From 1 November 2026, only EPCs produced under the new methodology will be valid. There will be a short transition period allowing existing EPCs to be used for sales and lettings taking place before the go-live date, but after that point, the new format must be used. Older certificates will remain accessible in the public register but will be clearly marked as historic and invalid.
What the new rules do
The 2025 Regulations revoke the 2008 rules and introduce transitional arrangements as the new system beds in. EPCs will use clearer indicators—heat retention, heating system and energy cost—and will be valid for five years rather than ten to keep data current. A central register will issue EPCs and property reports and will manage data entry for a fee.
Property reports must set out the property’s current energy performance, how it can be improved and the estimated costs. When a property is marketed for sale or rent, a valid EPC and the related property report must be available free of charge to prospective buyers or tenants and provided at completion. Additionally, buildings where members of the public have an express or implied licence to enter, such as retail stores, council offices and GP surgeries, must display a valid EPC.
Local authorities can issue civil penalties for breaches: £500 for residential properties and £1,000 for others.
Accreditation of schemes and organisations
Specific sections of the Regulations will commence on 1 January 2026, so the Scottish Government can ensure relevant approved organisations, accreditation schemes, and assessors are in place to support the new regime. Nothing will change for agents at this point.
Private rented sector: links to Scotland’s MEES proposals
Propertymark has consistently supported EPC reform that underpins net zero while remaining practical for the market, and we backed Scotland’s shift to a redesigned EPC with clearer metrics and digital access (alongside keeping PDFs for conveyancers).
To ensure the success of the new regime, Ministers must balance costs and benefits. On proposed lodgement fee increases and higher penalties, we warned against creating unnecessary cost pressures and recommended a review of the impact within two years of go-live.
The Scottish Government’s companion proposals for the PRS would require homes to meet a Heat Retention Rating (HRR) Band C on the reformed Scottish EPC from 2028 for new tenancies and 2033 for all lets. We support the principle but have pressed for phasing, fair exemptions, and better funding to keep homes available to rent.
