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17/12/25 3:30 pm
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Scotland's approach to minimum energy efficiency standards for rental properties has taken several turns over recent years. While England has established minimum EPC requirements, Scotland currently operates without such rules—but this is set to change by the end of 2028.
The Scottish Government initially planned to introduce minimum EPC requirements much sooner. The original proposal would have required private rented sector (PRS) properties to achieve an EPC rating of C at change of tenancy from 2025, with all properties reaching this standard by 2028.
However, at the time these plans were announced in late 2023, the Scottish Government reversed course and dropped these earlier deadlines. This decision came as part of broader policy reconsiderations around the timing and implementation of energy efficiency standards.
Unlike England, Scotland currently has no minimum energy performance certificate requirement for PRS properties. Properties need an EPC to be rented or sold, but there's no minimum rating threshold that must be met.
As part of draft legislation to create a new Heat in Buildings Standard, Scotland has established a revised timeline:
This represents a significant shift from the original change-of-tenancy approach to a blanket deadline for all rental properties.
In a consultation document - Delivering Net Zero for Scotland's Buildings - it explains it wants to see tenants having warmer homes that are easier and less expensive to heat as part of its obligation to address fuel poverty.
"We believe that establishing this standard in this way protects and is very much in the interests of tenants, while also enhancing the quality of the asset for the landlord. We are aware of the important role privately rented homes play as part of Scotland's housing stock, and the wider pressures on this sector," the document says.
The 2028 deadline affects Scotland's estimated 300,000 privately rented homes. Research suggests that 48% of these properties currently fall below EPC band C, with 14% in the lowest E/F/G bands.
The policy aims to tackle fuel poverty, which affects 44% of private tenants in Scotland who spend 10% or more of their income maintaining a warm home. Properties with higher energy efficiency ratings show lower fuel poverty rates—32% for EPC band C or better compared to 48% for bands F or G.
For landlords, this creates both challenges and opportunities. While upgrades require investment, improved energy efficiency can enhance property values and potentially justify higher rents through reduced tenant energy costs.
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Scotland's approach reflects broader UK trends toward improved energy efficiency, though timelines and enforcement mechanisms vary. The Scottish Government has conducted multiple consultations on energy efficiency in the PRS over recent years, indicating the complexity of balancing environmental goals with practical implementation.
The Heat in Buildings Bill will include powers for monitoring and enforcement, with proposed civil penalties for non-compliant private landlords after 2028. However, the Scottish Government has indicated that penalties won't play a key role during initial implementation stages.
Does Scotland currently have minimum EPC requirements for rental properties?
No, Scotland currently has no minimum EPC rating requirement for private rented properties. Properties must have an EPC to be rented, but there's no minimum standard that must be met, unlike England's minimum E rating.
When do Scottish landlords need to meet EPC band C?
All private landlords in Scotland must meet an EPC C rating by the end of 2028 under the proposed Heat in Buildings Standard. This applies to all rental properties, not just new tenancies.
What funding is available for energy efficiency improvements in Scotland?
Scottish landlords can access low or zero-interest loans up to £38,000 per property through Home Energy Scotland. Properties rated E, F, or G may qualify for ECO4 grant funding, particularly where tenants receive benefits.
Will there be exemptions from the EPC C requirement?
The Scottish Government proposes exemptions for properties where improvements aren't technically suitable or where required consents cannot be obtained. A cost cap may also apply, though exact details remain to be confirmed.
How will the EPC C requirement be enforced in Scotland?
Private landlords face proposed civil penalties for non-compliance after 2028. However, enforcement mechanisms are still being developed, with the Scottish Government indicating penalties won't be prominent during initial implementation.
What's the difference between Scotland's approach and England's EPC rules?
England currently requires rental properties to meet minimum EPC E rating, with plans for EPC C by 2030. Scotland has no current minimum but plans to jump directly to EPC C by 2028 for all rental properties.
Can Scottish landlords still rent properties below EPC C before 2028?
Yes, there are currently no restrictions on renting properties below EPC C in Scotland. The requirement only takes effect at the end of 2028.
What happens if a property cannot physically achieve EPC C?
The Heat in Buildings Bill will include provisions for modified standards or exemptions where properties cannot technically achieve EPC C due to building characteristics or where required consents cannot be obtained.
How much will EPC improvements cost Scottish landlords?
Costs vary significantly by property type and current rating. The Scottish Government has discussed cost caps, potentially around £10,000, beyond which exemptions may apply.
Will Scotland's EPC requirements affect mortgage lending?
While not yet confirmed, UK-wide trends suggest lenders increasingly consider energy efficiency in lending decisions. Properties below EPC C may face lending restrictions as the 2028 deadline approaches.
ent has backtracked on plans to force the private rented sector to meet energy efficiency deadlines by 2025.
These would have required PRS properties to achieve an EPC rating of C at the change of tenancy from 2025, with all properties having to reach the same standard by 2028 – but this proposal has been dropped.
Scottish ministers have been planning the introduction of a minimum energy efficiency standard for more than a decade but dates have changed several times. Unlike England, there is currently no minimum energy performance certificate (EPC) requirement for PRS properties.
However, as part of a draft bill containing the powers to create a new Heat in Buildings Standard, it has announced that all private landlords will need to meet a C rating by the end of 2028, while owner occupiers will need to meet the same standard by the end of 2033. By the end of 2045, all building owners will need to have ended their use of polluting heating.
Landlords in England now have no such target following the UK government’s recent U-turn on EPC targets.
In a consultation document - Delivering Net Zero for Scotland’s Buildings - it explains it wants to see tenants having warmer homes that are easier and less expensive to heat as part of its obligation to address fuel poverty.
“We believe that establishing this standard in this way protects and is very much in the interests of tenants, while also enhancing the quality of the asset for the landlord. We are aware of the important role privately rented homes play as part of Scotland’s housing stock, and the wider pressures on this sector," the document says.
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