The Scottish Government entered consultation on EPCs in 2024 on proposals to reform them to better support Scotland’s journey to net zero. The findings were published at the end of January 2025 and regulations formed to give consumers better information on the energy efficiency of their properties and to implement stronger governance of the regulations to improve quality assurance.
These regulations (“Regulations”) will now come into force in late 2027 and not on 31 October 2026 as originally planned. This is to align with other UK nations and their changes being postponed until then. Until that time, the existing Energy Performance of Buildings (Scotland) Regulations 2008 (2008 Regulations) will continue to be operational.
What is an EPC?
An EPC is an energy performance certificate confirming how energy efficient a property is. There is a rating scheme to summarise the energy efficiency of the property that ranges between 1 and 100 or – inefficient to very efficient. An EPC also provides information on measures to improve energy efficiency and indicative costs for implementing these measures.
They are required for both commercial and residential properties and produced by accredited or approved assessors. They are administered separately in (i) England and Wales, (ii) Scotland, and (iii) Northern Ireland and our focus is on the requirements for non-domestic buildings in Scotland.
All non-domestic buildings must hold an EPC at the point of sale, letting or construction and are valid for 10 years.
What is changing?
Domestic buildings will now be classed under a new EPC rating system. The proposed new ratings will list the following for each property:
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Energy Efficiency Rating on an A-G scale, and incorporating the same rating scale as used in England, Wales and Northern Ireland is to help businesses and property professionals compare EPCs more easily;
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Direct Emissions Rating will provide a clear breakdown of the carbon emissions and help owners/occupiers understand their environmental impact and work towards decarbonisation goals;
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Energy Demand Rating will indicate the regulated energy use to allow comparisons when evaluating energy efficiency against similar properties;
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Property Report setting out information on primary energy use and improvement measures to increase efficiency and reduce emissions
The validity period for an EPC will reduce from 10 years to 5 and the aim of this is to ensure EPCs reflect recent energy efficiency improvement, provide more relevant information to those with an interest in the property and identify energy saving opportunities earlier.
Interestingly Scotland has not yet committed to establishing minimum energy performance standards for commercial property as we have seen in England.
What should you do now?
You should continue to ensure compliance with the 2008 regulations and although the new Regulations are delayed, it may be helpful to consider what they aim to achieve and whether there are any actions that can be taken to improve energy efficiency and reduce costs for your property.
Here to Help
EPCs are something that all property owners, landlords and developers should be familiar with. If you plan to sell, let or develop a property and would like more information about EPCs and the upcoming reform, please get in touch with our Real Estate team here at Weightmans.
