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Scotland propose radical changes to EPCs and aim to slash validity period in half


The Scottish Government has released a new consultation surrounding proposed changes to Energy Performance Certificates (EPCs). This includes changes to metrics, accessibility, and the use of data. The consultation closes at 23:59 on 10th October 2023.

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In 2021, the Scottish Government consulted on proposals to amend the Domestic Energy Performance Certificate. This was built on the principle that high-quality advice and information are vital for homeowners to understand their building’s current energy rating and help inform decisions on improving its energy efficiency.

The Scottish Government initially advised there would be three stages of consultation on EPCs. However, this has been modified following consultation responses, further research, and a wider consideration of the Heat In Buildings policy. The Scottish Government announced that stages two and three of the consultation will be provided in a planned consultation on a proposed regulatory framework for heat and energy efficiency, to be published in 2023; this is now live.

Summary of the 2021 Consultation:

The 2021 consultation focused on the addition of a delivered energy metric to domestic EPCs. Following engagement and feedback from the consultation and further policy development, the Scottish Government is considering alternatives.

The existing EPC is based on two metrics:

  • Energy Efficiency Rating (£): Based on running cost (£ per m2)
  • Environmental Impact Rating: Based on emissions (kg CO2e per m2)

The consultation proposes adding a third metric, which would inform dwelling owners about their property’s energy use. This metric would be called ‘Energy Use Rating’ and would be based on kWh/M²/year. The other two metrics would be retained but would be renamed as ‘Energy Cost Rating’ and ‘Carbon Emissions Rating’ to provide better clarity to building owners.

This consultation received numerous responses, including further feedback and suggestions, which the Scottish Government took on board. The Government has now released a new consultation on the revised proposed changes.

Summary of the new Consultation:

Following further research and the numerous responses to the 2021 consultation, the Scottish Government has now published a new consultation with the following proposals:

Domestic EPCs

  • Fabric Rating – This would provide a clear rating of the dwelling’s fabric efficiency, i.e., the energy required to be supplied by the heating system to achieve standardised internal conditions.
  • Cost Rating –Presenting a 0-100 rating index rather than a £/m2/yr indicator, as a £/m2/yr could suggest predicted running costs to homeowners (which is not the case).
  • Heating System Type – Include information about the efficiency of the system with the potential to introduce a classification of heating systems from high efficiency zero direct emission heating systems to Heating systems with direct emissions.

In addition, the Scottish Government also proposes that the EPC displays:

  • The Emissions Rating; and,
  • The Energy Use Indicator.

The Emission Rating and Energy Use Indicator is not intended to be used as headline metrics but will provide information that is useful to stakeholders. Beyond the metrics listed above, it is intended that the EPC with provide a clear description of the energy efficiency features of the dwelling, which will be displayed as a list.

Non-Domestic EPCs

The Scottish Government proposes to present the following set of metrics on Non-Domestic EPCs:

  • Energy Rating (A to G) – based on modelled emissions relative to a reference building to align with the rating system used across the UK.
  • Direct Emissions (kg of CO2e/m2/yr) – the building’s modelled direct emissions to allow a focus on the decarbonisation of individual buildings.
  • Energy Use (kWh/m2/yr) – the building’s modelled energy use under standardised conditions to allow comparisons between buildings.

In addition to this, they propose to make the heating system type and fuel more prominent on the EPC.

Purpose and Validity Period of EPCs

The Scottish Government has highlighted once again that EPCs have a key role to play as a first step towards improving energy efficiency and reaching zero direct emissions.

The consultation proposes reducing the EPC’s validity period from ten years to five. This would mean that an updated EPC would be needed at the current trigger points (such as a sale or let to a new tenant) if one has not been issued in the last five years. This is intended to provide prospective owners and tenants with more up-to-date information about the building.

Addition Proposals

In addition to the changes above, the Scottish Government are keen to move away from the PDF EPC to a more digital solution, similar to what is already seen in England and Wales.

Alongside an updated EPC format, the modernisation of the EPC Register offers the potential to improve the use of EPC data. Making full use of this dataset offers significant advantages to those involved in delivering net zero.


The Scottish Government proposes to introduce the reformed EPC shortly after amended Energy Performance of Buildings Regulations are introduced this winter, ahead of proposed Heat in Buildings regulations being introduced.

Elmhurst Response:

“Elmhurst is thrilled to see that this consultation is now live. EPCs remain an important asset to the industry and a key component in the UK’s goal of achieving net zero. Providing homeowners with advice and coherent information will allow them to make informed decisions and help prevent any misunderstanding of what EPCs are and what they are not, as we have seen from recent headlines.

Elmhurst also welcomes the proposals to reduce the validity of EPCs and to include more metrics. These are steps that Elmhurst has been advocating for for some time, as highlighted in our recent publication, The Elmhurst Almanac. The proposed changes will certainly help to provide clearer and more up-to-date information to home and building owners.

Finally, this consultation is also positive news for Elmhurst DEAs and OCDEAs, as it shows that the Scottish Government is committed to investing in the EPC and the future of energy efficiency.

Elmhurst will respond to the consultation on behalf of our members.”

Responding to the Consultation:

To view and respond to the consultation, click the link below: https://www.gov.scot/publications/energy-performance-certificate-epc-reform-consultation/pages/1/

The consultation closes on 10th October 2023, at 23.59.