For several years, the Scottish Government has been working to modernise the Energy Performance Certificate (EPC) system. Progress, however, has been slow due to various factors – most recently the UK Government’s decision was to delay its own EPC reforms until the second half of 2027.
What were the proposed reforms?
In October 2025, the Energy Performance of Buildings (Scotland) Regulations 2025 were approved. These would have updated the EPC system from 31 October 2026 by:
- Reducing certificate validity from 10 years to 5.
- Introducing a new EPC layout with three new metrics:
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- Heat Retention Rating (HRR): A–G rating showing how well a property retains heat.
- Heating System Rating: Showing current and potential emissions category, thermal efficiency, and running costs of the main heating system.
- Energy Cost Rating: Based on the cost of running the home under standardised conditions.
The Government also proposed mandatory Minimum Energy Efficiency Standards (MEES) for the PRS via the draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations 2026. These aimed to require PRS properties to reach EPC C by 2028, subject to cost-cap exemptions.
What has changed?
On 17 March 2026, the Scottish Government confirmed the 2025 Regulations will not commence in October 2026 and Scotland will delay EPC reforms until at least late 2027, to align with UK-wide methodology changes and assessor retraining.
Accordingly, the 2008 regime remains in full effect. This means:
- PRS landlords must have a valid EPC when letting to a new tenant.
- EPCs remain valid for 10 years.
- There is no minimum EPC rating requirement for PRS properties.
- Local authorities continue to enforce compliance.
Outlook for PRS landlords
Whilst in the short term, there are no changes to implement, PRS landlords will require to await further updates after the 2026 Scottish Parliament elections. PRS landlords can, however, expect roll-out of a new EPC format and rating system in the future.
In a shifting regulatory landscape, staying informed is key. If you have any questions about how these changes may affect your property portfolio, or would like tailored advice, get in touch with the expert PRS team at prs@tcyoung.co.uk or visit tcyoung.co.uk.
