Energy Performance Certificate reform consultation: response

Ministerial Foreword

I am pleased to set out the Scottish Government’s response to the 2023 Energy Performance Certificate (EPC) Reform Consultation.

EPCs play a key role in Scotland’s property market, ensuring that current or potential owners and tenants have information on a property’s energy efficiency and emissions, and on potential improvements. Over 200,000 are issued every year, engaging with a range of households, workplaces and community buildings across Scotland.

They are therefore a foundation for our Heat in Buildings Programme, and it is essential that they contain the information that consumers need to be able to make informed choices when moving home or considering making changes to their property.

The Scottish Government has a long-standing commitment to improving Energy Performance Certificates (EPCs) and stakeholders such as the statutory Climate Change Committee or consumer bodies such as Which? have long-advocated the need for reforms that ensure EPCs are of higher quality and provide better information that is aligned with net zero policy objectives.

Following an initial scoping consultation in 2021, we consulted again in 2023 on a final package of proposed reforms to improve the quality of EPCs and make them more fit-for purpose in supporting net zero. The Scottish Government is pleased to confirm as part of this Government Response that we will lay revised EPC regulations in Parliament during 2025, with an intention to bring them into force in 2026.

These regulations will introduce an improved EPC rating system which will give consumers better information on the actual fabric energy efficiency of their property and on the emissions and efficiency of its heating system, and on potential improvements they could make to both.

We will also retain the rating on modelled energy costs which consumer testing tells us is so important to them at this time of sustained high energy prices. That user testing has also allowed consumers to tell us how to make the design and accessibility of EPCs better, and we can confirm that introduction of a redesigned certificate will coincide with the regulations bringing the new rating system into force.

An initial version of this redesign is included in this response and will be subject to further testing before regulations come into force.

It is vital that consumers are able to trust the EPC assessment process, and the Scottish Government is therefore pleased to confirm that we will be introducing alongside the new regulations, strengthened operational governance arrangements for the EPC assessor market to enhance quality assurance for consumers.

These arrangements will form part of negotiations with the UK Government and other devolved administrations on assessor skills and qualifications within the UK internal market, and will coincide with the introduction of a new technical infrastructure to replace the current Standard Assessment Procedure with the Home Energy Model calculation methodology, together with a new EPC Register.

Our reforms to EPCs aim to remain aligned with the EU Energy Performance of Buildings Directive, from which EPCs originated across the EU, where it is desirable and feasible to do so. In the period since our consultation on EPC reform closed in 2023, the EU has subsequently adopted the recast Directive in April 2024. Our proposals for EPC reform would already broadly align with the Directive’s provisions.

One area where the EU has strengthened the Directive is around quality assurance controls to audit the accuracy and reliability of certificates. This will see existing desk-based random sampling of certificates now supplemented by verification through onsite inspections. The Scottish Government believes this development across the EU’s member states is welcome to ensure the highest levels of EPC quality for consumers – particularly vital if EPCs are evidencing any proposed mandatory standards. We therefore plan to align with these requirements through establishing new audit and inspection arrangements when the revised operational governance arrangements commence.

Before laying the new regulations, we will require to undertake further consultation on the level of EPC lodgement fees, which have not been revised since 2017, and will need to be updated to support the costs of establishing the new technical infrastructure for the Register and calculation methodology.

Subject to those discussions with the UK Government and other devolved administrations, we expect to bring the new regulations, new EPC rating system and redesigned certificates into force during 2026.

In the related consultations on proposals for a Heat in Buildings Bill and Social Housing Net Zero Standard, we also considered the role that EPCs could play in supporting mandatory standards. The Scottish Government is still considering its response to these consultations and will set out its position separately, when responding to them, on how EPCs could support proposed mandatory standards.

It is right that we make these reforms to EPCs to ensure they are fit-for-purpose for the future. I am confident that the decisions set out in this Scottish Government response will make lasting improvement to the EPC system and ensure that it provides more relevant information to Scotland’s consumers for many years to come.

Alasdair Allan

Minister for Climate Action