Scottish Government confirms EPC reform delayed until April 2028

The Scottish Government has confirmed that major reforms to Energy Performance Certificates (EPCs) in Scotland will now come into force on 30 April 2028.

The reforms, introduced through the Energy Performance of Buildings (Scotland) Regulations 2025, had originally been scheduled to take effect on 31 October 2026. However, following an initial delay announced in March 2026, the Scottish Government has now set a revised implementation date for both domestic and non-domestic EPCs.

The revised timetable is intended to align Scotland with the wider UK implementation of EPC reform and allow sufficient time for the Home Energy Model (HEM), supporting infrastructure and assessor training to be completed ahead of launch.

Scottish EPC Register fees will still increase in October 2026

Although the main EPC reforms have been delayed, the planned increase to tZhe Scottish EPC Register lodgement fee, charged by the Keeper of the Register, will still take effect on 31 October 2026.

The central register fee will increase:

• from £2.60 to £6.00 for domestic properties
• from £12.10 to £15.50 for other properties

Why are the fees increasing?

Elmhurst has raised the increase in EPC lodgement fees directly with the Scottish Government to better understand the reasons behind the change and its timing. We have been advised that the additional income will help support the costs of preparing for wider EPC reform, including changes to the register, calculation methodologies and enhanced audit arrangements. Some of this work is already underway, and the associated costs are already being incurred ahead of implementation.

Elmhurst will continue to engage constructively with the Scottish Government and represent members’ interests as these reforms progress.

Increased Quality Assurance and Onsite Audits

As with the increase in Scottish EPC Register fees, elements of the new quality assurance framework are expected to be introduced ahead of the main EPC reform implementation date.

The Scottish Government has advised Elmhurst that it is aiming to launch the new onsite audit regime in the second half of 2027. It has also said it will continue to engage with industry as the design develops, with the intention of giving Accreditation Organisations and their members sufficient notice before the new arrangements go live.

Elmhurst will keep members updated as further details are confirmed.

Transitional Arrangements

Existing Domestic and Non-Domestic Buildings

For existing domestic and non-domestic buildings being sold or let, a one-year transitional period will run from 30 April 2028 to 30 April 2029.

During this period:

• A valid existing EPC produced under the 2008 Regulations may continue to be used for a sale or let.
• Any new EPC commissioned from 30 April 2028 must be produced under the new 2025 Regulations.
• If a property using an existing EPC is sold or let again during the transition period, a new-style EPC will be required.
• From 30 April 2029, only new-style EPCs produced under the 2025 Regulations will be accepted for properties being sold or let.

The transition is designed to prevent a sudden surge in demand for new EPCs when the regulations come into force and give the assessor and property markets time to adapt to the new system.

Large non-domestic buildings

Different transitional arrangements will apply to certain large non-domestic buildings that are frequently visited by the public and are required to display an EPC.

These buildings will be able to continue displaying an existing EPC produced under the 2008 Regulations until either:

• the EPC reaches the end of its validity period; or
• 30 April 2033, whichever comes first.

After 30 April 2033, all buildings covered by these requirements will need to display a new-style EPC produced under the 2025 Regulations.

New Build Homes

For new buildings completed on or after 30 April 2028, a valid new-style EPC will need to be provided to the building owner within seven days of the completion certificate being submitted to the local authority verifier.

The Scottish Government has also confirmed that the next changes to Building Standards, which are expected to use HEM, are currently planned for Autumn 2029. This creates an interim period where SAP may continue to be used for Building Standards compliance while HEM is used for EPC production, and further detail will be needed on how this will operate in practice for the new build sector.