Organisations across Scotland have been given significantly more time to prepare for upcoming changes to Energy Performance Certificates (EPCs), after the Scottish Government confirmed that its planned EPC reforms will now be delayed until April 2028. The update affects both domestic certificates and the commercial energy performance certificate framework.
The announcement marks a major shift from the original implementation date of October 2026 and provides greater certainty for property owners, landlords, occupiers and energy professionals. It also gives organisations more time to plan for future Commercial EPC requirements and understand how an EPC certificate for a commercial property may be assessed under the new approach.
The Scottish Government has confirmed that most of the current EPC framework will remain in place until 30 April 2028, when the outstanding provisions of the Energy Performance of Buildings (Scotland) Regulations 2025 are expected to come into force. The revised timeline applies to domestic EPCs and non-domestic EPCs.
Why Has the Reform Been Delayed?
According to the government, the decision follows extensive engagement with the UK Government and the EPC assessor industry. The reforms rely on the development of the UK Home Energy Model, supporting infrastructure and industry-wide training, all of which require additional time before the new system can be successfully implemented.
What Will the New EPCs Look Like?
When introduced, the reformed EPC framework is expected to feature:
- New certificate designs and rating systems
- A Heat Retention Rating (HRR) showing how effectively a building retains heat
- Reduced certificate validity periods of five years, compared with the current ten-year validity
- New methodologies for assessing building performance.
What Does This Mean for Organisations?
For now, businesses and public sector organisations operating in Scotland can continue to work within the existing EPC regime. The extended timeline provides additional breathing space for organisations planning future compliance activity, property upgrades and wider decarbonisation projects, including those responsible for maintaining a valid Commercial EPC certificate across their estates.
However, while implementation has been delayed, the direction of travel remains unchanged. Improving the energy performance of buildings continues to be a key part of Scotland’s long-term net zero ambitions, meaning organisations may benefit from using the additional time to review their estates, identify energy-saving opportunities and prepare for the transition ahead.
Is your organisation based in Scotland? Find out your building’s current EPC rating using the Scottish EPC register.