Scottish EPC Reform Delayed Until 2028: What Does This Mean for Commercial Property?

Businesses and property owners who have been preparing for Scotland's new Energy Performance Certificate (EPC) regime now have additional time to prepare.

The Scottish Government has announced that implementation of the reformed EPC framework, originally expected to come into force in October 2026, has been postponed and is now expected to take effect on 30 April 2028.

The postponement comes at a time when a number of building energy policy initiatives have experienced revised timetables. In relation to EPC reform, the additional time is intended to allow for the development and implementation of the new UK-wide EPC framework and supporting infrastructure. Whilst the implementation timetable has changed, the underlying policy objectives have not. The Scottish Government maintains that it remains committed to improving the energy performance of buildings and decarbonising heat across Scotland's building stock. The delay therefore appears to reflect practical implementation considerations rather than any change in policy direction.

For commercial property owners, investors, landlords and occupiers, the delay provides additional time to consider the likely impact of future energy efficiency requirements on acquisitions, disposals, leasing strategies, refurbishment programmes and asset management decisions.

Energy performance remains an increasingly important consideration in commercial property transactions, with purchasers, investors, lenders and occupiers placing greater emphasis on sustainability credentials, operational efficiency and the potential capital expenditure required to improve building performance. As a result, energy efficiency issues continue to form a significant part of property due diligence and investment analysis.

While implementation of EPC reform has been delayed, commercial property stakeholders should not assume that the agenda has disappeared. If anything, the recent announcements suggest that the pace of change may have slowed, but the direction of travel remains the same.

For a more detailed overview of the proposed EPC reforms and what they may mean for commercial property owners, please see our earlier article on Scottish EPC reform: The New Energy Performance of Buildings (Scotland) Regulations 2025: What You Need to Know. If you would like advice on how the proposed EPC reforms or wider sustainability requirements could affect your property portfolio, development project, acquisition, disposal or leasing transaction, please contact MBM's Commercial Property team.