The Scottish Government has published its official response to the Energy Performance Certificate (EPC) Reform consultation, which was initially presented to the industry in 2023. This response outlines the planned updates, that are set to be implemented alongside the rollout of the Home Energy Model in 2026.
Updates to Domestic EPC Ratings
The Scottish Government proposed several changes to the information provided on Domestic EPCs, with one of the aims being to introduce clearer terminology. The new system would feature three main metrics:
- Fabric Energy Efficiency Rating
- Heating System Type Rating
- Cost Rating
The Scottish Government, following a similar consultation in England and Wales, have considered adding secondary metrics, such as ‘Emissions Ratings’ and ‘Energy Indicator.’ However, industry feedback on these proposed metrics was largely negative. In response, the government has confirmed that the following new metrics will be introduced to Domestic EPCs in 2026:
Heating System Rating
The Heating System Rating will provide insight into the performance of a heating system and its potential for improvement, based on the following criteria:
- Emissions Category – This assesses the system’s emissions, from clean to high-pollution.
- Running Costs – This evaluates the cost of operating the system, presented on an A to G scale, reflecting the system’s operational expenses.
- Thermal Efficiency – This measures the system’s ability to convert fuel or energy into heat, displayed on an A to G scale.
Heat Retention Rating
The Heat Retention Rating will measure a home’s insulation and fabric energy efficiency. It will be based on the amount of energy needed to maintain a set temperature in the home (measured in kWh/m²/year). This rating will be displayed on an A to G scale, showing both the current and potential ratings.
Scottish Government research suggests that most homes with an EPC Energy Efficiency Rating of C will also achieve a Heat Retention Rating of C. However, 15% may improve to a higher rating, while 10% could see a decline.
Energy Cost Rating
The Energy Cost Rating will essentially replace the existing Energy Efficiency Rating (EPC or SAP rating), illustrating how changes to the home’s heating system or fabric affect the overall running costs. Like the other metrics, it will be presented on an A to G scale, with both current and potential ratings included.
Changes to Recommendations and Certificate Design
Concerns were raised about potential confusion among the public regarding how to interpret EPCs based on the addition of new ratings and metrics. Therefore, the Scottish Government has outlined several key updates:
- Refining Improvement Logic: The methodology for determining suggested improvements will be adjusted to prioritise enhancing the building’s fabric and favouring cost-effective options for homeowners.
- Renaming Recommendations: The current “Recommendations” section will be rebranded as “Potential Improvement Options.” This section will now include clearer guidance to help homeowners understand available improvements, steps for implementation, and funding opportunities.
- Emphasising Low-Carbon Heating Solutions: If a property currently uses a high-emission heating system (such as a gas boiler), the EPC will now highlight potential pathways for switching to clean heating technologies (such as heat pumps). It will also recommend a detailed assessment to identify the most suitable heating solution for the specific building.
- A Redesigned Certificate: The EPC itself will undergo an update to reflect these changes, making the information clearer and more user-friendly.
Updates to Non-Domestic EPC Ratings
The Scottish Government also reviewed the structure of Non-Domestic EPCs. One major concern raised by respondents was that Scotland’s current rating system differs from the rest of the UK, leading to potential confusion. However, officials noted that Domestic and Non-Domestic buildings cannot be directly compared due to fundamental differences in how they are assessed.
To address these concerns, the government has decided to introduce a revised set of emission-focused metrics for Non-Domestic EPCs. Although only around one-third of respondents supported these changes, the government has confirmed that the following ratings will be implemented:
- Energy Demand Rating: This will indicate regulated energy use, allowing for comparisons with other buildings to assess efficiency.
- Energy Efficiency Rating: Displayed on an A to G scale, this will now align with the Asset Rating used in England, Wales, and Northern Ireland for non-domestic EPCs, ensuring greater consistency across the UK.
- Direct Emissions Rating: This new metric will provide clearer information about a building’s direct emissions, helping businesses and policymakers track environmental impact.
In addition to these changes that will be implemented, the Primary Energy Rating metric that already exists will be retained to enable comparisons with buildings across the EU.
These changes aim to simplify EPCs while making energy efficiency and carbon reduction efforts more transparent and actionable.
Heating System Classification for Non-Domestic EPCs
The updated Non-Domestic EPC will now include a clear classification for heating systems, aligning with the structure introduced for Domestic EPCs. Heating systems will be categorised into four distinct groups:
- Clean Heating
- Renewable Bioenergy
- Polluting Heating
- Hybrid Systems
As with Domestic EPCs, the certificate itself will undergo a redesign to present information more clearly. Additionally, EPCs will transition to a default online format, with an option for users to generate a printable version when needed.
EPC Validity Period Reduced to 5 Years
In a significant policy shift, the Scottish Government has confirmed that EPCs for both domestic and non-domestic buildings will now be valid for five years instead of ten. This change ensures that property buyers, tenants, and owners receive up-to-date and relevant energy performance information when making decisions about properties in all contexts.
Strengthening Quality Assurance
Ensuring that EPC assessments are carried out to the highest standards remains a key priority for the Scottish Government. They intend to collaborate with accreditation bodies to further improve assessor training and qualifications so therefore the assessments are carried out to the best standard.
Additionally, the government plans to introduce enhanced auditing measures, potentially incorporating ‘Smart’ auditing techniques, already in use in England and Wales and independent onsite inspections to verify the accuracy of assessments.
The overarching goal is to ensure that EPCs remain trustworthy and reliable, giving property owners full confidence in the accuracy of their energy performance ratings.
Moving to a Digital EPC
Scotland is set to follow England, Wales, and Northern Ireland by shifting EPCs to a fully digital format, replacing traditional PDFs. The goal is to improve accessibility and usability for the public. As part of this transition, the government is considering how best to display the redesigned EPC within a web-based format via the Scotland EPC Register. However, a printable version will still be available when needed.
To enhance user engagement, the Scottish Government has also commissioned research into developing a dynamic EPC user interface. This interactive tool would allow property owners to input various usage scenarios (e.g., heating patterns, occupancy levels) to better understand the impact of their behaviour on energy consumption.
Next Steps
The Scottish Government aims to introduce these changes alongside the launch of the new Home Energy Model, which is currently scheduled for the latter half of 2026. While this timeline is subject to change, aligning the reforms with the Home Energy Model is intended to minimise disruption and provide stakeholders with sufficient time to adapt to the new system.
Additional Information
For more details, you can read the full Scottish Government response here: Scottish Government EPC Reform Consultation Response
These upcoming EPC changes highlight the growing need for qualified assessors and up-to-date knowledge. At Quidos, we support professionals through our trusted accreditation schemes and comprehensive training programmes to ensure you stay ahead of regulatory reforms and industry best practice.
