EPC Changes in Scotland: New Method for Commercial Buildings

EPC Changes in Scotland: What Commercial Property Owners Need to Know

The Scottish Government has confirmed the new Energy Performance of Buildings (Scotland) Regulations 2025, which will come into force on 31 October 2026.  These regulations represent a significant shift for non-domestic property owners, with the EPC changes in Scotland requiring that all existing EPCs issued under previous Regulations ceasing to be valid after a transitional period.  The new framework aims to deliver more meaningful, performance-based energy ratings and support Scotland’s decarbonisation objectives.

What is the new rating system in Scotland?

• Energy Performance Rating (A–G): Based on modelled emissions from regulated energy use, benchmarked against a reference building.
• Energy Use Rating: Reflects the building’s modelled regulated energy use under standardised conditions.
• Direct Emissions Rating: Shows the building’s direct emissions from regulated energy use, highlighting decarbonisation opportunities.

Alignment with EPCs across the UK

• The new approach aligns Scotland with the rest of the UK, allowing fairer, more consistent benchmarking across portfolios and regions.

What are the changes to the validity of EPCs in Scotland?

• EPCs will be valid for five years (previously ten), ensuring more up-to-date information for owners, occupiers and investors.

What are the transitional arrangements for EPCs in Scotland?

• From 31 October 2026, a one-year grace period allows existing EPCs (2008 Regulations) to be used for ongoing sales and lets.  After 31 October 2027, only EPCs issued under the 2025 Regulations will be valid
• Large non-domestic buildings frequently visited by the public have until the earlier of their current EPC expiry or 31 October 2031 to transition to the new-style EPC

Implications for Commercial Real Estate

The EPC Changes in Scotland will require all non-domestic property owners, landlords and asset managers to obtain new EPCs under the updated methodology.  It is an opportunity for business owners to:

• • Benchmark building performance more accurately
  • Identify and prioritise retrofit and decarbonisation measures
  • Align property portfolios with ESG and net zero targets

With the current EPC methodology not fit for purpose, the change to the EPC methodology will allow Scotland to catch up with England in decarbonising commercial real estate.

What are the Next Steps?

The Scottish Government will engage with stakeholders throughout 2026 to ensure a smooth transition. Owners and managers of non-domestic buildings should prepare for the new requirements, review their current EPC status, and plan for reassessment under the new regulations.

Download our Guide to the Changes

EPC Changes in Scotland: The Key Takeaways

• • From October 31, 2026, existing EPCs can be used for one year; after that, only 2025 Regulations EPCs will be valid.

• • EPCs will align across the UK using the same methodology, as confirmed by the Scottish Government.

• • New EPCs will have a validity of 5 years, reduced from the previous 10 years.

• • Buildings not already advertised for sale or rent will require new EPCs under the updated method from October 31 2026.

• • Successful implementation depends on defining reference buildings consistently, ensuring clarity, and integrating with digital platforms.

EPC Changes in Scotland: Q&A

What are the transitional arrangements for the changes to EPCs in Scotland?

From 31 October 2026, a one-year grace period allows existing EPCs (2008 Regulations) to be used for ongoing sales and lets.  After 31 October 2027, only EPCs issued under the 2025 Regulations will be valid

Large non-domestic buildings frequently visited by the public have until the earlier of their current EPC expiry or 31 October 2031 to transition to the new-style EPC

Will changes to Scotland EPCs mean alignement across the UK

Yes, the Scottish Government has confirmed that EPCs will be aligned across the UK with the same methodology used.

How long will the new EPCs in Scotland be valid for?

the validity will be reduced from 10 years to 5 years for the new EPCs.

Will all EPCs need to be recalculated once the changes are made in Scotland?

Yes, from 31st October next year those buildings that were not already advertised for sale or rent will need an EPC conducted under the new method.

How can KJ Tait help with the EPC changes?

At KJ Tait, we have CIBSE accredited Level 5 energy assessors in Scotland and England and are therefore experienced in the current and future methodology in Scotland.  Contact your local office for more details.