Member representation: Consultation responses and position papers

The Scottish Government has launched a technical consultation on proposed changes to lodgement fees and penalty charges as part of its ongoing reform of Energy Performance Certificates (EPCs). This follows the publication of the Scottish Government’s response to a 2023 consultation on EPC reform and outlines plans to introduce new EPC regulations in 2025, with enforcement scheduled for 2026.

The Ministry of Housing, Communities and Local Government (MCLHG) and the Welsh Government have proposed new regulations overhauling how insurance costs are charged to leaseholders in multi-occupancy buildings, to increase transparency and prevent leaseholders from being overcharged through commissions and hidden fees. While Propertymark supports efforts to ensure fairness for leaseholders, we have warned Ministers that these reforms alone will not bring down insurance premiums; a focus on building safety and insurer confidence is needed to achieve real change.

The Scottish Government is consulting on the process for a Mental Health Moratorium designed to give people with severe mental health conditions respite from debt recovery action, including rent arrears. Propertymark supports the proposals with recommendations to ensure the scheme works effectively in practice and recognises the rights of landlords.

The Northern Ireland Executive has published a draft Fuel Poverty Strategy with proposals for improving energy efficiency in homes, protecting consumers, and fostering collaboration across sectors. Propertymark supports the key principles but has highlighted critical areas that need further consideration, including achievable timescales, sensible exemptions, and cost caps that reflect property values.

The Scottish Government has launched a review of fire safety regulations following the fatal Cameron House Hotel fire in 2017. Recommendations from the Fatal Accident Inquiry (FAI) highlighted key safety failings and proposed regulatory changes to prevent similar incidents in the future with a particular focus on traditional buildings converted to be used as hotels.

Propertymark has responded to the UK Government’s consultation on proposals to streamline the infrastructure planning process consultation, highlighting key areas where improvements can be made while ensuring the interests of local communities and property professionals are safeguarded. Importantly, we recommend a stronger emphasis on public approval during the pre-application process to ensure that only well-supported projects move forward quickly.

The UK Government is proposing changes to the Right to Buy (RTB) scheme intended to create a fairer and more sustainable system which retains the opportunity for social housing tenants to buy their homes while supporting councils to replace properties that are sold. Propertymark is supportive of the proposals, which include increasing the length of time someone needs to have been a public sector tenant, amending discount percentages, and allowing Councils to ask for repayment of discounts if the property is resold within ten years.

One of the key themes of the White Paper is the Welsh Government’s commitment to achieving housing adequacy — a concept that includes affordability, security, and access to quality housing. While Propertymark agrees with this goal and supports enshrining housing adequacy as a human right in Welsh law, we have urged policymakers to focus on pro-growth policies rather than introducing restrictions that will force landlords out of the market.

We welcome proposals from the Department for the Economy on supporting low-carbon heating in residential buildings, which is a crucial step towards achieving Northern Ireland’s net-zero emissions target by 2050. However, in our response to the consultation we have emphasised the need for an assessment-led approach to funding, ensuring that financial support is directed to the most impactful measures for each property.

This report has been produced by the Wales Tourism Alliance (WTA) in association with Propertymark—acting in an independent role—for submission to Jayne Bryant MS, the Housing Cabinet Secretary. It formed the discussion at the roundtable meeting in Cardiff on 12 November 2024.

Propertymark has criticised the Scottish Government’s proposals for implementing a Building Safety Levy, stating that it is not the best way to fund the remediation of unsafe cladding, and risks cutting the supply of homes. Instead, charges should be directed to the developers and individuals responsible for installing the cladding in roughly 6,000 buildings across the country.

The Northern Ireland Executive’s draft Programme for Government identifies providing access to affordable, sustainable, and quality housing as an immediate priority and acknowledges the pressing need for action. Propertymark supports this aim and has made specific recommendations to accelerate progress.