KJ Tait

Scotland Energy Performance Certificate (EPC) Reform Consultation

29 August 2023

Since EPCs were first introduced in 2008, Scotland has adopted a different approach to England and Wales.  Rather than comparing the building being assessed with a ‘Reference Building’, Scotland simply produce a rating based on the buildings kgCO2/m2/yr.  Where this is probably more representative of a building’s actual emissions, it’s indiscriminate between building types and causes EPCs in Scotland to sometimes appear dramatically poorer than an England and Wales equivalent assessment.


Since the methodology was updated in 2022 however (reducing the carbon emission factor for electricity), all-electric buildings in Scotland suddenly achieve exceptionally good EPC’s since the rating scale remains unchanged.  This is despite very poor u-values for example in some cases.

The Scottish Government have now accepted this and have published an EPC reform consultation.  Broadly, this would aim to bring the EPC rating scheme inline with the England and Wales system.  Other changes may include metrics allowing fabric performance to be highlighted and changing the validity period from 10, down to 5 years.


Here at KJ Tait, we agree there is an urgent need for non domestic EPCs to be reformed.  We would advise that moving to the Reference Building system is implemented as fast as possible with the ideal scenario being that Scotland takes the Part L methodology to ensure consistency across borders.  We also have concerns on EPCs being in place from three different sets of regulations (Section 6 2015, Section 6 2022 and the new Reference Building style).  We would urge that all EPCs are required to be reassessed under the new methodology to provide confidence in the EPC regime with the ideal goal being to mimic the MEES regulations in England and bring in a minimum standard of EPC ‘B’ by 2030.


We would urge all our clients to provide their views via the consultation link: