Commercial EPC Requirements in Scotland: What Changes in 2028

Key points

• The current EPC rules under the 2008 Regulations continue to apply until 30 April 2028.
• The Scottish Government plans to bring the reformed EPC system into force on 30 April 2028, subject to parliamentary approval.
• New non-domestic EPCs will carry an Energy Performance Rating, an Energy Use Rating and a Direct Emissions Rating, and will be valid for five years.
• Old style EPCs can be used for sales and lettings until 30 April 2029 at the latest.
• Section 63 applies now when buildings over 1,000 m² are sold or let, and the reforms do not revoke it.

Watch: Scotland's EPC changes explained

In this video, KJ Tait explains the revised timetable for EPC reform in Scotland and what it means for commercial property owners. A written summary of the video is set out below.

When do the new EPC rules start in Scotland?

The reformed EPC system is planned to come fully into force on 30 April 2028.

The Energy Performance of Buildings (Scotland) Regulations 2025 were approved in December 2025 and were originally due to start on 31 October 2026. The start was delayed because the UK Government's new calculation methodology was not ready. Draft amending regulations laid on 24 August 2026 move the start date to 30 April 2028. They are subject to parliamentary approval and make no other change to the substance of the reforms.

What will a new non-domestic EPC include?

A new style non-domestic EPC will:

• show an Energy Performance Rating, an Energy Use Rating and a Direct Emissions Rating
• come with a Property Report, which replaces the current recommendations report
• be valid for five years instead of ten
• be subject to strengthened quality assurance, including onsite audits

How does the transition period work?

From 30 April 2028, assessors can only issue new style EPCs. A valid old style EPC can still be used for a sale or let until 30 April 2029. If the building is sold or let again within that year, the second transaction needs a new style EPC. After 30 April 2029, only new style EPCs can be used.

Two groups of buildings follow different rules:

• Large public buildings: large non-domestic buildings frequently visited by the public can keep displaying their current EPC until it expires or until 30 April 2033, whichever is sooner.
• New buildings: buildings completed on or after 30 April 2028 need a new style EPC and Property Report. The developer must give these to the owner within seven days of submitting the completion certificate.

What are the current EPC requirements for commercial buildings?

An EPC is required when a new building is completed. It is also required whenever a building is sold or let to a new tenant.

The EPC rating must appear in all commercial sale and letting advertisements and be given to anyone who enquires. Buildings over 250 m² that are occupied by a public authority and frequently visited by the public must also display an EPC.

Current EPCs are valid for up to ten years. Local authorities can issue penalty charge notices for non-compliance, with a minimum penalty of £1,000 for non-domestic buildings.

Which buildings are exempt?

The following buildings do not need an EPC:

• stand alone buildings (other than dwellings) under 50 m²
• temporary buildings with a planned use of two years or less
• buildings with low energy demand
• buildings sold for demolition

Places of worship and historic buildings have no general exemption in Scotland.

What is Section 63?

Section 63 is Scotland's way of improving older commercial buildings. Unlike England and Wales, Scotland has no minimum EPC rating for letting a commercial building.

It applies when you sell or let a non-domestic building over 1,000 m² that does not meet 2002 energy standards. Before the sale or let, you need an Action Plan from a registered Section 63 adviser. The plan sets out cost effective improvements, such as better lighting or upgraded heating controls.

You then have two choices:

• Carry out the improvements within 42 months.
• Defer them by measuring the building's actual energy use and displaying a Display Energy Certificate, renewed every year.

Lease renewals with the same tenant are excluded, as are qualifying short leases and qualifying Green Deal properties.

Section 63 sits in separate regulations from 2016, which the EPC reforms do not revoke. It is expected to continue after 30 April 2028. The Scottish Government has not yet confirmed how Action Plans will work alongside new style EPCs.

What should commercial property owners do now?

• Confirm that EPCs are valid before marketing a building.
• Include the EPC rating in every sale and letting advertisement.
• Check whether Section 63 applies to buildings over 1,000 m².
• Compare EPC expiry dates against planned transactions and the 2028 to 2029 transition window.
• Keep drawings, specifications and evidence of installed building services for future assessments.

Key dates

Date	What happens
Now to 29 April 2028	Current EPC and Section 63 requirements continue
30 April 2028	Reformed EPC system comes into force, subject to parliamentary approval
30 April 2029	Old style EPCs can no longer be used for sales or lettings
30 April 2033	Backstop for large public buildings to display a new style EPC

Frequently asked questions