The New Energy Performance of Buildings (Scotland) Regulations 2025: What You Need to Know

The Scottish Government has laid the Energy Performance of Buildings (Scotland) Regulations 2025 before Parliament, marking a significant step in the country’s journey toward net zero and the most significant overhaul of building energy standards in over a decade. Coming into force on 31 October 2026, these regulations replace the 2008 regime and aim to modernise how Energy Performance Certificates (EPCs), are issued, used, and enforced across Scotland’s commercial property sector. Here’s what you need to know.

Why the Change?

EPCs have long been a fixture in the property market, required when buildings are sold, let, or newly constructed. However, concerns around their relevance, accuracy, and alignment with climate goals prompted the Scottish Government to undertake a multi-year reform process. The new regulations aim to enhance the accuracy, transparency and comparability of building energy data while driving improvement in existing stock.

Key Changes

1. New Rating System

The traditional ratings will be replaced to include a Heat Retention Rating (HRR) that measures how well a building retains heat, offering a clearer picture of insulation and energy efficiency and a Heating System Rating that evaluates the environmental impact of heating systems, helping users make informed choices.

2. Shorter Validity Period

EPCs will now be valid for five years instead of ten, ensuring that energy performance data remains current and relevant. Transitional provisions will allow existing EPCs to be used only until 31 October 2027 in most cases.

3. Enhanced Quality Assurance

EPC assessors will be subject to stricter oversight, including new audit and inspection requirements, to ensure consistency and reliability.

4. Improved Accessibility

The new EPC and accompanying Property Report will be designed with user testing to ensure they are accessible and easy to understand.

Implications

The reforms bring both challenges and opportunities:

• Compliance Planning: With the new regulations taking effect in late 2026, now is the time to assess your portfolio and plan for compliance.
• Investment Decisions: The updated ratings may influence asset valuations and tenant preferences, particularly as sustainability becomes a key driver in commercial leasing.
• Operational Adjustments: Approved Organisations and EPC assessors will need to adapt to new accreditation schemes and methodologies.

Looking Ahead

MBM Commercial will continue to monitor developments and provide updates to help our clients navigate the transition smoothly.

If you have questions about how these changes may affect your property interests, or if you’d like tailored advice on any commercial property matters, please don’t hesitate to get in touch with our Commercial Property team.