EPC Scotland update

The Scottish Government has released its response/outcome to the Energy Performance Certificate (EPC) Reform consultation, a consultation originally put to industry back in 2023. The document confirms the planned introduction of new ratings, a redesign to the certificate and a reduction in the validity period, which are all due to be introduced in line with the release of the Home Energy Model (due in 2026).

Domestic EPC Ratings

The Scottish Government proposed revisions to the current information displayed on Domestic EPCs. These revisions looked at expanding the current ratings as well as renaming them to make them clearer. As a result they proposed 3 headline metrics which included a:

• Fabric Energy Efficiency Rating

• Heating System Type Rating

• Cost Rating

In addition to this, and similar to the recent EPC Reform consultation in England and Wales, the Scottish Government were also proposing to introduce secondary metrics in the form of an ‘Emissions Ratings’ and ‘Energy Indicator.

However, the feedback from the industry regarding the above metrics was generally unfavourable, and with that, the Scottish Government has confirmed its intentions to introduce the following metrics to Domestic EPCs in 2026:

Heat Retention Rating

The Heat Retention Rating, will provide information on the fabric energy efficiency of the home – i.e. how well insulated it is. The rating is based on the modelled energy required to heat the dwelling to set temperature conditions (in kWh/m2/year) This rating will be shown on an A to G rating scale showing a current and potential rating, equivalent to what is shown on the current EPC as a cost-based Energy Efficiency Rating. A property with a Heat Retention Rating of 30 kWh/m²/year or lower would be considered highly energy-efficient, corresponding to an EPC Rating of A. On the other hand, a property with a Heat Retention Rating of 351 kWh/m²/year or higher would be deemed inefficient, resulting in an EPC Rating of G.

Initial research from Scottish Government suggested that the majority of homes currently with an EPC Energy Efficiency Rating of C would also achieve a Heat Retention Rating of C, with 15% moving to a better rating and 10% moving to a lower rating.

Heating Systems Rating

Heating System Rating The Heating System Rating will provide an indication of a heating system’s current performance, as well as potential for improvements, based on three different criteria:

• Emissions Category– rates the type of system in respect of its emissions from clean to polluting.

• Running costs– The performance of the system in terms of how much it costs to run will be shown on an A to G scale. This will reflect how much it currently costs to use the system to heat the home to standardised conditions

• Thermal Efficiency– How effective the heating system is at using fuel or energy to produce heat, shown on an A to G scale.

Energy Cost Rating

The Energy Cost Rating is simply a rebranding of the current Energy Efficiency Rating (EPC or SAP rating) showing how changes to the heating system or fabric affect the cost of running the home . This will once again be delivered on an A to G scale, with a current and potential rating still in place.

Proposed Scottish Non-Domestic EPC

The Scottish Government also proposed revisions to the information displayed on Non-Domestic EPCs. They noted that a key concern raised by responders was that current Scottish non-domestic EPC ratings do not align with those used across the rest of the UK, potentially making this confusing for the general public. They also emphasised that Domestic and Non-Domestic buildings are not comparable, and continuity across ratings is not possible due to the “differing contexts” of each sector.

In light of this, a reformed set of metrics that focus on the direct emissions of Non-Domestic buildings were proposed. Although only about one-third of respondents agreed with these ratings, the Scottish Government has decided to proceed with the proposed metrics, which are as follows:

• The Energy Efficiency Rating, shown on an A to G scale and will follow the same rating scale as the Asset Rating used on non-domestic EPCs across England, Wales and Northern Ireland, allowing it to be used interchangeably across the UK.

• The Direct Emissions Rating which will provide further information on a buildings direct emissions

• The Energy Demand Rating which will provide information about the regulated energy use of the building and provide a point of comparison against other buildings. The Primary Energy Rating will remain as part of the non-Domestic EPC as this allows comparison with other buildings across the EU. In addition to this, the reformed non-domestic EPC will clearly outline a rating for the main heating system, following the same classification as the reformed Domestic EPC. The heating system can be categorised as:

• Clean Heating

• Renewable Bioenergy

• Hybrid Systems

• Polluting Heating

Similar to the domestic EPC changes, the certificate will be redesigned to better display the information and EPCs will move to a default online platform for consumers, with access to a printable version if required.

Validity

Validity Period to be reduced to 5 Years In a positive development, Scottish Government have confirmed that the validity period of EPCs for both domestic and non-domestic buildings will be reduced to 5 years. This is to ensure that consumers have up-to-date and relevant information when looking to purchase, rent, or make improvements to their property.

Triggers

An EPC should be re-assessed and re-issued whenever there is a change to a building that impacts its energy performance. The reduction in validity period to 5 years is a welcome step forward.

What’s next?

These new measures are planned to be implemented in line with the release of the new Home Energy Model, currently planned for release in the second half of 2026. Although this timeline could change, the Scottish Government believes the implementation alongside the Home Energy Model will reduce disruption and allow key stakeholders enough time to prepare.