EPC changes in Scotland are coming, following the Scottish Government’s response to the EPC Reform Consultation. For commercial buildings, the most significant update is the planned introduction of a reference building methodology. This change brings EPC Scotland changes in line with the rest of the UK and fixes key issues in the current framework.
This isn’t just a technical update. It’s a strategic shift in how we design, assess, and manage commercial buildings. At KJ Tait, we see this as a move toward more transparent, performance-driven energy ratings. It also supports Scotland’s wider decarbonisation goals.
These changes are not yet law. The Scottish Government plans to legislate next year. Once passed, the new regulations will reshape how EPCs are issued and interpreted across Scotland.
The proposed framework will base the Energy Efficiency Rating (A to G) on modelled carbon emissions compared to a reference building. This benchmark uses the same geometry and use type, allowing fair comparisons.
This approach fixes a long-standing issue: lack of context. Absolute emissions don’t reflect performance accurately, especially for complex assets. The new method offers:
One major proposal is to reduce EPC validity from ten years to five. Once the new rules are in place, every building will need a new EPC under the updated methodology.
This isn’t just about compliance. It’s a chance to:
For landlords and asset managers, this means more frequent assessments, but also better alignment with ESG goals and continuous improvement.
For developers, landlords, and consultants, the new EPC framework is more intuitive and actionable. Design teams can model building options with meaningful feedback. Asset managers gain clearer insights across portfolios.
The reference building methodology improves decision-making. It reflects the impact of fabric upgrades, system improvements, and low-carbon technologies more accurately. This helps drive investment in retrofit and design optimisation.
Success depends on implementation. The reference building must be:
We also recommend aligning the reference building with Part L EPCs to avoid cross-border confusion. And we support stronger links to operational performance metrics, so EPCs reflect actual building use—not just design intent.
https://www.gov.scot/publications/epc-reform-consultation-government-response/