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Energy Performance Certificate Reform (Scotland)

The Scottish Government is overhauling the Energy Performance Certificate (EPC) system, with new regulations expected to come into force in October 2026. The aim is to provide clearer, more meaningful information on energy performance and heating emissions, supporting Scotland’s net-zero targets.

What’s Changing?

  • Solar thermal systems.
  • New EPC formats for both residential and non-domestic buildings.
  • Validity reduced to 5 years (currently 10) to ensure ratings reflect current building performance.
  • A new Property Report will accompany every EPC, replacing Recommendation Reports and providing tailored guidance on energy efficiency measures and alternative heating systems.
  • Stronger governance and quality assurance for EPC assessors and Approved Organisations.

Residential EPCs – New Metrics

Residential EPCs will introduce three clear A–G metrics, designed to be more intuitive for householders:

  • Heat Retention Rating (HRR) – how well the home retains heat, reflecting fabric performance such as insulation and glazing.
  • Energy Cost Rating (ECR) – estimated annual running costs under standardised conditions.
  • Heat Retention Rating (HRR) – how well the home retains heat, reflecting fabric performance such as insulation and glazing.

These metrics aim to support better retrofit decisions by linking comfort, cost and carbon performance.

Non-Domestic EPCs – Updated Methodology

Non-domestic buildings will move to a revised assessment approach that provides:

  • An Energy Performance Rating based on modelled emissions.
  • An Energy Use Rating (kWh/m²/yr), giving clearer visibility of actual energy demand.
  • A Direct Emissions Rating, highlighting on-site carbon emissions from regulated energy uses.
  • Updated heating-system classifications aligned with decarbonisation pathways.

This will give owners and occupiers a more transparent view of efficiency, operational performance and future compliance risk.

What This Means for Asset Owners

Portfolio risk: new metrics may change how buildings score relative to current EPCs.

This could affect asset value, ESG ratings, future lettability and compliance with lender requirements.

Older EPCs will be invalidated once the new system is live; EPCs will need refreshing more frequently.

Heat-loss performance and heating-system emissions may become more prominent indicators of asset quality.

Forward planning: early modelling can help identify buildings that may see rating changes and require retrofit or heating-system upgrades.

Atelier Ten can support with indicative performance modelling using English-methodology EPC tools and scenario testing ahead of the new Scottish software release.

What’s Next on the Policy Agenda?

The government is developing optional Heat & Energy Efficiency Technical Suitability Assessments to provide deeper, bespoke technical analysis beyond EPCs.

Proposals for minimum energy efficiency standards (initially for the private rented sector) are under review; these may reference the new EPC metrics in future.

A revised Heat in Buildings Bill is expected, taking a more pragmatic approach but retaining a 2045 ambition to phase out polluting heating systems where practicable.

How Atelier Ten Can Help

Atelier Ten is actively tracking the reform and modelling implications for new and existing buildings.

For further insight or to discuss implications for your properties, please contact our Environmental Divisional Director Sarah Peterson – sarah.peterson@atelierten.com

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