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18/12/2025

Major Win for Self-Catering as Scottish Government Confirms Pragmatic EPC Transition

The Association of Scotland’s Self-Caterers (ASSC) has today welcomed confirmation from the Scottish Government of a pragmatic and proportionate transition period for new Energy Performance Certificate (EPC) requirements under the Energy Performance of Buildings (Scotland) Regulations 2025, providing important clarity and reassurance for Scotland’s self-catering sector. 

In its updated response, the Government recognises the practical realities facing short-term let operators, particularly the fact that self-catering properties are typically marketed continuously. As a result, a one-year grace period has been built into the regulations to allow businesses time to transition without unnecessary disruption. 

Under the confirmed arrangements: 

  • Between 31 October 2026 and 31 October 2027, self-catering properties may continue to use either a valid EPC issued under the 2008 Regulations or a new-style EPC issued under the 2025 Regulations. 
  • From 31 October 2027 onwards, only the new-style EPC and accompanying property report issued under the 2025 Regulations will be accepted for the letting of a property as a short-term let. 

The Scottish Government has stated that this approach is designed to support a smoother and more evenly spaced transition for approximately 30,000 short-term lets across Scotland, helping to minimise market disruption . 

The updated EPC framework also represents a shift in how energy performance is measured. While current EPCs focus on cost-based energy efficiency and environmental impact, the new certificates will introduce three updated ratings: 

  • A Heat Retention Rating, reflecting fabric efficiency and insulation. 
  • A Heating System Rating, covering system type, efficiency and emissions. 
  • An updated Energy Cost Rating. 

Importantly, the Government has also reiterated that short-term holiday lets were proposed to be excluded from minimum energy efficiency standards consulted on earlier this year for the Private Rented Sector. This reflects recognition that guests do not pay energy bills directly and therefore do not experience fuel poverty in the same way as private tenants. Any future consideration of minimum standards for short-term lets would be subject to full consultation. 

Commenting on the announcement, Fiona Campbell MBE, Chief Executive of the Association of Scotland’s Self-Caterers, said: 

“We welcome this pragmatic and proportionate approach from the Scottish Government. Our representations on the operational realities of self-catering businesses have clearly been listened to, and the one-year grace period provides essential breathing space for operators to plan and adapt. 

Our latest ASSC Barometer Survey shows that 62.24 per cent of self-catering properties, from a sample of 444, currently have an EPC rating of D or below. Many of these are older, historic or heritage properties. Any blanket requirement to achieve a C rating or above would, in many cases, be economically unviable and would almost certainly result in property closures. That would be damaging not only for businesses, but for local economies and rural tourism. 

We fully support realistic, evidence-based approaches to improving energy efficiency, but regulation must reflect the diversity of Scotland’s building stock and avoid unintended consequences.” 

ASSC will continue to engage constructively with the Scottish Government as EPC reform develops, advocating for policies that support climate ambitions while safeguarding the viability of Scotland’s vital self-catering sector. 

 

Please view guidance below on  New Energy Performance Certificate Requirements

 

 

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