KJ Tait

Commercial EPC Requirements in Scotland: What Changes in 2028

EPC Changes Scotland
Date
1 September 2025
Updated7 October 2026
5 minute read

Service

Commercial EPC Assessments for Non-Domestic Buildings

Commercial EPC assessments for non-domestic buildings across England, Scotland and Wales. Level 5 DSM using IES VE and chartered engineering…

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Scotland is reforming its non-domestic EPC regime. The current 2008 rules apply until 30 April 2028, when new certificates with three separate ratings and five year validity are planned to take effect, subject to parliamentary approval.

Key points

  • The current EPC rules under the 2008 Regulations continue to apply until 30 April 2028.
  • The Scottish Government plans to bring the reformed EPC system into force on 30 April 2028, subject to parliamentary approval.
  • New non-domestic EPCs will carry an Energy Performance Rating, an Energy Use Rating and a Direct Emissions Rating, and will be valid for five years.
  • Old style EPCs can be used for sales and lettings until 30 April 2029 at the latest.
  • Section 63 applies now when buildings over 1,000 m² are sold or let, and the reforms do not revoke it.

Watch: Scotland's EPC changes explained

In this video, KJ Tait explains the revised timetable for EPC reform in Scotland and what it means for commercial property owners. A written summary of the video is set out below.

When do the new EPC rules start in Scotland?

The reformed EPC system is planned to come fully into force on 30 April 2028.

The Energy Performance of Buildings (Scotland) Regulations 2025 were approved in December 2025 and were originally due to start on 31 October 2026. The start was delayed because the UK Government's new calculation methodology was not ready. Draft amending regulations laid on 24 August 2026 move the start date to 30 April 2028. They are subject to parliamentary approval and make no other change to the substance of the reforms.

What will a new non-domestic EPC include?

A new style non-domestic EPC will:

  • show an Energy Performance Rating, an Energy Use Rating and a Direct Emissions Rating
  • come with a Property Report, which replaces the current recommendations report
  • be valid for five years instead of ten
  • be subject to strengthened quality assurance, including onsite audits

How does the transition period work?

From 30 April 2028, assessors can only issue new style EPCs. A valid old style EPC can still be used for a sale or let until 30 April 2029. If the building is sold or let again within that year, the second transaction needs a new style EPC. After 30 April 2029, only new style EPCs can be used.

Two groups of buildings follow different rules:

  • Large public buildings: large non-domestic buildings frequently visited by the public can keep displaying their current EPC until it expires or until 30 April 2033, whichever is sooner.
  • New buildings: buildings completed on or after 30 April 2028 need a new style EPC and Property Report. The developer must give these to the owner within seven days of submitting the completion certificate.

What are the current EPC requirements for commercial buildings?

An EPC is required when a new building is completed. It is also required whenever a building is sold or let to a new tenant.

The EPC rating must appear in all commercial sale and letting advertisements and be given to anyone who enquires. Buildings over 250 m² that are occupied by a public authority and frequently visited by the public must also display an EPC.

Current EPCs are valid for up to ten years. Local authorities can issue penalty charge notices for non-compliance, with a minimum penalty of £1,000 for non-domestic buildings.

Which buildings are exempt?

The following buildings do not need an EPC:

  • stand alone buildings (other than dwellings) under 50 m²
  • temporary buildings with a planned use of two years or less
  • buildings with low energy demand
  • buildings sold for demolition

Places of worship and historic buildings have no general exemption in Scotland.

What is Section 63?

Section 63 is Scotland's way of improving older commercial buildings. Unlike England and Wales, Scotland has no minimum EPC rating for letting a commercial building.

It applies when you sell or let a non-domestic building over 1,000 m² that does not meet 2002 energy standards. Before the sale or let, you need an Action Plan from a registered Section 63 adviser. The plan sets out cost effective improvements, such as better lighting or upgraded heating controls.

You then have two choices:

  • Carry out the improvements within 42 months.
  • Defer them by measuring the building's actual energy use and displaying a Display Energy Certificate, renewed every year.

Lease renewals with the same tenant are excluded, as are qualifying short leases and qualifying Green Deal properties.

Section 63 sits in separate regulations from 2016, which the EPC reforms do not revoke. It is expected to continue after 30 April 2028. The Scottish Government has not yet confirmed how Action Plans will work alongside new style EPCs.

What should commercial property owners do now?

  • Confirm that EPCs are valid before marketing a building.
  • Include the EPC rating in every sale and letting advertisement.
  • Check whether Section 63 applies to buildings over 1,000 m².
  • Compare EPC expiry dates against planned transactions and the 2028 to 2029 transition window.
  • Keep drawings, specifications and evidence of installed building services for future assessments.

Key dates

DateWhat happens
Now to 29 April 2028Current EPC and Section 63 requirements continue
30 April 2028Reformed EPC system comes into force, subject to parliamentary approval
30 April 2029Old style EPCs can no longer be used for sales or lettings
30 April 2033Backstop for large public buildings to display a new style EPC

Frequently asked questions

Do I need to replace my commercial EPC before April 2028?

No. A valid EPC issued under the current rules can still be used. After 30 April 2028, it can be used for one sale or let until 30 April 2029 at the latest.

How long will a new style EPC be valid?

Five years, compared with ten years for current certificates.

What is the penalty for not having an EPC in Scotland?

Local authorities can issue a penalty charge notice. The minimum penalty is £1,000 for non-domestic buildings.

Do listed buildings need an EPC in Scotland?

Yes, unless they fall within one of the standard exemptions. Historic buildings have no general exemption in Scotland.

Will Scotland introduce a minimum EPC rating for commercial property?

Not at present. Scotland has no minimum EPC rating for commercial lettings, unlike the MEES regime in England and Wales. The Scottish Government has proposed powers to set future standards for non-domestic buildings but has not set any rating level. Any future standard is expected to use the new style EPC ratings.

Will Section 63 still apply after the EPC reforms?

Yes. The 2025 Regulations do not revoke the 2016 Section 63 Regulations, so the duty to obtain an Action Plan on sale or letting is expected to continue. The Scottish Government has not yet confirmed how Action Plans will link to new style EPCs.

 




Paul Miller

Written by

Paul Miller

Director

CEng, MEI, LCEA, PGDip, BEng (Hons)

Paul leads sustainability and energy performance at KJ Tait, supporting developers, landlords, design teams and estates managers across the UK.

View Paul Miller’s profile