Energy Performance Certificate reform consultation: response

5. Quality Assurance and Approved Organisation Framework

You Said

Key Findings

• A large minority of respondents supported the proposals to review and update the auditing and assurance requirements for EPCs in Scotland (Q17)

Key themes

• Improvements to auditing and assurance requirements were broadly welcomed, with some comments that the current system does not produce consistency and there are some issues around quality
• Support for the consistency of high standards and accuracy of information, amid concerns about variations and discrepancies in EPC outcomes
• Smart auditing was broadly welcomed as being effective

Next most frequent themes

• Good governance and administration of the system was urged in order to gain consumers’ trust
• On additional assurance activities, a better system to help ensure the consistency of EPC surveys and assessments was advocated, including better ways of flagging inconsistencies
• Allied to this there were recommendations for the collection of real performance data
• Calls were made to ensure that assessors undergo proper training to attain the requisite accreditations and skills

Other themes

• Support for allowances and flexibility to be provided for traditionally built buildings and for enabling stakeholders to be able to challenge assessments and EPCs
• Concerns were expressed about extra burdens, costs and regulation on consumers arising from extra assurance requirements
• Other concerns were a perceived lack of clarity and detail in the auditing and assurance proposals

We Will Do

We are now finalising our review of the current Operational Framework that governs EPCs in Scotland, to ensure these assessments are undertaken to the highest quality standards by competent and qualified assessors. We want to work with the assessor market and with the Approved Organisations which oversee, accredit and train assessors, to ensure that quality improves further when the revised regulations are implemented.

We will also work with the UK Government where appropriate on issues such as quality assurance of EPC assessors (their skills and qualifications) across the UK, which is covered by UK-wide internal market legislation, following the responses received to the UK Government’s consultation on EPC reform^[11].

We welcome that key industry bodies themselves recognise the importance of this push to drive higher standards, especially in light of recommendations made over the last decade in the Bonfield review in 2016^[12] as well as in the Grenfell Tower inquiry report in 2024^[13]. Our review has also taken into consideration recommendations made within the 2019 independent external review commissioned by the Scottish Government^[14] itself, relating to quality assurance, and aims to address these (where appropriate).

Our review has also explored how to improve the enforcement of the EPC legislation and consumer redress mechanisms for home and business owners/ tenants.

The objectives of this review have been as follows:

• To critically assess the current basis on which organisations accrediting EPC assessors are appointed, and the wider role these organisations play in the market;
• To critically evaluate the existing mechanisms in place which ensure that EPCs are prepared to the appropriate standard of quality;
• To critically assess the provisions within the existing EPC regulations and Operational Framework to ensure that consumers are at the centre of the approved organisations and their members’ business;
• To critically evaluate the role of the current enforcement bodies (local authorities) in overseeing and implementing the existing EPC regulations; and
• To critically evaluate the current skills and qualification requirements for EPC assessors, and ensure that consumers across Scotland have access to highly qualified and competent EPC assessors regardless of their location.

This review is being underpinned by the following key outcomes:

• Satisfied home and business owners, tenants, and users;
• Achieving a “right first time” approach;
• Opportunities for Scottish business and workers;
• Supporting our proposed Heat in Buildings Standard and Social Housing Net Zero Standard;
• Accurate results that people can rely on;
• Trusted organisations delivering for Scotland; and
• Delivering best value for money for Scottish consumers.

The Scottish Government has engaged with a range of businesses representing the assessor industry, Approved Organisations, local government and consumer groups to gather evidence to help achieve these objectives and realise these outcomes.

We have also established an Independent Advisory Group and External Reference Group (featuring industry, local authority, and consumer representation) to review and agree our proposed approaches to reform. These groups will continue to meet throughout 2025-26 (and beyond, where necessary) to advise and support the Scottish Government to implement reforms.

We have now identified the areas where we think reform is needed, and we will implement these changes through a revised Operational Framework – which will be negotiated and come into force for Approved Organisations and assessors when the revised regulations come into force during 2026.

