EPC Changes in Scotland Delayed to Coincide with UK Changes

Energy Performance Certificates (EPCs) are the source of some confusion – not because of the certificates themselves, but because they are tied into government energy efficiency policies.

These are shifting sands, with implementation dates moving seemingly at random, requirements changing and landlords tearing their hair out trying to work out what they need to do and when. Or not as the case may be.

The proposed EPC changes in Scotland in contrast are fairly straightforward; the design of the certificate is changing, the methodology behind the rating is changing and the validity period is changing.

Originally scheduled for October 2026, the Scottish Government has announced that they are delaying the introduction of the new EPCs in order to better coordinate with the UK’s planned changes.

Additionally, from their statement it appears that work is not complete on revising the assessor training required because of the change in methodologies.

So, although reference is made to aligning Scotland’s changes with the rest of the UK, the Scottish Government appears at present to be unable to give a definitive date for these changes:

“We cannot confirm a new date until the UK Government agrees with industry and the Scottish Government its revised EPC reform timeline”.

As property professionals, these changes affect us and our clients, so let’s explain what’s changing and how, if not the when.

Information provided by the new EPCs

When the EPC changes come into force, the certificates will include three ratings:

A Heat Retention Rating (HRR)

A Heating System Rating (HSR)

An Energy Cost Rating (ECR)

Each of these will be rated from A (good) to G (poor). Additionally, the EPC will be accompanied with a property report which will suggest changes to improve these ratings.

Further, this report will show the expected changes to these three ratings if these suggestions are followed.

Heat Retention Rating (HRR)

As the name suggests, the HRR is a measure of how well a property is insulated and therefore how well it retains heat.

It will estimate how much energy (kWh/m2 /year) will be required to heat the property to a ‘comfortable temperature’ (21°C in the living area).

The Heat Retention Rating will now be calculated using the Home Energy Model (HEM), which will replace the Standard Assessment Procedure (SAP) which has been hitherto used in EPCs.

In addition to the current HRR, you’ll also get a potential HRR which reflects the changes to the rating if the suggestions made in the property report are implemented.

Heating System Rating (HSR)

The Heating System Rating concentrates on the efficiency of the main heating system in the property. It also takes into account the level of emissions generated when operating the system.

In order to achieve a rating of ‘C’ or above, a heating system must achieve zero direct emissions or near net zero emissions.

The ratings are:

(Table courtesy of Changeworks)

As before, the property report will make suggestions about alternative, more efficient, heating solutions along with suggested installation and running costs.

Energy Cost Rating (ECR)

The Energy Cost Rating aims to estimate the likely cost, expressed in £/m²/year, for energy use within the property. This includes heating, hot water, lighting, cooling, and ventilation, and replaces the old Energy Efficiency Rating.

The Energy Cost Rating will be calculated using expected energy prices from 2026.

Once again, the report will include a projected ECR based on all the suggestions in the property report being acted upon.

Validity period

Current EPCs are valid for a period of 10 years from the date of issue. It is proposed that when the new EPCs are introduced, this validity period will decrease to five years.

The stated aim of these EPC changes in Scotland is to ensure that consumers, whether buying a property or renting one, have up-to-date information.

Advice from the property pros

The EPC changes in Scotland should have been fairly straightforward, however the unexpected change of heart by the current Scottish Government rather throws things into a state of confusion.

When you stir in the expected change to the composition of the government itself as a result of the upcoming election, the PRS, along with everyone else who stands to be affected, will just have to wait and see what finally transpires.

The change of methodologies, fromSAP to HEM are esoteric and are not something we are going to delve into here. You’re welcome to do a deep dive yourself if that floats your boat!

What we can say is that this methodological change appears to be a substantial factor in the decision to delay the introduction of the new regime in Scotland.

The bigger change for the PRS in Scotland will be the introduction of revised EPC rating requirements for rental properties, starting in 2028 for new rental properties and to existing properties from 2033.

Where a property is currently below a C rating, we would recommend waiting for the new 2026 standards before starting major upgrades, to maximise your investment by ensuring any improvements are in line with the new requirements.

In summary…

Once again the PRS finds itself in the position of ‘hurry up and wait’. This does seem to be a recurring theme where the regulation of energy efficiency is concerned unfortunately.

Accordingly, having had a clear, scheduled change to adjust to just a few weeks ago, the PRS is once again in the position where it sort-of-knows what the government wants to do, but not when.

Moreover, we have no way of knowing at present whether or not the proposed changes will survive changes to the Scottish Parliament which are inevitable after May 7th this year.

Plus ça change, plus c’est la même chose!

We’re always happy to chat with you regarding the PRS in Scotland and how it can help you achieve your goals, so if it’s something you’re interested in, or it piques your interest, please just get in touch.

Thanks for reading!

Written by Ross MacDonald, Director of Sales & Cofounder of Portolio

Get in touch on 07388 361 564 or email to [email protected]