

The Scottish Government has launched a consultation on its plans to introduce a minimum EPC level for rented homes.
This would see all properties rented privately to tenants required to meet a band C level EPC by January 4th, 2028, for new tenancies, and by 2033 for existing ones. Justifying this, the official statement says that among Scotland’s 300,000 rented homes, 48% are under a band C and 14% have the lowest E/F/G bands.
It also says 44% of private tenants in Scotland live in fuel poverty, which is when a household spends 10% or more of its income on maintaining a warm home.
The consultation document adds: “Energy efficiency improvements would benefit tenants by enabling them to use less energy to reach the same thermal comfort in their homes, possibly resulting in lower bills and a reduction in overall fuel poverty rates.
“However, typically, when a property is rented, the tenant is not able to make those upgrades themselves. Upgrades are usually the responsibility of the landlord. This means that the landlord would be required to improve the property for the tenant to benefit.
“Evidence shows the lowest rates of fuel poverty are associated with higher energy efficiency standards. 32% of households living in dwellings currently rated EPC band C or better were fuel poor, compared to 48% living in dwellings in bands F or G.”
For landlords, there will be two key exemptions including a cost cap of £10,000.
The other is that landlords will not be required to install anything which is technically unsuitable for the type of property they own or for which they cannot attain the required consent from tenants, neighbours or planning authorities.
As in England and Wales, the Scots’ system of EPCs is controlled via the MEES standard and this is being overhauled and the current ‘headline’ system replaced with three metrics – heat retention (which will be the key one) plus energy cost and quality of heating system.
The consultation, which ends in late August, will be followed by the necessary regulations going through the Scottish parliament next year in readiness for the 2028 first implementation.
"I invite anyone with an interest in these proposals – tenants, landlords, suppliers and others – to respond to this consultation," says Acting Climate Change Minister Dr Alasdair Allan (main image).
"We welcome your views, to help us understand the practical implications, so we can reflect those as we finalise our proposals to help ensure these regulations to work as effectively as possible."
But patience over the preparations for the 2028 introduction is wearing thin. The Scottish Association of Landlords has pointed out somewhat resignedly that “this is the seventh consultation in just over eight years relating to energy efficiency in the PRS in Scotland”.
Funding for landlords in Scotland to upgrade their properties includes access to low or zero-interest loans of up to £38,000 per property or £100,000 for those who own up to five properties.
Rented homes with an EPC of band E,F or G can access grant funding for certain upgrades such as wall and loft insulation and heating systems via the ECO4 grant system, particularly if their tenants are in receipt of benefits.
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