What changed since the original announcement

The Energy Performance of Buildings (Scotland) Regulations 2025 were approved and made in December 2025. Their provisions for a new accreditation scheme and the approval of organisations began on 1 January 2026, but the main changes to certificates, ratings and validity were originally due on 31 October 2026. In March, the Scottish Government confirmed that timetable could not be met. Its August update proposed 30 April 2028 as the replacement date.

As of 28 September 2026 the draft 2026 amendment needed to change the commencement date is still before the Scottish Parliament. The new date and associated transitional arrangements should therefore be described as planned, subject to approval, rather than already in force.

The dates at a glance

What will the new non-domestic EPC show

The planned certificate brings three measures together. The Energy Performance Rating retains an A–G comparison based on modelled emissions from regulated energy use relative to a reference building. A Direct Emissions Rating will show modelled emissions arising directly at the building, while an Energy Use Rating will show modelled regulated energy use in kWh/m²/year. Information about the main heating system is also proposed.

These measures answer different questions. In particular, the Energy Use Rating is a standardised model result, not a reading from utility bills. The new presentation should give owners more context than a single headline grade when considering energy improvements or a change of heating system. The final calculation methodology and certificate design will need to be checked when published.

Will existing EPCs need to be replaced? 

There is no blanket requirement to replace a current non-domestic EPC in October 2026. Under the proposed transition, a still-valid EPC issued under the 2008 Regulations could be used for a sale or letting between 30 April 2028 and 30 April 2029. If the property is sold or let again within that year, the next transaction would need a new-style EPC and property report. After 30 April 2029, an old-style EPC would no longer meet the sale or letting requirement, even if its original ten-year expiry date is later.

There is a different arrangement for certain large non-domestic buildings that must display an EPC because they are frequently visited by the public. An old-style EPC already displayed could continue until it expires or 30 April 2033, whichever occurs first. A newly completed building on or after 30 April 2028 would require a new-style EPC and property report under the proposed rules.

Where does Section 63 fit? 

Section 63 Action Plans remain a separate consideration for qualifying existing non-domestic buildings. The delayed EPC reform does not suspend the existing Section 63 regime. Owners planning a sale or new letting should check both requirements, particularly where an existing Action Plan and EPC relate to earlier building services or fit-out. The proposed five-year EPC validity should not be taken to mean that an Action Plan automatically has to be renewed every five years.

Could this change again?

Possibly and probably. The Regulations have been laid before Parliament and are well advanced in the legislative process. Government publications consistently describe the reforms as coming into force on 31 October 2026. However, legal certainty is achieved only once Parliament has approved the instrument and Ministers have formally made it. At present, there is no indication that the Regulations will be withdrawn or delayed.

Are non-domestic EPC ratings changing and how will they change?

Yes. The Scottish Government has confirmed that non-domestic EPCs will be issued under a revised regime. Although much public commentary has focused on domestic EPC changes, the non-domestic system will also be updated. Government research indicates that the intention is to modernise the methodology and certificate format, providing clearer and more consistent measures of energy performance that better support investment and decarbonisation decisions.

What owners should do now

For current transactions, continue to apply the existing Scottish EPC rules. For a portfolio, it is sensible to record EPC issue dates, likely sale or letting dates, and any substantial changes to the building or its services. Good evidence on construction, heating, cooling, ventilation and lighting remains valuable under the present assessment and will help when the new system arrives.

The next point to check is Parliament’s consideration of the draft 2026 amendment. Until it is approved and made, the revised commencement and transition dates remain a Government proposal.

Key impacts for non-domestic property

The proposed reforms will affect when owners need to obtain an EPC and how they interpret its results.

• More frequent renewal: New-style EPCs are expected to be valid for five years rather than ten. This may increase assessment costs for properties that are regularly sold or let.
• Replacement of older EPCs: An existing EPC may remain within its original ten-year validity period but cease to be acceptable for a sale or letting after the proposed transition ends on 30 April 2029.
• More detailed results: The new certificate is expected to show energy performance, modelled energy use and direct emissions separately. Owners should consider all three measures when assessing improvements.
• Changes in reported ratings: A rating may change when a property is reassessed under the revised methodology, even where the building itself has not changed. Old and new ratings should therefore be compared with care.
• Greater importance of technical evidence: Accurate information on construction, heating, cooling, ventilation and lighting will help ensure that assessments reflect the building as closely as possible.
• Section 63 planning: The existing Action Plan requirements remain in place. Owners planning a sale or letting should consider EPC and Section 63 requirements together, but the proposed five-year EPC validity does not automatically require an Action Plan to be renewed every five years.

These impacts remain subject to the revised commencement and transitional arrangements being approved.

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