Energy Performance Certificate reform consultation: response

6. Potential Future Reform

You Said

The Scottish Government did not ask specific questions on actual energy use data and Green Building Passports, however, building on the points above around how improvements to auditing and assurance would help ensure the consistency of high survey standards, a small minority of respondents also commented in favour of using actual or measured energy use in EPC calculations, perhaps alongside the SAP methodology.

A small minority of organisations referred to Building Performance Certificates or Green Building Passports (GBPs). Stated advantages included that they provide more detail than EPCs and focus on more than a fabric first approach. A combination of EPCs and GBPs could offer owners more bespoke advice about their property and provide homeowners with a clear roadmap to decarbonising their property.

We Will Do

The Scottish Government continues to recognise the role that actual energy consumption data can provide in supporting better consumer information alongside EPCs. The research which we commissioned on the use of energy consumption data in EPCs has now published alongside this Government Response^[15]. In summary, it says that:

Metered energy consumption data could be used in two ways; to provide more accurate information on building fabric performance, and to give an indication of how efficiency energy is used in the building. The report noted smart meter coverage, data access, and technical challenges as potential barriers, particularly in relation to using meter data as part of an asset rating. However, the report noted potential approaches to developing an indicator of operational performance as part of a dynamic, digital EPC.

As part of our proposed move to the more accessible, digital format for EPCs we have also now commissioned research to scope out the potential content for a new dynamic EPC User Interface. This would include interactive features allowing consumers to input different variables in terms of their behaviour and preferences, to understand the likely impact that this would have on their energy use. The research will:

• review existing approaches to displaying dynamic and interactive information about home energy efficiency,
• review evidence regarding the effectiveness of these approaches, and
• assess the importance of different occupancy variables that impact heat use and energy efficiency.

We expect this research to conclude later in 2025 and will use it to inform work to modernise the EPC Register. This work could make use of flexibility offered by the Home Energy Model to customise inputs and outputs.

It is important to note that providing a more dynamic interface for users to interact with the information contained in an EPC, to take account of their lifestyle and behaviour would not form part of what constitutes ‘the Energy Performance Certificate’ for legal purposes. It would only be a voluntary ‘for information’, add-on to the ‘fixed’ part of the EPC (which would remain as the certificate containing the ratings and potential improvement options, which are based upon standardised, modelled calculations).

We think, however, that interactive elements would provide an additional source of information to help building owners make informed decisions about potential improvements to their building based on the way they use it – such as showing how the benefit of insulation measures will depend on their energy use.