|---|---|
| EPC regulations laid in Parliament | September 20251 |
| Reformed EPCs and HRR in force | Autumn 20261 |
| HEM EPC infrastructure expected | Second half of 20262 |
| MEES apply to new tenancies | 20281 |
| MEES apply to all privately rented homes | End of 20331 |
Why it matters for households
The HRR measures the fabric of a home rather than the cost of the energy used in it, so it reflects how well a property holds heat2. For households, that changes what an EPC tells a buyer, tenant or installer about a home: the rating will speak to insulation and heat retention rather than running costs alone. Scotland's draft Climate Change Plan, published on 6 November 2025 and since superseded by the final plan published in March 2026, states that emissions from buildings, primarily from heating, account for 15% of Scotland's greenhouse gas emissions, having reduced by 39% since 1990 to 6.0 MtCO2e in 20233. The same document estimates that 861,000 households in Scotland (34%) are living in fuel poverty and 491,000 (19.4%) in extreme fuel poverty3.
For privately rented homes, the proposed band C requirement would place the cost of reaching that standard on landlords, with exemptions available in defined circumstances1. Tenants in homes that fall below the standard would be affected by the phased timetable rather than immediately, since the requirement would first apply to new tenancies from 20281. The Scottish Government has said it is planning to create powers to set minimum energy efficiency standards for owner/occupier and non-domestic properties, subject to further consideration3. Details of any such standard for owner-occupiers have not been reported.
What happens next
The consultation on the draft PRS MEES regulations closed on 29 August 2025, and responses are to be published on consult.gov.scot1. The EPC regulations are due to be laid in Parliament in September 2025 and brought into force in autumn 20261. The final BRIA is to be published alongside the final regulations2. The Scottish Government has said it will prepare a heat decarbonisation strategy setting out actions intended to meet the decarbonisation target3.
Sources3 cited
- 3. PRS MEES consultation - Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations: consultation - gov.scot, gov.scot
- Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations 2026: partial BRIA - gov.scot, gov.scot
- Annex 2 – Sectoral Annexes - Scotland's draft Climate Change Plan: 2026-2040 - gov.scot, gov.scot