As noted earlier in this consultation, we also share a common interest with the UK Government and other devolved administrations in agreeing our approach in this area, given that issues such as assessor qualifications and skills are covered by UK internal market legislation. We will work with the other governments to agree a common approach to issues around accreditation, skills and quality assurance, reflecting the approach we set out below in responding to our own consultation, and to reflect on the outcomes of the UK Government’s consultation.

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. Following closure of the EPC reform consultation period 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 now supplemented by 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 or eligibility for government delivery programmes.

We therefore plan to align with these requirements through establishing new independent audit and inspection arrangements when the revised operational governance arrangements commence.

5.1 Conclusions of Operational Framework Review

These are as follows:

5.2 Skills and Qualifications

• We will undertake a joint exercise with the UK Government and other devolved administrations to a) assess the existing skills/ qualifications landscape across Scotland and the United Kingdom and b) make recommendations that can be taken forward to professionalise the EPC assessor industry. We intend that this includes review of the current National Occupational Standards (NOS) relating to energy assessment, to ensure they continue to form the foundation of a skilled, technically competent EPC assessor workforce. We commissioned research, which we will publish alongside the forthcoming technical consultation on EPC lodgement fees, to benchmark against EU best-practice skills requirements, and the findings of this report will help to inform this joint exercise.
• We will work with our Approved Organisations to a) improve the Continuing Professional Development (CPD) pathways offered to EPC assessors in Scotland and b) ensure potential routes for assessor upskilling are embedded within any revised Operational Framework (for example, those wishing to undertake more detailed technical suitability assessments in future).
• We are also working to ensure that there is a sufficient pool of competent and skilled EPC assessors available in the market to handle any anticipated increases in the volumes of EPCs needed to be produced to evidence compliance with any proposed, future mandatory standards.

5.3 Enforcement

• We will continue to work with local government to agree the future arrangements for the discharge of enforcement functions under the revised EPC regulations. This includes working with local authorities across the rest of the United Kingdom to understand best practice and lessons learned, and how these can be adopted in Scotland.
• We will continue to work with all parties involved in the property sales and letting process to ensure there is a clear understanding of the existing legal requirements around the production of valid EPCs in Scotland, and ahead of introducing the changes set out in this Scottish Government response through new regulations.

5.4 Quality Assurance

• We have commissioned an independent audit of all Approved Organisations, which is now complete. The results of these audits will help to inform the future Operational Framework.
• We will take further measures to enhance the existing Operational Framework to improve transparency and accountability, to ensure best value for home and business owners in Scotland. This will include exploring continuous improvement in the discharge of the various functions under the Operational Framework: from reforms to the Approved Organisation appointment process, to enhanced performance management arrangements.
• We have also revised and expanded the information collected within the Operational Framework annual reports, which all Approved Organisations are obliged to complete and return. This has allowed the Scottish Government to gain a greater appreciation of the challenges facing our Approved Organisations, and will allow us to work together to take targeted action where any common issues are identified.
• We will also consider what proactive measures can be taken to attract new applicants to become approved under the revised Operational Framework to ensure the market continues to remain competitive.

5.5 Audit and Inspections

• We will introduce enhanced auditing and inspections requirements to align with the recast Energy Performance of Buildings Directive (2024) – including considering introducing ‘smart’ auditing and independent onsite inspection and auditing functions.

5.6 Consumers

• We will ensure that any revised Operational Framework has the needs of consumers at its core, and we will work with our Approved Organisations to improve transparency around the consumer complaints process.
• We will continue to improve consumer knowledge with regards to the escalation mechanisms available to them, to ensure consumers have the confidence and knowledge to escalate any complaints or disputes relating to their EPC assessment experience to our Approved Organisations, where appropriate.
• We will seek to explore - with the UK Government and other Devolved Administrations - the potential for establishing a dedicated Ombudsman function for EPC consumer protection, and whether such function would be necessary to protect consumers both now and in the future.