Energy Performance of Buildings (Scotland) Regulations 2025 — Government response and update.
EPC Changes in Scotland: Simple Facts
Big changes are coming for commercial EPCs in Scotland. The introduction of the new non domestic EPC regime is no longer expected to begin in late October 2026. A revised timetable is awaited.
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.
EPCs issued under the old 2008 rules will be superseded by the new format at the standard trigger points once the new regime commences. Every commercial property will eventually need a new EPC under the revised method.
Important Deadlines and Exemptions
- Start date. The introduction of the new non domestic EPC regime is no longer expected to begin in late October 2026. A revised commencement date is awaited
- Transition arrangements. Transitional arrangements are expected, but the dates will depend on the revised commencement date
- Display duty. Large public access buildings are expected to have specific arrangements for displayed certificates, subject to the display rules
- Validity. Non domestic EPC validity is expected to reduce from 10 years to 5 years under the new regime
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 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.
