New Deadline Confirmed for EPC Reform in Scotland

The Scottish Government has provided an update to confirm that proposals to reform EPC legislation will now take effect on 30 April 2028, a further 18-month delay on the original implementation date of October 2026.

This reform marks an important step towards Scotland’s Net Zero goals, with significant implications for property owners, developers, and the wider built environment.

The Carbon Futures team is ready to help our clients and design team colleagues navigate this update and ensure a smooth transition to the new standards.

We’ve summarised the key changes below:

• New regulations will come into force on 30 April 2028.
• The Home Energy Model (HEM) will be introduced as the calculation methodology to replace SAP.
• A new cloud-based EPC Register will store all digital EPCs
• A new Property Report will set out potential improvement measures that could improve the energy efficiency and lower the energy costs of the building.
• The validity of EPCs will reduce from 10 years to 5 years, ensuring consumers have more up-to-date information.
• Non-Domestic Buildings will have their own rating system covering Energy Performance Rating, Energy Use Rating & Direct Emissions Rating
• Domestic Buildings will have a new rating system covering Heat Retention Rating (a reflection of fabric energy efficiency), Heating System Rating (emissions and efficiency) and an Energy Cost Rating (an update to the existing efficiency rating.)
• The Scottish Government has identified the need to mitigate potential negative impacts on parts of the property market and there will be a grace period of one year for short term let properties and for properties being sold or let between 30 April 2028 and 30 April 2029.
• Developers of new buildings completed on or after 30 April 2028 will be required to provide a valid EPC and property report that meets the requirements of the 2025 Regulations to the owner of the building within seven days of submitting a completion certificate to a local authority verifier.