Energy Performance Certificate reform: consultation analysis

Legislating for EPC Reform and Timeline

Key Findings

Key themes emerging across this question included:

• The most supported timeline, albeit by only a minority of respondents, was to align reform implementation with the launch of SAP 11 in 2025. This would help avoid confusion, avoid the possibility of further EPC reviews and allow time for the underlying calculation methodology to be adapted for the new ratings
• However, there were also calls for the reform implementation to take place as soon as possible. This was because of the need to reduce carbon emissions, introducing the proposed Heat in Buildings regulations and promoting growth in the electric heating sector
• A small minority of respondents suggested dates later than 2025 to allow more time to understand all the potential implications. There were concerns that the proposed timeline options were too soon
• There were calls for the implementation to be streamlined with the introduction or reform of other strategies for easier integration

Q19: Do you have a view on our timeline for reform implementation?

The table below has been based on verbatim data and should be treated with a degree of caution. The largest number of respondents who gave an opinion on a specified timeline opted for aligning reform implementation with the launch of SAP 11 in 2025. A significant minority of respondents overall desired this option, including a large minority of organisations. A smaller minority of respondents (mainly organisations) supported the proposed timeline of shortly after the amended Energy Performance of Buildings Regulations introduction in Winter 2023-24. However, a significant minority (almost all being individuals) either specified a timeline of later than 2025 or indicated that the suggested timelines were too soon.

Percentages may not add to 100% due to rounding *NB. Numbers are approximate, being generated from the open-ended part of the question.

Comments about Suggested Timelines

Detailed responses to this question were received from 237 respondents.

The most popular specified option of aligning reform implementation with the launch of SAP 11^[12] in 2025 was seen to be advantageous in helping avoid confusion. It would also allow time for the underlying calculation methodology to be adapted for new ratings. It would also help to reduce the bureaucratic burden.

A small minority said implementation should align with the UK government’s changes to SAP or RdSAP whenever they were to happen. Uncertainty around transition times for software that is needed to reflect the advanced technologies was also raised as a concern. Similar numbers wanted implementation to be done in conjunction with the rest of the UK in order for consistency.

Of the respondents who supported the proposed timeline, it was seen as sufficient time for building managers to implement improvements based on previous EPC recommendations. This would also allow time to bring in training for assessors. These respondents also said that:

• This would give more time to get used to changes
• There is an urgent need to reduce carbon emissions
• Delays would restrict growth in the electric heating sector

Additionally, there were views on a pressing need to introduce proposed HiB regulations. There were also comments that there were already too many delays to buildings’ regulatory changes. However, a significant minority of mainly individuals considered this to be too soon. It was felt that individuals needed more time to cope with and understand the new system, given other pressing concerns such as the cost of living crisis.

Of those suggesting dates later than 2025 for implementation, 2025 was viewed as unachievable. There was a perceived need for more time to understand all the potential implications. It was inferred a later date would allow for the natural replacement of older heating systems and enable future proofing of EPCs. Dates suggested were 2026, 2028, 2030, after 2030 or after the next Scottish election.

Other Comments about Timings

A significant minority voiced concerns over unrealistic timelines more generally. They felt sufficient time was needed to facilitate the transition and for implementation to fulfil full compliance. Additionally, that time was needed for professionals such as assessors to become trained, and for other stakeholders to adjust. There were also a few calls for transitional arrangements. Also, the phasing in of some measures to accommodate capacity issues for EPC provision; and of a need to run a concurrent publicity campaign.

There were a small minority of calls for the implementation to be streamlined with the introduction or reform of other strategies for easier integration.

Unrelated Comments

A small minority of respondents reiterated points made previously. These included:

• The need for public funding and support to be available to those for whom the cost of change is prohibitive
• Any change should apply to new builds only rather than existing homes.

The problems of retrofitting some properties were mentioned along with a view that properties were unlikely to meet EPC requirements without greater decarbonisation of the grid.

A significant minority reiterated arguments against the proposals and EPC ratings in general, amid criticisms of the government.