Proposal for new look EPCs in Scotland

We’ve had a sneaky peak at the proposed new EPC ratings, thanks to this Scottish consultation on setting MEES standards for private rental properties.

Improving the energy efficiency of Scotland's aging buildings is crucial to reducing CO2 emissions and lowering fuel bills

If you’re a Scottish landlord, tenant or retrofitter, have a read and provide feedback – deadline is August 29th:

https://www.gov.scot/publications/consultation-draft-energy-efficiency-domestic-private-rented-property-scotland-regulations/

The proposal says, from 2028, all new domestic private rentals (PRS) will need a C-rated Energy Performance Certificate or better. This is the new-look EPC, which will rank homes based on fabric performance, and must be created using the Home Energy Model, not SAP.

By 2033, every private rental in Scotland will need to comply. So that adds up to 300,000 HEM models, just for existing homes in Scotland. 😮 

MEES (Minimum Energy Efficiency Standards) already exist in England – homes need an E rating or better. But we're also expecting this to change in the near future also to a fabric-C, using HEM.

Interestingly, this Scottish consultation explains what a fabric-C means...

To give it its proper name, the Heat Retention Rating will measure annual heating demand in kWh/m2. To get the best EPC ratings, homes will need lots of insulation, modern windows, and maybe a cheeky little air leakage test to bump up the numbers.

There will be a cost cap for landlords in case upgrading to a C is too expensive (suggested £10,000). Other exemptions will apply to room lets, holiday homes, mobile homes, social housing (which has separate mandated targets), and where consent isn’t giving to complete the works (that could be from the local authority, heritage teams or even the tenant).

The consultation says:

🟢 A ratings will achieve <30 kWh/m2

🟡 B ratings will be <70

🟠 C rating will be <120

Until we have access to HEM and the specific Scottish EPC wrapper, we can’t calculate these ratings definitively, but similar calculation already exists in SAP Worksheets (Box 99), so you can use that as a guide for now.

The consultation mentions other metrics of the new EPC – the Energy Cost Rating (ECR) will predict fuel bills (similar to the existing EPC) and the Heating System Rating (HSR) will score the heating system based on how green the fuel is, and how efficient it is.

Although the UK Government hasn't yet published specific details from its EPC Reform, dare I say it would be sensible for English and Scottish EPCs to use the same targets!

Scottish Gov is planning to lay out final details of the new-look EPC this September, and the outcome of this MEES PRS consultation will be announced early 2026.

The race is on to change EPCs, to provide better information using a more accurate calculation tool.

Putting the focus on fabric performance will force landlords who own the coldest buildings to make improvements, as bolt-on tech (like PV) won't impact on the HRR.

Yet another policy that will be interesting to see how it develops!