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Energy Performance of Buildings (Scotland) Regulations 2025

Overview

The Energy Performance of Buildings (Scotland) Regulations 2025 modernise Scotland’s Energy Performance Certificate (EPC) system.
They were laid before the Scottish Parliament on 10 October 2025 and will come into force on 31 October 2026.

These new regulations:

  • Replace the Energy Performance of Buildings (Scotland) Regulations 2008
  • Introduce a new EPC format using the UK Home Energy Model (HEM)
  • Support Scotland’s transition to net zero under the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019
Are Self-Catering and Short-Term Let Properties Included?

Yes.
Self-catering and short-term let properties are explicitly included in the new EPC framework.

“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… Short term let properties will therefore have a full one-year grace period in which to obtain a new-style EPC… 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.”¹

What This Means for You
  • All self-catering and short-term let properties must hold a valid EPC (no change).
  • From 31 October 2027, only the new-style EPC will be accepted.
  • You will have one year (Oct 2026–Oct 2027) to update your EPC to the new format.
Minimum Energy Efficiency Standards

No new minimum standards have been introduced yet.

The 2025 Regulations are administrative, not regulatory. They:

  • Do not set minimum EPC bands (e.g. EPC C or above).
  • Do reduce the validity period of EPCs from 10 years to 5 years.

“The changes being made through the revised regulations are administrative in nature. They will not change the circumstances in which an EPC is currently required, when a property is advertised for sale or let, other than reducing the EPC validity period.”²

However, EPC reforms will underpin future mandatory minimum standards, expected to be introduced through:

  • The forthcoming Heat in Buildings Bill; and/or
  • The Private Rented Sector Minimum Energy Efficiency Standards (MEES) framework.

“EPCs could be used as a basis for setting minimum energy efficiency standards and providing evidence on how a building would meet such standards.”³

Key Timelines
Date Requirement / Event
10 Oct 2025 Regulations laid before Scottish Parliament
31 Oct 2026 Regulations come into force
31 Oct 2027 New EPC format mandatory for all short-term lets
Ongoing EPCs required when a property is advertised for sale or let
Every 5 years EPC renewal now required (previously every 10 years)

What ASSC Members Should Do
  • Check your EPC – ensure it is valid and will remain current until at least October 2027.
  • Plan ahead – arrange for an updated EPC assessment between 2026 and 2027.
  • Keep documentation – you will need a valid EPC to advertise or operate.
  • Stay informed – ASSC will provide updates on future minimum standard proposals.
  • Engage with consultations – ASSC will continue to represent members on proportional and fair application of future energy regulations.
Key Legislative References
  • Energy Performance of Buildings (Scotland) Regulations 2025 (SSI 2025/XXX)
  • Energy Performance of Buildings (Scotland) Regulations 2008 (SSI 2008/309)
  • Climate Change (Emissions Reduction Targets) (Scotland) Act 2019
  • EU Energy Performance of Buildings Directive (Recast) (EU 2024/1275)
Official Scottish Government Sources
  1. Scottish Government (2025). Update to the Energy Performance Certificate Reform Consultation: Government Response, October 2025, p. 5.
  2. Scottish Government (2025). Energy Performance of Buildings (Scotland) Regulations 2025: Fairer Scotland Duty Assessment (FSDA), October 2025, p. 4.
  3. Scottish Government (2025). Energy Performance of Buildings (Scotland) Regulations 2025: Business and Regulatory Impact Assessment (BRIA), October 2025, p. 17.
Summary for Members
Issue Position (2025–2027)
Inclusion of self-catering properties Explicitly included
EPC requirement Mandatory
EPC validity period Reduced to 5 years
Minimum EPC standard None yet introduced
Transition deadline 31 October 2027

 

Author of guidance: ASSC

Date of guidance: October 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.

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