Scottish Government Sets 2026 Date for EPC Reform Implementation
The Scottish Government has officially laid the new Energy Performance of Buildings (Scotland) Regulations 2025 in the Scottish Parliament, with the regulations confirmed to come into effect on 31st October 2026, as set out in the Government’s response to the EPC Reform consultation published in January 2025.
The reforms represent the most significant shake-up of Energy Performance Certificates (EPCs) in Scotland in over a decade, aiming to provide clearer, more meaningful information for property owners and occupiers, and to better support Scotland’s journey to net zero.
What was announced in January?
At the start of the year the Scottish Government set out proposals to reform EPCs. The plan introduced a new three-metric rating system for domestic EPCs which included: Heat Retention, Heating System, and Energy Cost, replacing the single headline rating currently used.
The reforms aimed to provide clearer, more meaningful information on a building’s energy performance, with EPC validity reduced from 10 years to 5 years (both domestic and non-domestic), a new certificate design, and the launch of a digital EPC platform to show how different upgrades could affect a property’s performance.
Stronger quality assurance and oversight of accreditation schemes and assessors were also proposed, with initial changes for non-domestic buildings expected at a later stage.
FIND OUT MOREWhat new updates have been released?
As of today (10th October) the Scottish Government has laid the legislation in Parliament, confirming the reforms will take effect on 31st October 2026. No major changes have been made to the original EPC Reform proposal/outcome released early in the year, however, Elmhurst has identified the following key updates:
- A commitment to align the new EPC format with the Home Report: Following stakeholder feedback, The Scottish Government has committed to ensuring the new EPC format is closely aligned with the Scottish Home Report. This aims to reduce duplication and improve the clarity of information provided to homeowners and buyers.
- Further detail on the digital EPC interface that will support the transition: The Scottish Government has confirmed plans to introduce a digital EPC interface that will sit alongside the certificate, allowing users to explore upgrade options and see how different measures could affect ratings. A printable/PDF version of the EPC will remain available, but the preference is toward a web-based, interactive presentation of EPC data.
- No change to proposed metrics: The proposed three-metric approach (Heat Retention Rating, Heating System Rating and Energy Cost Rating) remains unchanged. The ratings will continue to use an A–G scale, with both “current” and “potential” ratings displayed (i.e. showing impact of improvements).
- Shift from SAP/RdSAP to the Home Energy Model (HEM) as the underlying methodology: The Scottish Government confirms that it will replace SAP/RdSAP with the UK Home Energy Model (HEM) as the foundational methodology for new EPCs. The move to HEM is central to the reform’s objective of delivering more robust, consistent, and comparable performance metrics across the UK and improving the relevance of EPC data.
- Transition and invalidation of EPCs issued before the 31st October 2026: As a result of the EPC metrics and design changing, and in order to ensures consistency, and reduces confusion, From 31 October 2026, only EPCs produced under the new methodology will be valid.
There will be a short transition period allowing existing EPCs to be used for sales, lettings and other trigger events taking place before the go-live date, but after that point the new format must be used. Older certificates will remain accessible in the public register but will be clearly marked as historic and invalid. - On Site Auditing to go ahead: Once the regulations are in force, The Scottish Government plans to recruit a team of auditors and inspectors who will work alongside local government enforcement authorities to carry out onsite inspections/audits. This auditing function will be reviewed within two years after implementation to assess resourcing, consistency and effectiveness.
Elmhurst’s Managing Director, Stuart Fairlie, is pleased to see this update from Scottish Government which signals that change is well and truly under way:
The laying of the legislation in Parliament is a major step forward for EPC reform in Scotland. It moves this agenda from consultation into delivery, giving the industry a clear date to work towards and the certainty needed to prepare.
The commitment to modernise the methodology, refresh the design of EPCs and strengthen auditing is a positive and necessary evolution of the framework. These changes have the potential to make EPCs more accurate, consistent and trusted, which is essential if they’re to play their full role in supporting Scotland’s net zero goals.
As the focus now shifts from policy to practical implementation, we look forward to working closely with the Scottish Government and other stakeholders to make sure the transition is smooth and effective for our members and consumers alike.”
Next Steps
The Scottish Government will now focus on implementing the legislation and supporting delivery ahead of the October 2026 go-live date. This includes finalising secondary technical consultations (such as lodgement fees and penalty structures), establishing the operational framework for enforcement and auditing, and working with local authorities to build capacity.
Related Links
Scottish Government Progress Report (10th Oct 2025): Energy Performance of Buildings (Scotland) Regulations 2025 – EPC reform consultations: SG response – update – gov.scot
Scottish Government EPC Reform Outcome (21st Jan 2025): 4. EPC Operational Infrastructure – Energy Performance Certificate reform consultation: response – gov.scot