This information is subject to change and should not be relied upon. Legal advice should be sought from your solicitor.

The Scottish Government's EPC reform aims to modernise both non-domestic and domestic EPCs (Energy Performance Certificates) to provide clear, consistent, and usable information, to support the transition to net zero.

At the Elmhurst Scotland Conference in May 2025, the Scottish Government advised that the reforms would be formally announced later in 2025 and take effect in 2026.

The proposals are likely to change, but the Scottish Government proposals are included in the "reform".

No further minimum standards have been announced at the time of writing. As of 6 June 2025, the Scottish Government launched a Consultation for proposed minimum standards for privately rented homes in Scotland, based on some of the reforms.

Core changes to the non-domestic EPC rating system

Based on the Scottish Government consultation, the proposed changes for non-domestic would include the following. 

New rating metrics introduced

The reformed EPCs will display three main ratings on domestic Energy Performance Certificates (EPCs). This doesn't seem to be clear advice on whether these metrics will apply to non-domestic properties. A new version of SBEM was launched in 2023, and this has altered non-domestic EPC ratings significantly. Non-domestic EPC rating changes from 2023

Changes for domestic property include. 

• Energy Efficiency Rating (EER)

Expressed on an A-G scale, this metric is based on the building's modelled emissions from regulated energy use (kgCO2e/m²/year) relative to a reference building. This change aligns with the "Asset Rating" system in England, Wales, and Northern Ireland, enabling direct EPC headline ratings to be compared across the UK.

• Direct Emissions Rating

This would display the building's modelled direct emissions (kg CO2e/m²/year), highlighting the carbon emissions generated directly by the building (e.g., from gas boilers). Buildings that use only electricity or are connected to heat networks will display zero direct emissions.

• Energy Demand Rating

Reports the building's modelled energy use under standardised conditions (kWh/m²/year), allowing cross-building comparisons based on design performance.

Heating System Disclosure

The new certificates will highlight the type of heating system in use, categorised as: Clean / Renewable, Bioenergy / Hybrid /Polluting.

This classification mirrors domestic EPCs and supports decarbonisation and the electrification of the UK by providing clear visibility into heating technologies.

Primary Energy Rating Retained

The Primary Energy Rating (reflecting energy transmission losses) will be retained to maintain EU comparability.

Certificate redesign

The Scottish Government will redesign the EPC to be more accessible and engaging. The changes in the actual EPC report may include the Use of an A-G rating graphic, visual summaries, and property icons, a modular "block" layout for consistency, reduced text, and improved readability.

Operational Infrastructure Upgrades

To support the revised domestic certificates, the Government will implement the UK Home Energy Model (HEM) and replace the Standard Assessment Procedure (SAP). HEM will improve the accuracy of energy modelling and ensure consistency across the UK.

Launch a New EPC Register

This modern, cloud-based register will interface with the UK Government's HEM infrastructure and provide public and API access to non-personal EPC data.

Reduce the validity period of EPCs

Reduce EPC Validity Period: From 10 to 5 years, ensuring that property owners and renters have up-to-date information on building performance.

Improved Quality Assurance

Recognising past concerns about inconsistencies and data quality, the Government has announced that it will establish a new Operational Framework to enforce assessor competence and consistency.

Introduce a risk-based auditing system that includes on-site inspections, aligning with the EU's revised Energy Performance of Buildings Directive. The Scottish Government has decided to align EPC regulations with the EU as the UK Withdrawal from the European Union (Continuity) (Scotland) Act 2021

Warnings about potential retrofit costs and the need for financial support.

The Scottish Government has stated that the metrics for domestic and non-domestic EPCs will remain distinct due to the varying functions and energy profiles.

Heat Network

The certificates will also indicate whether a building is located within a heat network zone, supporting the development of low-carbon district heating schemes. Additionally, the Government may consider integrating more metrics or reforming the Section 63 process in its upcoming response to the Heat in Buildings Bill.

Other domestic EPC changes 

• New Approach to Recommendations - "Recommendations" will be renamed Potential Improvement Options to clarify that EPCs are indicative and not prescriptive. These options will:
  Prioritise fabric upgrades (e.g., loft insulation, cavity wall insulation).
• Suggest clean heating system transitions when appropriate.
  Before retrofits, include disclaimers urging further professional assessment via a proposed Heat & Energy Efficiency Technical Suitability Assessment (HEETSA)
• Accessibility features for users with disabilities.
  The default delivery format will shift from PDF to a dynamic, interactive webpage, with downloadable versions available. This modern format supports better data presentation and live updates.

Next Steps

The implementation of the Scottish EPC reforms is planned for 2026 and is contingent upon the rollout of the UK Home Energy Model. The Government will conduct further technical consultations in 2025, including revised EPC lodgement fees to fund the new infrastructure and governance systems.

The Scottish Government's January 2025 response to the EPC Reform Consultation does not introduce any new minimum EPC rating standards in this document. However, there are strong indications that EPCs will be reformed to support future mandatory standards, which may include minimum ratings.

Key Points

At this stage, the reform does not include any further minimum EPC Ratings (Yet). However, a Scottish Government Consultation was launched on 6 June 2025, based on minimum ratings in Scotland for privately rented properties.

The Government's response does not set specific mandatory minimum EPC ratings for domestic or non-domestic properties as part of these reforms.

Preparation for future use in standards

The reformed EPC system is designed to support future regulatory use, including minimum energy efficiency or heating system standards.

The Government has consulted separately on proposals for a Heat in Buildings Bill and a Social Housing Net Zero Standard, which explore how EPCs could be used to evidence compliance with minimum requirements.

The response confirms that the Scottish Government is still considering whether and how EPC ratings might be used to support proposed mandatory standards.
The outcome of those related consultations will determine whether minimum ratings (e.g. EPC band C) will be required for specific property types or transactions (e.g., sales or rentals).

Improved accuracy and governance

Before introducing any binding minimums, the Scottish Government is focused on

1. Replacing SAP with the Home Energy Model (HEM).
2. Redesigning the EPC and enhancing rating clarity.
3. Upgrading Assessor quality assurance.

For more detailed information, you can access the full consultation documents on the Scottish Government website.

This information is subject to change and should not be relied upon.