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30/04/2025

EPC Consultation: Key Points for Your Response

The UK Government is consulting on proposals to improve the energy performance of privately rented homes. These changes may unintentionally impact short-term let (STL) and self-catering businesses. If this happens south of the Border, it may well come to Scotland.

Your voice matters — please consider submitting a personal response.

Use the full ASSC briefing as a reference, and feel free to copy the points below into your submission:

  • Self-catering is not private renting – We operate under licences to occupy, not tenancy agreements. These are commercial tourism businesses, not homes.
  • Tourism properties don’t fit residential EPC rules – Seasonal use, guest turnover, and business-paid utilities make residential EPC standards unsuitable.
  • Cost burden is unmanageable – EPC upgrades could cost £20,000–£50,000, more than three years of average profit. 30% may exit if forced to upgrade.
  • Cumulative regulation is unsustainable – With STL licensing, NDR reform, planning zones, and tax changes, this is one pressure too many.
  • Climate action must be sector-specific – We support energy efficiency, but not at the cost of livelihoods, tourism, or rural communities.

Please urge the UK Government to exempt STL businesses from PRS EPC rules and work with ASSC on proportionate climate solutions.

You can view the ASSC’s consultation response below.

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