Scottish Government Launches MEES Consultation for Domestic Private Rented Sector
The Scottish Government has released a consultation which is proposing the introduction of minimum energy efficiency standards (MEES) for privately rented homes in Scotland.
The proposals outlined would, if enacted, require landlords of domestic private rented properties in Scotland to ensure homes achieve an Energy Performance Certificate (EPC) rating of C by April 2028 for new tenancies, and April 2033 for all tenancies.
This is set to follow the Scottish Government’s planned reforms to EPCs, expected to take effect from Autumn 2026. A reformed EPC will feature three headline metrics instead of the single current rating: a Heat Retention Rating (HRR), Energy Cost Rating (ECR), and a Heating System Rating (HSR). Of these, the HRR will form the basis for compliance under the proposed MEES regulations.
According to the Scottish Government’s response to the EPC Reform consultation, the new Heat Retention Rating (HRR) band C will broadly match the energy performance of homes that currently achieve EPC band C. In other words, although the format of the EPC is changing, the standard expected from homes will remain similar. Yet, the proposed regulations will require landlords to comply with the new HRR band C to meet requirements and an existing EPC band C certificate will not be sufficient.
Landlords whose properties fall short of this threshold will be prohibited from letting them unless they either meet the HRR Band C standard, have installed all relevant energy efficiency measures, or qualify for an exemption.
Proposed Enforcement and Penalties
Local authorities will be responsible for monitoring and enforcing the new MEES regulations. They’ll use data from the EPC Register and PRS property lists to check compliance and can issue penalties where standards aren’t met. Fines for non-compliance range from £600 to £3,000, depending on how long a landlord has been in breach or if false information has been provided. This local approach builds on existing schemes and aims to ensure consistent, effective enforcement across Scotland.
Exemptions
As with regulations in England and Wales, landlords will be able to register for an exemption if improvements are not viable. These exemptions will apply where:
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Improvements are too expensive
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Technically unsuitable (e.g. for older or protected buildings)
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Cannot proceed due to planning restrictions or lack of tenant consent
Temporary exemptions will also apply in cases such as a change of landlord.
The Scottish Government is also proposing a £10,000 cost cap (lower than the £15,000 cost cap proposed in England and Wales), meaning landlords will not be required to spend more than this to meet the standard. If a property cannot reach EPC HRR band C even after all suitable improvements within this cap, it can still be let under exemption rules.
Final Thoughts
Caroline Postles, Existing Dwellings Technical Team Leader at Elmhurst Energy, comments:
“We’re pleased to see the Scottish Government finally consulting on its proposed MEES regulations, a step we’ve long been calling for. If memory serves, these plans were originally expected several years ago but were understandably delayed by the Covid-19 pandemic.
Private rented homes are among the least energy-efficient in Scotland, with nearly half currently falling below EPC band C. This often leaves tenants in colder homes with higher energy bills, and little control to make improvements themselves. Having MEES regulations in place will provoke action to improve these properties; not only reducing fuel poverty but also supporting Scotland’s net zero ambitions.
Elmhurst will now take some time to review the consultation in full”.
The closing date for responses to this consultation is the 29th August 2025.
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