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Scotland takes first steps towards new framework for energy efficiency in non-domestic buildings


Following the release of Scotland’s Heat in Building Strategy, the Scottish Government has been seeking views on developing a new regulatory framework for energy efficiency in non-domestic buildings.

The new framework will be adopted for all non-domestic buildings, to ensure they are energy efficient and use zero emissions heating and cooling systems by 2045.A Call for Evidence titled: “Regulation of energy efficiency in existing non-domestic buildings” was released in December, and sought evidence of existing approaches to improving energy efficiency, and converting buildings to zero emission heat sources.It proposed 3 possible regulatory approaches to regulation:

  1. Measures-based approach – specifying a list of improvement measures that must be considered to reduce the energy demand associated with a non-domestic building.
  2. Minimum standards approach – setting a standard for the building’s operation under standardised conditions, most typically based on achieving a certain EPC rating for modelled energy use or emissions.
  3. Operational ratings approach – using the actual energy consumption and CO2e emissions from use of non-domestic buildings, as the basis for a regulatory approach.

How did Elmhurst respond?

You can read Elmhurst’s response in full here.

Elmhurst supports the Scottish Government in their move to reviewing the regulations and are always supporters of improvement and change for the better. Our key messages within this call for evidence are:

  1. Continue with the use of the asset rating (EPC) as a way of assessing non-domestic building energy efficiency in combination with an in-use occupancy assessment (DEC). Both provide the best overall measurement of a building, allowing for the best possible choices to be made to improve energy efficiency, reduce carbon emissions and save money for the building user.
  2. Adopt an end to end process for retrofitting building such as PAS 2038 which incorporates quality advice, assessment, design and installation by qualified, accredited and competent people. This approach is quality assured and managed to ensure the correct improvement measures are applied in the correct order to the correct standard ensuring a whole building approach is followed.
  3. Investment in EPC and Section 63 methodology to be consistent with other regions reducing confusion from across border stakeholders such as banks and lender. Ensuring the measures and processes are easily adopted by building owners and occupiers.
  4. Adopt a minimum energy efficiency standards (MEES) approach using the EPC. The use of MEES for the private rental sector in England has shown a shift towards improving energy efficiency awareness and implementation of energy efficiency measures.


A formal public consultation on detailed proposals for regulation in Scotland will be carried out in 2022.

To read the call for evidence click here.

To read Elmhurst’s response click here