EPC Reform in Scotland: What the latest delay means for landlords
If you are a landlord in Scotland, you may have noticed that EPC reform has been moving at a rather leisurely pace. There is now another change to the timetable and, for landlords, it means a little more time to prepare.
The Scottish Government has published draft regulations proposing to delay the introduction of new-style Energy Performance Certificates (EPCs) from 31 October 2026 to 30 April 2028. The change follows delays to the UK-wide methodology and technical infrastructure needed to support the new EPC system.
So, what does this actually mean for landlords?
What is changing?
The current EPC system will eventually be replaced with a new system designed to provide a clearer picture of a property's energy performance.
For domestic properties, the new EPC will include three key ratings:
- Heat Retention Rating (HRR) – showing how well the building retains heat.
- Heating System Rating – providing information about the property's heating system.
- Energy Cost Rating – continuing to provide information about the estimated cost of running the property.
The new system will use the Home Energy Model (HEM) rather than the current SAP methodology.
One of the biggest changes for landlords is the introduction of the Heat Retention Rating. This focuses on the building itself – essentially, how well the property retains heat.
The Scottish Government has committed to maintaining broad equivalence between the current EPC Band C and a “Good” Heat Retention Rating, expected to be HRR Band C or better. However, the new rating system is designed differently, so landlords should not assume that an existing EPC rating will automatically translate directly into the same HRR rating.
EPCs will also be valid for less time
Another important change is the validity period.
Under the new system, EPCs will be valid for five years rather than the current 10 years. This means landlords will need to budget for EPC renewals more frequently in the future.
What happens between 2028 and 2029?
There will be a one-year transition period from 30 April 2028 to 30 April 2029.
During this period, a valid existing EPC issued under the current system can still be used for a sale or let.
However, there is an important catch.
If a property is sold or let using an old-style EPC during the transition period and is then sold or let again before 30 April 2029, a new-style EPC will be required for the second transaction.
After 30 April 2029, only new-style EPCs will be accepted for sales and lets.
The transition period is intended to give landlords, property owners and EPC assessors time to adjust to the new system without creating an immediate rush for new certificates.
What does this mean for MEES?
This is where things become particularly relevant for landlords.
The Scottish Government has been developing proposals for a Minimum Energy Efficiency Standard (MEES) for privately rented properties. The consultation proposed using the new Heat Retention Rating as the basis for the minimum standard.
The original proposal was for MEES to apply to new tenancies from 2028, with all privately rented properties meeting the standard by 2033. However, these dates are proposals rather than confirmed deadlines.
Because the new EPC system, including the HRR, will not now be introduced until 30 April 2028, the previously proposed MEES timetable will also need to be reconsidered.
The Scottish Association of Landlords (SAL) is calling for at least two years between the introduction of the new-style EPCs and the first MEES compliance deadline, giving landlords time to understand the new rating system, assess their properties and plan any necessary works.
For now, there is no confirmed new MEES start date.
What could MEES mean for landlords?
Although the final rules are still to be confirmed, the proposals give us an indication of what landlords may need to prepare for.
The proposed standard is based on the property's Heat Retention Rating, rather than simply requiring every landlord to carry out a specific list of improvements.
This is important because the same improvement may not have the same impact on every property. The age, construction and characteristics of a building will all affect its heat retention.
The proposals have also included exemptions and a proposed £10,000 cost cap for qualifying improvements, although the final rules are still subject to change.
This is one reason why landlords should be cautious about making major investment decisions based solely on today's EPC rating.
1Let's advice for landlords
So, what should landlords actually do now?
If your property is EPC C or above
You are likely to be in a relatively strong position, but don't assume your current EPC rating will automatically translate into the same HRR rating.
The Scottish Government is aiming to maintain broad equivalence between the current EPC Band C and a “Good” HRR rating, but the new system measures property performance differently.
If your property is below EPC C
Don't panic and don't rush into expensive works purely because of the upcoming EPC changes.
If your property needs repairs or improvements for other reasons, these should of course be considered on their own merits.
However, if you are considering significant energy-efficiency improvements specifically to prepare for future MEES requirements, it may be sensible to understand the new HRR system first. This should give you a clearer picture of what your property actually needs and help ensure that your investment is targeted at improvements that support future compliance.
In other words, now the advice isn't necessarily “wait” – it is “understand what you are investing for before you spend.”
Plan ahead
The new EPC system is currently proposed to begin on 30 April 2028.
Once the new system is in place, a new EPC will provide more detailed information about the property's heat retention and heating system. For landlords planning refurbishment or longer-term investment, this information should be useful when deciding where money is best spent.
If your property is likely to require improvements, it is worth starting to think about them now rather than waiting until a compliance deadline is approaching. But where possible, avoid making major regulation-driven investments based solely on the current EPC rating while the new methodology and MEES rules are still evolving.
Keep an eye on the rules
This is unlikely to be the last EPC update we see.
The timetable has already changed, the new EPC methodology is still being implemented, and the proposed MEES dates will need to be revisited. The Scottish Government is continuing to develop the new system, while SAL is calling for sufficient time between the introduction of the new EPCs and any future MEES compliance deadline.
Our advice is simple: don't ignore the changes, but don't panic either.
There is now more time to understand what the new system means, assess your portfolio and plan investment carefully.
We'll continue to monitor the changes and keep landlords updated as the Scottish Government confirms the next steps.