Scotland EPC Reform Confirmed - What & When

The Scottish Government has published what EPC Reform is going to look like. SAP assessors are advised to strap in… it could be a bumpy ride!

From October 2026, every property up for sale or rental in Scotland will need a new, HEM-based EPC. Old-style SAP-based EPCs will become invalid.

⏱️ Summary: Every EPC in Scotland will need to be redone, using a more complicated assessment tool that isn’t ready yet, with a nation of re-trained SAP assessors attending training courses that haven’t been written yet, signing up to 'new enhanced accreditation scheme requirements' that don’t exist yet, with inspectors completing on-site auditing checks who haven’t been recruited yet, and a new digital EPC Register at will cost more for assessors to use. But don’t worry, we’ve got [checks calendar] 380 days until this goes live. 😬 

Scotland is the first UK nation to confirm sweeping changes to the Energy Performance Certificate. England and Wales will also be reforming EPCs also, but haven't confirmed details yet.

The scary date for your diary is next Halloween - 31st October 2026 🎃 

That’s the date all residential EPCs in Scotland, both new-build and existing homes, must be created using the new Home Energy Model.

All the hundreds of thousands of EPCs created using SAP over the last decade will become invalid, regardless of their expiry date. The new EPCs will be valid for 5 years (not 10 as it is currently) so will need updating more frequently.

Scotland is keen to jump into HEM, and doesn't want SAP-based EPCs running in parallel and confusing the market. EPCs will have a new-look with new targets (which I’ll cover in my next post). 

The look of non-domestic EPCs will also be changing, but SBEM will still be used to calculate them (albeit an updated version of SBEM).

Old-style non-domestic EPCs will also need to be reissued using the latest methodology.

There will be a few exemptions to this rule. Existing house lets/sales, advertised before the Halloween cut-off will have one year’s grace before a new EPC is required.

Also, large non-domestic buildings will be given five-years grace because of the high cost of getting reassessed.

In other news, Scotland is getting a new, digital EPC Register. The new platform is expected to be like the system currently used in Wales and England so should make finding EPCs simpler.

Both SAP and rdSAP assessors will need to prove competency with HEM before they can lodge the new-style EPCs.

And quality checks are being taken to the next level... the Scottish Government plans to introduce on-site auditing. It’s not yet clear what these announcements mean exactly, or how frequently audits will be completed.

Either way, it’s a big leap away from the desktop auditing process currently used for EPCs throughout the UK.

Here's the official release:

https://www.gov.scot/publications/energy-performance-buildings-scotland-regulations-2025-update-government-response-epc-reform-consultations/pages/1/