Scottish Government Consults on EPC Register Fees and Penalties
The Scottish Government has released a new consultation which is looking at potential changes to the fees charged when energy assessors lodge EPCs to the register, as well as penalty notices associated with EPC non-compliance/enforcement.
This follows the recent publication of the Scottish Government’s response to 2023’s EPC Reform consultation which will see a new look EPC and changes to regulations come into force in 2026.
Proposed changes to ‘Lodgement Fees’
The Scottish Government intends to adjust the lodgement fee levels for reformed domestic and non-domestic EPCs. For clarity, this is the fee which is charged on top of any accreditation lodgement fees and is more commonly referred to as a ‘register fee’ within industry.
This fee is put in place by Scottish Government to maintain the operational infrastructure of the EPC regulatory system, which with a new EPC in 2026, would include the provision of a Register, Calculation Methodology (Home Energy Model) and potential on-site audits/inspections.
The proposed fees—£6.00 for domestic EPCs and £15.50 for non-domestic EPCs—are intended to provide the necessary revenue to support the operational infrastructure and ensure fairness across both types of lodgements. This increase is also in response to the need for upskilling the workforce and maintaining high standards, which will ultimately benefit consumers by ensuring more accurate and reliable EPCs.
Increased Penalty Charges
Under the current EPC Regulations, local authorities can issue penalty charges if a property owner fails to provide a valid EPC when selling or letting a property. Since 2008, these penalty charges have been set at £500 for domestic properties and £1,000 for other types of buildings. Local authorities have reported rarely using these powers, and the Scottish Government is now considering whether the current charges are sufficient, especially given that EPC ratings can affect property value and eligibility for government funding.
With that said, the Scottish Government are seeking views on what the appropriate increase should be to penalty charges, to ensure that they are fair and effective when it comes to deterring non-compliance.
Elmhurst’s Thoughts
Elmhurst’s Technical Development Director, Andy Parkin, comments:
“While an increase to costs for energy assessors is never welcome; with reform to EPCs in Scotland, reduced validity period and other regulatory changes, not only will the demand/need for EPCs increase but so will their overall value. When we reach 2026, irrespective of these proposals, Assessors should really be looking at the value of their services and what they charge to building owners.
The fees do however, show a significant jump in cost, much of which is set to cover a new independent on-site inspection/auditing regime. While we do see the benefit of this, this particular venture could be difficult and even more costly in practice for the Scottish Government.
As for penalty notices, an increase to this is always welcomed as it will not only deter non-compliance but will also strengthen the value of the EPC”.