Energy Performance Certificate Requirements Update Dec 2025 – FAQs

1.When the new EPC’s come into effect, do self-catering businesses have to get a new EPC, or is there existing one adequate until it expires?

The Scottish Government’s Updated Government Response explains the transition period set out in the Energy Performance of Buildings (Scotland) Regulations 2025. The provisions include specific protections for short term lets as set out below:

“We recognise that short term lets are normally continuously advertised and therefore on day one of the new Regulations, it would not be possible for all hosts to immediately obtain a new-style EPC issued under the 2025 Regulations. Short term let properties will therefore have a full one year grace period in which to obtain a new-style EPC. This means that:

•  between 31 October 2026 and 31 October 2027, short term let properties may continue to use either valid EPCs and recommendation reports issued under the 2008 Regulations or valid EPCs and property reports issued under the 2025 Regulations.
• after 31 October 2027, only the new-style EPC and property report issued under the 2025 Regulations will be allowed for the letting of a building as a short term let.

As outlined in the BRIA accompanying the Regulations, this grace period allows the sector to have a more evenly-spaced transition to the new-style EPC for Scotland’s approximately 30,000 short term lets, which should minimise any potential disruption to the market.”

2.What metrics will be used for the new EPCs and how do they compare with existing criteria?

The current certificate contains ratings for the:

• Energy Efficiency Ratings (based on the modelled cost to run the property)
• Environmental Impact Rating (based on the modelled emissions from the property)

The Updated Government Response sets out that the new domestic EPCs will contain the following ratings:

• Heat Retention Rating (reflecting fabric energy efficiency (how well insulated the building is)),
• Heating System Rating (covering type, emissions and efficiency),
• Energy Cost Rating (an updated version of the existing cost-based Energy Efficiency Rating).

The Updated Government Response ‘EPC Calculation Methodology and Rating System section’ sets out detail on the calculation of each of these ratings Energy Performance of Buildings (Scotland) Regulations 2025 – EPC reform consultations: SG response – update – gov.scot

3.Will self-catering properties, where they do not charge guests for energy, require to meet minimum standards?

The Scottish Government held a public consultation on minimum energy efficiency standards in the Private Rented Sector earlier this year. This proposed a MEES for the PRS of EPC HRR C, to apply to privately rented domestic properties required to meet the repairing standard, with some exceptions. One of these exceptions in the consultation was short-term holiday lets.

The consultation noted that the repairing standard does apply to short-term holiday lets, meaning they would ordinarily be included in our PRS MEES proposals and that our proposal in the consultation was to exclude these properties from our regulations. The Scottish Government recognised that the STHL sector does not have the same interaction with fuel poverty as properties in the PRS. This is because those staying in short-term holiday lets typically do not pay energy bills,  and therefore do not receive the same benefits of energy efficiency improvements as PRS tenants. It is the owner who would benefit from making the upgrades.

That said, the Scottish Government recognise the benefits of improving energy efficiency across all buildings in Scotland  and the role that can play in reducing emissions, particularly those caused by existing polluting heating systems. The draft HIB Bill published in November included powers for Scottish Minsters to set a Minimum Energy Performance Standard across wider sectors in future should the choose to (including non-domestic buildings). This means any future regulatory approach could consider the potential for standards to be applied to short-term holiday lets, and the Scottish Government would fully consult on any proposals to do so.

Author of Guidance: ASSC

Date of Guidance: December 2025

Version Number: V1

Disclaimer – Guidance Sheets are written by experienced Members of the ASSC and other experts. The information in the ‘Guidance Sheet’ is provided by the ASSC for use by Members in support of their own independent business decisions. It does not constitute advice or instruction for which the ASSC can be held liable in any way whatsoever. All Members and other readers remain responsible for the consequences of any decisions taken whether in the light of information gained from this Guidance Sheet or not.