ENERGY PERFORMANCE CERTIFICATES – MAJOR CHANGES DELAYED BEYOND OCTOBER 2026

Regulations reforming energy performance certificates (EPCs), which were due to come into force on 31 October 2026, will no longer commence as planned. The Scottish Government confirmed on 10 March 2026 that implementation will be delayed to the second half of 2027 in order to align with the UK Government’s updated plans. The delay follows many years of uncertainty and flip-flopping with other proposals. 

New split-rating system and five year validity

Under the new scheme (now delayed), the trigger points for an EPC will remain largely unchanged but the structure, content and governance of EPCs will be overhauled. EPCs will move away from a single headline rating. Domestic properties will receive Heat Retention, Heating System and Energy Cost ratings. Non-domestic properties will receive Energy Performance, Direct Emissions and Energy Use ratings.  

For both sectors, the validity of an EPC will reduce from ten years to five years. The existing recommendations report which accompanies an EPC will be replaced by a new “property report” identifying improvement options and alternative heating choices. 

The Scottish Government still intends to proceed with these reforms, but not in 2026. Implementation is now expected in the second half of 2027, although the precise commencement date has not yet been confirmed. 

Transitional provisions

When the new EPC scheme was expected to come into force, EPCs issued under the current scheme would have become invalid subject to the following transitional provisions: 

• The owner of a building sold or let during the first 12 months after commencement would have been able to use either a valid EPC issued under the current scheme or an EPC issued under the new scheme. This would have applied only to the first sale or let during that initial 12 month period. If the same property were sold or let again within that period, an EPC issued under the new scheme would have been required. After the initial 12 month period, only EPCs issued under the new scheme could be used.
• Short-term let operators would have been able to use either type of EPC throughout the initial 12 month period, after which only an EPC issued under the new scheme could be used.
• Public buildings with EPC display duties could have continued to use their existing EPC until the earlier of expiry and five years after commencement.  

These transitional provisions are now paused. However, it is expected that broadly similar arrangements will take effect once a revised commencement date for the new scheme is confirmed. 

Other

Under the delayed reforms, from 31 October 2026 a developer would have been required to provide the owner of the building with a copy of an EPC issued under the new scheme within seven days of submitting a completion certificate. This requirement is now postponed. 

A further proposal is the Heat and Energy Efficiency Technical Suitability Assessment (HEETSA) – a more detailed, optional assessment to help owners understand which improvements are technically suitable for their properties. The consultation closed in August 2025, and HEETSA was expected to be introduced by end of 2027. It is not yet clear whether the delay to EPC reform will affect this timing. 

Finally, the Scottish Government consulted last year on proposals requiring most privately rented residential properties to meet or exceed the new EPC Heat Retention Rating Band C, being one of the three split ratings for domestic properties under the new EPC scheme. Under the proposals, a landlord could not let a property unless they (1) have an EPC HRR Band C; or (2) have made “all relevant energy efficiency improvements” identified for that property (up to a £10K cap); or (3) qualify for an exemption. The intention was that the new standard would apply to new tenancies from 1 April 2028 and all tenancies from 1 April 2033. Although the draft regulations were expected in early 2026, none have yet been issued and the delay to the EPC reforms means that there is currently no clear timetable for when these proposals might progress. 

If you would like to discuss any of these aspects further, please get in touch with your Turcan Connell contact or email enquiries@turcanconnell.com.