The ongoing efforts to improve the energy efficiency of privately rented homes in Scotland, have been adversely affected by COVID-19. Set to be introduced on 1st April, The Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations 2020 were delayed due to the pandemic. Although there is currently no date set for the new legislation to come into force, landlords are planning how they will meet the minimum energy efficiency standards, now that Scotland is beginning to ease the lockdown measures.

A coalition of four membership organisations representing Scotland’s private rented sector, was formed to urge the Scottish Government to work with them on starting preparations for energy efficiency improvement works in advance of the minimum standards taking effect.

The Scottish Land & Estates, Scottish Association of Landlords, Central Association of Agricultural Valuers and Historic Houses Scotland wrote an open letter to Kevin Stewart, Minister for Local Government, Housing and Planning, expressing concerns about the consequences of COVID-19 on improvement works required to bring properties to the new minimum energy efficiency standards.

Danger of energy efficiency improvement works backlog

In a joint statement, the organisations said: “Private landlords in Scotland are committed to improving the energy efficiency of their properties. However, landlords have been unable to continue making improvements or to maintain property fully during the COVID-19 pandemic. This means there is a very real danger that there will be a backlog of work required to be completed.

“We are urging the Scottish Government to commit to a timeline which means the first ‘milestone’ of the regulations is one year after the new regulations are published. This will allow landlords sufficient lead in time to carry out improvements to properties that require to be upgraded to comply with minimum energy efficiency standards.


“Many landlords have suffered a substantial loss of income during lockdown due to rent reductions and rent holidays to help their tenants during this difficult and uncertain time. The funding of these maintenance and improvement works will require planning and enough time for income levels to rise. It is crucial that the government consider this.

“Landlords need reassurance from the government that any energy efficiency improvement works carried out now will be taken into account when the new regulations come in. They should not be discouraged from continuing to improve their properties before the new regulations are introduced.

“We continue to have concerns about the methodology and accuracy of energy performance certificates which will be used to show if a property is at the required standard or needs further work carried out to be more energy efficient. We want to continue working with the Scottish Government on this matter.”

The organisations have also called on the Scottish Government to publish a guidance (even if it’s just a draft at this stage) to help landlords better understand how the future legislation may affect them and how they can proactively plan upgrading their properties.