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Committee

Local Government, Housing and Planning Committee 11 November 2025

11 Nov 2025 · S6 · Local Government, Housing and Planning Committee
Item of business
Subordinate Legislation
Energy Performance of Buildings (Scotland) Regulations 2025 [Draft]

I will give my view on that, and then I will let my team come in with anything else that they would like to add. First, the whole thrust of our proposed changes is to empower consumers to understand more about the buildings that they are buying or renting. To do that, we need to have accurate and up-to-date information. There is a balance to be struck between ensuring that they have such information and understanding that, as you said, the frequency with which EPCs are required creates additional obligations for building owners. To our mind, the move from 10 to five years strikes that balance. Ultimately, we are asking that a property has only one more EPC in a decade, which, to me, feels like a proportionate way to ensure up-to-date and accurate information. When the committee heard evidence, bodies such as Which?, and others, were clear on that, too.

In both the social and private rented sectors, particularly when a landlord has a large portfolio, we are not just talking about them having to make one more certificate available. We have been considering how to work with the social rented sector on a framework for the procurement of EPCs for a large number of properties. We think that that could reduce costs by up to 20 per cent. The majority of PRS landlords have one property, but I am aware and conscious that some have more. We have been working with them on guidance for reusing data, for example, when updating an EPC.

I hope that, in all those ways, we can make what I think is a proportionate change all the less burdensome. I am also interested in and open minded to the idea that the validity period could move back to 10 years once a heat retention rating C has been achieved, but we will keep that under review.

In the same item of business

The Convener Green
The next item is an evidence session on the draft Energy Performance of Buildings (Scotland) Regulations 2025. We are joined by Màiri McAllan MSP, the Cabine...
The Cabinet Secretary for Housing (Màiri McAllan) SNP
Good morning. I am pleased to join the committee today to speak to the draft Energy Performance of Buildings (Scotland) Regulations 2025, which will legislat...
The Convener Green
I will open up the questions by asking about EPC metrics and the assessment methodology. When you joined us in a previous evidence-taking session, you talked...
Màiri McAllan SNP
The home energy model is a foundational part of the proposed changes. I will point to a few things in answering your question. First, UK and Scottish officia...
The Convener Green
What are those agreed timelines?
Màiri McAllan SNP
Ross Loveridge will keep me right on this. Is it to go live on the 31st October next year?
Ross Loveridge (Scottish Government)
Yes. We are working to the same timetable, convener, because, as the cabinet secretary said, the UK Government is planning to make similar reforms in England...
The Convener Green
The next theme is the reduction in EPC validity periods, which Meghan Gallacher will cover.
Meghan Gallacher (Central Scotland) (Con) Con
The Scottish Association of Landlords is in favour of retaining the 10-year period, arguing that increased regulation incurs costs, which can then be passed ...
Màiri McAllan SNP
I will give my view on that, and then I will let my team come in with anything else that they would like to add. First, the whole thrust of our proposed chan...
Meghan Gallacher Con
That is helpful. Convener, I do not have any further questions on that.
The Convener Green
It is interesting that the majority of people have one property, but others have more than that. Do you have the data on that?
Màiri McAllan SNP
Yes. In my scribbled handwritten notes it says that, in June 2024, 76 per cent of all registrations were for one property. I will check the source of that an...
The Convener Green
That would be great—thank you very much. The possibility of going back to a 10-year validity period once people reach an EPC C rating is interesting. The ot...
Evelyn Tweed (Stirling) (SNP) SNP
Cabinet secretary, will you outline what the Government’s plans are for the training and availability of assessors to undertake the proposed new assessments?...
Màiri McAllan SNP
My colleague Ross Loveridge has already mentioned that the assessment and the pool of assessors is a UK-wide matter, so it is another part of the process on ...
Ross Loveridge
I am happy to do that. The market has been through previous changes—EPCs have been updated over time—so the assessor market is used to dealing with changes t...
Evelyn Tweed SNP
When might the training start, given that it is not too long before the regulations come into force?
Màiri McAllan SNP
I think that it has already started, to a great extent, has it not?
Ross Loveridge
Yes, it has. We are already discussing that with organisations. Versions of the home energy model are now available for approved organisations and assessor o...
Patrick Mason (Scottish Government)
As the cabinet secretary set out, the role of the assessor will not be significantly different. They will be doing much the same job, but they will need to b...
The Convener Green
Could you give us an indication of your plans for updating the auditing and assurance requirements?
Màiri McAllan SNP
Forgive me, convener, but I might turn straight to Ross Loveridge to answer that. We had a conversation about it this morning and he explained it to me very ...
Ross Loveridge
We have known for a long time—indeed, such matters were raised when the committee discussed EPCs back in January—that there have been long-standing concerns ...
The Convener Green
Will you say a little more about smart auditing, Ross? That sounds interesting.
Ross Loveridge
Patrick Mason can explain this as well. We have a system that flags errors. For example, if an assessor submitted or lodged multiple certificates—a number th...
Patrick Mason
That is exactly right. In essence, our approach involves risk-based auditing. It looks at an unlikely set of circumstances, puts rules in place around it and...
Màiri McAllan SNP
The other side of the auditing process involves the carrying out of local authorities’ enforcement obligations. Again, we are conscious of monitoring that. W...
The Convener Green
Alexander, you had questions in that area. Do you want to pursue those?
Alexander Stewart (Mid Scotland and Fife) (Con) Con
Yes, thank you, convener. Thank you, cabinet secretary, for that insight. As you have identified, the problem is that, under the existing regulations, some c...