New EPC regulations in Scotland: what changes, and when.

The 2025 Regulations, and the delay to 2028

EPCs in Scotland are still issued under the Energy Performance of Buildings (Scotland) Regulations 2008. The 2025 Regulations, approved by the Scottish Parliament and made on 16 December 2025, replace them. Only the parts that let the Scottish Ministers approve organisations and accreditation schemes for EPC assessors have been in force, since 1 January 2026. As made, regulation 1 brought everything else into force on 31 October 2026, when the 2008 Regulations would be revoked, subject to transitional rules.

The Energy Performance of Buildings (Scotland) Amendment Regulations 2026 (SSI 2026/322), published in draft on 24 August 2026, approved by the Scottish Parliament and made on 28 October 2026, change that date to 30 April 2028 and move every transitional date with it. The date change came into force on 30 October 2026, the day before the original start date, and the fee change on 31 October. The Scottish Government's EPC guide already uses the 2028 dates.

Apart from the register fee (see below), the amendment changes dates, not the new rules themselves. Its policy note says the 2025 Regulations could not come into force as planned in October 2026 because the Scottish and UK Governments are jointly developing the infrastructure they rely on, including the Home Energy Model calculation methodology and a new EPC register.

Under either set of dates, an old-style EPC can only be used in the transition if it is still valid under the 2008 Regulations. The Scottish Government's guide, which uses the 2028 dates, says assessors will only be able to issue new-style EPCs from 30 April 2028, and that the short-term let window is designed to give Scotland's 30,000 short-term lets time to move across gradually.

What a new-style EPC shows

Regulation 8 of the 2025 Regulations sets out what the certificate must contain. For a home, the single Energy Efficiency Rating is replaced by three ratings, each showing the current and the potential position:

• Heat retention rating: the energy performance of the fabric of the building.
• Heating system rating: the emissions likely from the normal operation of the main heating system, and its efficiency.
• Energy cost rating: the estimated annual cost of the energy used in normal use of the home.

Non-domestic certificates show an energy performance rating, an energy use rating and a direct emissions rating instead. Every certificate also gives the address, the report reference number, the date of issue, the type of heating system (a broad category such as "gas boiler", "air source heat pump", "electric storage heating" or "heat network") and whether the building was in a heat network zone on the date of issue. The Regulations name the ratings; the methodology for calculating them, and the way each is expressed, are for the Scottish Ministers to approve and publish under regulation 10.

The recommendations report becomes a property report. It includes an indicator of primary energy use, measures that could improve the ratings or cut emissions, with estimated costs, and the name of the assessor and their accreditation scheme. For a home it also covers estimated emissions, the estimated energy used for heating, hot water, cooling, lighting and ventilation, and an alternative main heating system that could be installed, with its estimated emissions and installation and running costs.

What it means for landlords and letting agents

The core duty carries over. When a home is to be let, the owner must make a valid EPC and the related property report available free of charge to a prospective tenant, and give the tenant a copy once it is let. Someone becomes a prospective tenant as soon as they ask for information about the property, ask to view it or make an offer. Renewing a lease with the same tenant does not count as letting. The Scottish Government's guide adds that every self-contained dwelling that is rented out needs its own EPC, but renting a room with shared kitchen, bathroom or living space does not.

Adverts will need all three ratings. Regulation 7 requires any advert in commercial media to state the energy performance indicators. That covers newspapers and magazines, anything online, and written particulars: for a let, a written description with at least two of a photo, a floor plan, room sizes and the proposed rent. During the transition an advert may state either the new ratings or the single 2008 rating, so letting templates will need a place for three ratings as new-style EPCs arrive.

Plan for shorter validity. A new-style EPC lasts 5 years, so a home let to a new tenant more than 5 years after its EPC was issued will need a fresh one. For now, the guide says a new EPC is not needed when a current certificate's 10-year validity expires, unless the property is being sold or let to a new tenant.

Penalties. Local authorities enforce the Regulations. Under the 2025 Regulations a council can require an owner to produce the EPC within 7 days, and can give a penalty charge notice of £500 for a home or £1,000 for other buildings. For the duty to make the EPC available, a notice can only be given if the owner failed to do so within 10 days of a request. There are defences, for example where the owner asked for an EPC at least 14 days beforehand and could not get one, or where the advert instructions asked for the ratings. The guide describes the current penalty as £500 or more for homes.

What to do now: check each property's EPC on the Scottish EPC Register (search by postcode, or by report reference number to confirm it is valid), and note which homes may be let to a new tenant more than once in the transition window, since an old-style EPC can cover only the first sale or let in that window.

What it means for surveyors and EPC assessors

New-style EPCs must be issued by an energy assessor who is a member of an accreditation scheme approved by the Scottish Ministers, and the assessor must send the data to the register before issuing the certificate. The draft policy note says the Scottish EPC Accreditation Scheme remains open for new applicants. Existing approvals of organisations under the 2008 Regulations continue until 30 April 2028 under the amendment (31 October 2026 under the Regulations as originally made).

The register fee rose on 31 October 2026, to £6.00 for a home and £15.50 for other buildings, up from £2.60 and £12.10. With the amendment, those amounts apply under the amended 2008 Regulations; the 2025 Regulations set the same figures. The guide notes that the assessor pays the lodgement fee when an EPC is produced.

For a property surveyor, the new certificate separates the fabric (heat retention) from the heating system. A condition report that records insulation, windows, damp and the heating system, with photos, sits naturally beside it.

Where PropertySurvey Pro fits

• EPC details in the report: record the rating, potential rating, certificate number, expiry date and recommendations in the survey's Energy & EPC section, beside your condition findings. Scottish certificates are held on the Scottish EPC Register, so type the details in from the certificate.
• Room by room and outside: condition, defects and maintenance for each room and elevation, with photos and optional temperature and humidity readings.
• Dated photos (Pro): print the date and time each photo was taken or added.
• On site and offline: the PDF is built on your device before you leave.

Outside Scotland, see EPC property surveys for how the app's GOV.UK EPC lookup works.