EPC Changes in Scotland: Simple Facts
Big changes are coming for commercial EPCs in Scotland. Starting 31 October 2026, new EPC rules take effect. All old certificates will ultimately be replaced. However, there is a one‑year transition period for properties being actively marketed.
For owners, this matters. The changes protect asset value over time and help prepare your buildings for net zero pathways.
Why Are the EPC Changes Happening?
The current EPC system in Scotland has limitations. The new approach introduces a reference‑building comparison for non‑domestic EPCs to improve fairness and transparency, and to support decarbonisation planning across portfolios.
From October 2026, EPCs issued under the old 2008 rules will be superseded by the new format at the standard trigger points. Every commercial property will eventually need a new EPC under the revised method.
Important Deadlines and Exemptions
- Start date. The new rules begin on 31 October 2026
- One‑year transition. For sales or new lettings up to 31 October 2027, a valid legacy EPC may be used only where the building or unit was already advertised for sale or to let on 31 October 2026 when the new rules began
- Final position. After 31 October 2027, transactions must use the new‑style EPCs issued under the 2025 Regulations
- Display duty. Large public‑access buildings have a longer period to switch displayed certificates, subject to the display rules
- Validity. Non‑domestic EPC validity reduces from 10 years to 5 years
Transition timeline at a glance
31 Oct 2026
New EPC rules begin
Grace period
Legacy EPCs allowed only if on market on 31 Oct 2026
31 Oct 2027
New‑style EPCs required for all transactions
What Are the Changes on the EPC?
- Energy Performance Rating (A–G). The primary comparator using a standard reference building
- Energy Use indicator. Shows modelled regulated energy under set conditions
- Direct Emissions indicator. Shows modelled regulated carbon emissions to inform decarbonisation plans
These changes bring Scottish EPCs into closer alignment with England and Wales. Owners with UK‑wide portfolios will find cross‑border comparisons easier.
What You Should Do
Many owners ask: “Will my rating change? What steps should I take? What is the cost?” The best lever for long‑term ratings resilience is heat decarbonisation, supported by efficient HVAC and controls. Moving away from fossil‑fuel heat may include heat pumps, distribution upgrades and control optimisation. A feasibility study covering cost, planning, programme and electrical capacity is essential before committing.
Avoid Mistakes
Simple advice like “install VRF to get a B” is not enough. Achieving the right outcome requires a whole‑building plan, correct inputs and a clear improvement pathway. At KJ Tait, we provide a costed, sequenced upgrade plan based on the new EPC method and your operational constraints.
How KJ Tait Can Help
We are expert engineers with CIBSE‑accredited Level 5 energy assessors across Scotland and England. We combine compliance knowledge with practical delivery. We help you:
- Assess your building under the new reference‑building method
- Identify the best upgrade measures for fabric, HVAC and controls
- Create a costed, time‑bound plan to protect asset value
- Meet your ESG and net zero goals with evidence‑ready outputs
Your Next Steps
- Check your current EPC and expiry
- Plan for reassessment under the new rules where transactions are expected
- Begin heat decarbonisation planning now and test capacity early
The EPC changes in Scotland are a chance to act. Use them to future‑proof your assets.
Need expert help? Contact KJ Tait to discuss how the changes affect your properties and timelines.
What Are the Government Next Steps?
The Scottish Government will continue engagement through 2026 to support a smooth transition. Owners and asset managers should review EPC status, plan for reassessment and align investment programmes with the new reporting outputs.
