Consultation on EPC reform in Scotland

Proposed reforms of Scotland's Energy Performance Certificate (EPC) scheme have been published for consultation.

The proposals have come about following recommendations by the Climate Change Committee (CCC), that were set out in the 2021 Scottish Government's Heat in Buildings Strategy. 

EPCs are required where a building or building unit is to be sold or let. The owner must make a copy of a valid EPC for the building or building unit and of the related recommendations report available to a prospective buyer or tenant.

Not only are they an important source of information for current and potential occupiers as they help them to understand the energy performance of the buildings, but EPCs are an important tool to help buildings reach net zero. The Scottish government have legally binding climate change targets of net zero by 2045, along with interim reduction targets of 75% by 2030 and 90% by 2040. Currently buildings in Scotland account for 20% of all carbon emissions. So in order to meet net zero and reduction targets, buildings need to be energy efficient and aim for zero direct emissions heating systems.

The current EPC regime is not appropriate to drive the improvements needed in order to move achieve these ambitions so proposals have been put forward to reform EPCs and ensure they are appropriate for the important role they have in the journey to net zero.

Proposed reforms cover both domestic and non-domestic EPCs, although some of the proposed changes apply differently to domestic and non-domestic buildings as their use and energy efficiency context is very different.

EPC changes

The following proposals are aimed at both domestic and non-domestic EPCs:

• clarify the purpose of EPCs;
• reduce the validity period from 10 to five years;
• modernise the Scottish EPC format, including moving to a webpage format, adding interactive links to signpost further advice and support, and providing links to more tailored recommendations;
• expand the sharing of non-personal EPC data to allow more effective use of this useful resource, including direct public access to current and historical EPC records (this would also apply to other related certificates, including Energy Action Plans and Display Energy Certificates);
• improve the assurance behind EPC assessments by updating the auditing requirements with a risk-based, smart auditing approach, as well as updating the operating requirements for approved organisations and their members.

Domestic EPC metrics

Proposals to revise the information displaced on domestic EPCs seek to expand and rename the current EPC metrics to the following:

• Fabric Rating – setting out the current modelled fabric performance of the building in terms of its heat loss in standard conditions, in kWh/m2/year, calculated through the standard assessment procedure (SAP);
• Cost Rating – setting out the current modelled annual costs of running the building based on the SAP assessment, and how these costs could change as a result of measures recommended. This is the same as the Energy Efficiency Rating (EER) currently displayed on EPCs;
• Heating System Type – clearly identifying the heating system installed in the dwelling and whether or not it meets the proposed Zero Direct Emissions Heating standard.

In a separate section the following would be reported:

• Emissions Rating – setting out the current modelled total emissions from the building in kgCO2e/m²/year. This is the same as the Environmental Impact Rating (EIR) currently displayed on EPCs;
• Energy Indicator – reporting the modelled energy use of the dwelling in kWh/m2/yr.

Non-domestic EPC metrics

Proposed reforms to non-domestic EPCs focus on the reduction of direct emissions, and the proposed metrics are as follows:

• Energy Efficiency Rating (A to G) – based on modelled emissions from regulated energy use relative to a reference building to align with the rating system used across the UK;
• Direct Emissions (kg of CO2e/m2/yr) – the building’s modelled direct emissions from regulated energy use to allow a focus on the decarbonisation of individual buildings. For buildings which only use grid electricity this will be zero;
• Energy Demand (kWh/m2/yr) - the building’s modelled regulated energy use under standardised conditions to allow comparisons between buildings;
• Heating fuel type and heating system.

What next?

The consultation on the proposed reforms is open to responses until 16 October 2023. Currently the Scottish government are hoping to introduce the reformed EPC regime not long after the amended Energy Performance of Building Regulations are introduced, which is anticipated in Winter 2023-24, ahead of the introduction of the proposed Heat in Buildings Regulations.

The Scottish Programme for Government made a commitment to consulting on proposals for a Heat in Buildings Bill in 2023. This Bill would seek powers to introduce regulations requiring domestic buildings to meet a minimum fabric energy efficiency standard equivalent to EPC C by 2033 and prohibit the use of direct emissions heating systems in domestic and non-domestic buildings by 2045.

It is understood that there will need to be a transitional period to allow for a move to new metrics and methodology for calculations under a reformed EPC regime. Therefore the Scottish government have mentioned the launch of a reformed EPC regime may be timed to coincide with the UK governments launch of SAP 11 in 2025.

For more information, see:

• Energy Performance Certificate (EPC) reform: consultation.