The Scottish Government has announced proposals for the extensive reform of Energy Performance Certificates (EPCs). The aim of these reforms is to make EPCs more accurate in measuring the energy efficiency and easy for property owners to understand. The changes themselves are a little complicated, so at Under One Roof, we have aimed to summarise them below.
What is an EPC?
Every property that is being sold or rented has an EPC, which rates the property’s energy efficiency from A (the most efficient) to G (the least). The certificate is meant to give property owners a sense of what their energy costs will be, and the environmental impact of heating their property. However, the use of EPCs to measure the energy efficiency of a domestic property has been criticised for years because of their use of outdated and insufficient data. For instance, EPCs currently only need to be renewed every 10 years. In that long timeframe, many changes can be made to a property to change its energy efficiency, rendering the current certificate out-of-date. Secondly, a property’s rating is based on modelled, not actual, running costs, and these models may not accurately reflect a property’s real fuel use or insulation level. Additionally, assessors typically do not have access to all the information they need to carry out an accurate calculation, such as information on all the layers of materials used to build the walls of a property.
To address these critiques, the Scottish Government announced proposals in January 2025 to introduce an entirely new ratings system, which should give clearer information about emissions, energy efficiency and costs of heating a property.
What are the proposed changes?
Firstly, the validity period of EPCs will be reduced from 10 years to 5. The increase in the -frequency of assessments should result in more up-to-date information provided to property owners, tenants, and potential buyers.
Secondly, the entire ratings system will be changed to provide a more accurate picture of a property’s energy efficiency, carbon emissions, and associated energy costs. This information will be presented on a redesigned certificate, to make the information clearer and more accessible. Non-domestic buildings will have a new, separate ratings system to reflect the different way in which energy is consumed compared to domestic buildings.
Furthermore, the governance arrangements for EPC assessors will be tightened, and a list of approved organisations will be set up to improve quality assurance. According to the government, this will ensure that a high standard of assessment is delivered across the country.
Additionally, new procedural infrastructure will be introduced to replace the current Standard Assessment Procedure (SAP) with a different calculation model called the UK Home Energy Model (HEM). As the name suggests, this will be shared with the UK Government to ensure similarly high standards across the UK. A new EPC Register will also be established.
In a statement on 21st January 2025, Alasdair Allan, the acting Minister for Climate Action, explained the benefits of the proposed new system:
“The system will ensure better information for consumers on how well a property retains heat and on the emissions and efficiency of its heating system, as well as re
designated and more accessible certificates. Consumers need to be able to trust the EPC assessment process, so the new regulations will be accompanied by tighter governance requirements to improve quality assurance.”
Why does the EPC process need to be reformed?
The proposals are being suggested in an effort to meet the Scottish Government’s legally binding target of achieving net zero carbon emissions by 2045. Improving the energy efficiency of homes and workplaces, which count for a fifth of Scotland’s total emissions, is seen as an important step towards this goal. Ideally, reforming EPCs, to give buyers, landlords, and tenants a more relevant and holistic rating of the energy efficiency of their property, will help to drive a reduction of carbon emissions and reduce fuel poverty.
The Scottish Government’s Climate Change Committee has advised that significant improvements must be made to the fabric of buildings across the country to lower emissions. This includes improving insulation, but also includes more significant changes, such as transitioning away from direct emissions heating systems which are powered by oil and gas, and towards zero direct emissions systems like heat networks and heat pumps.
Are there any downsides to the proposed changes?
The proposed changes align with what industry professionals have been asking the Scottish Government to do. However, there is still uncertainty on the impact of changes to EPCs for flat owners, particularly landlords, because of the requirements that are expected to be introduced in the Scottish Government’s Heat in Buildings Bill to meet energy efficiency requirements at a minimum EPC level.
In an interview with Good Morning Scotland, Josiah Lockhart, Chief Executive of Changeworks, a charity which gives advice on low-carbon living, stated:
“We don’t know what we’re being encouraged to do yet, until we see what the Scottish Government will produce in the Heat in Buildings Bill… that will set the timeline and dictate to us when and how we do this [make improvements to properties based on the new EPC ratings system]”
When will these changes take place?
Following Scottish Parliamentary approval, the proposed changes are expected to come into force in 2026 alongside requirements laid out in the Heat in Buildings Bill (which the Scottish Government is expected to introduce shortly).
Read more about the subject of energy efficiency in tenement buildings on Under One Roof’s website
