Scotland Section 6 and PassivHaus consultation
The Scottish Government has published new proposals for changing Section 6 of the Technical Handbooks to create a ‘Scottish equivalent to the PassivHaus standard’.
📝 A public consultation on these changes is open until 16th October 2026.
Ten of the headline proposals are:
⏰ We have three years to get ready
These new requirements aren’t going live until the second half of 2029.
The original plan was to release in early 2028 as a voluntary option, but that’s no longer happening.
✅ SAP or HEM?
Section 6 modelling in Scotland will continue to use the current SAP10.2 until the new regulations come into force.
Then, we’ll have dual compliance options.
🟣 Either use the new Home Energy Model, or
🔵 Use an adapted version of the PHPP Passivhaus calculator that aligns with Section 6 targets.
Unlike in England and Wales, there is no plan to use SAP10.3 as a stepping stone for compliance.
🎯 Targets
◼️ The Delivered Energy Rate is staying, but will include the reporting of unregulated energy forecasts. Unregulated calculations are built into both HEM and PHPP calculations, but SAP only offers a very basic guess.
◼️ The Space Heat Demand will become mandatory. This is similar to the Fabric Energy Efficiency Standard used in England, and is currently an optional route for Scottish compliance for developers who don’t want to meet all the backstop U-Values.
🏚️ A new notional?
This is where things get complicated. Targets in SAP have always relied on a notional specification to create a comparison.
This proposal prefers an absolute figure based on a few key details about the dwelling.
So, an east facing, detached house in Edinburgh with a heat pump will have a target of X.
A south facing mid floor flat in Inverness with panel heaters will have a target of Y.
The specific Xs and Ys haven’t been published.
🧱 U-Values
Of the three GB nations, Scotland leads the way with the strictest U-Value requirements.
These proposals aren't looking to tighten any further, so expect 0.17 for walls, 0.15 for floors, 0.12 for roofs and 1.40 for windows.
But designers may need to push the overall fabric performance further to meet the new Space Heat Demand targets.
🌪️ Ventilation
When the concept of a Passivhaus equivalent standard was first published, there was talk of banning basic ventilation systems in new builds, pushing designers towards whole house systems, especially MVHR.
This idea appears to have been shelved.
As long as the dwelling meets the (as yet unknown) targets, any ventilation system can be used.
👷♂️ Air testing
The maximum air test allowed on new dwellings could be lowered to 5 under these proposals, although this comes with a caveat that building inspectors can allow for exceptions and extreme circumstances.
☀️ Overheating
Updates to the overheating part of Section 3 are also mentioned in this consultation, although not in any great detail.
There's a suggestion of replacing or updating the Simplified Approach for overheating calculations, and allowing PHPP as an alternative route to Dynamic. This makes sense if the same PHPP model can be used for both measuring energy performance and overheating risk
This also brings to mind previous discussions about creating a HEM wrapper to assess overheating within the same model.
❓ What does compliance look like?
We don’t know the targets. We don’t have a Scottish wrapper for HEM. We don’t have a Scottish version of PHPP.
So we don’t currently have a scooby about what specification details will comply. But it's a safe bet to say the Future Homes Standard specification, plus some tighter fabric standards, is a good place to start.
👮♂️ Is this a Passivhaus equivalent, or is this a cop out?
The idea behind these regs changes was never to go full Passivhaus, but to find a sweetspot that is technically feasible for all construction companies in Scotland regardless of size or location, to follow PassivHaus principles while also ensuring build costs don’t spiral, and to create rules which don’t conflict with other sections of the regulations.
The question for now is, do these proposals find that sweetspot, are they too watered down, or are they too Passivhausy? I'm sure opinions will be divided!
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