Property logbooks would be the best solution to EPC reform

Propertymark has responded supportively to the Scottish Government’s consultation on changes to Energy Performance Certificates whilst adding recommendations on assistance for the property sector to move towards net zero and a call for adequate time to implement any changes.


The review included EPCs for both domestic and non-domestic properties, and proposals include plans to reform the metrics displayed, the purpose and validity period, the format of the document, and quality assurance procedures.

The changes are intended to provide relevant and holistic information to help people make informed purchase, rental and retrofit decisions that support the improvement of homes and buildings towards net zero. However, these are intended to be made by Winter 2023/2024 and we have stressed the importance of sufficient time to allow property agents to become familiar with the changes and receive training if needed.

Logbooks are a holistic solution

We strongly support the introduction of individual property logbooks which would include comprehensive data on energy performance and are designed to be of practical use to agents, owners, and occupiers throughout the life of a building. Logbooks should also include details of retrofitting work that has been completed and recommendations for further energy efficiency improvements.

The future of EPCs

EPCs are a recognised brand for homeowners, landlords, their agents, and tenants, and the rating system is relatively simple to understand. We welcome the proposal to digitalise EPCs, but PDFs must remain as they are essential during the home buying and selling process for conveyancing solicitors.

Equally, we support the proposal to shorten the validity period of EPCs to five years from the current ten, as a lot can happen to a property within that timeframe. We already encourage property agents to renew their EPCs as often as possible as a matter of good practice.  

More accurate data

The Scottish Government also propose to collect additional data as part of the EPC assessment framework. This will include more holistic data on the fabric of buildings and greater emphasis on wall and loft insulation. We support this proposal, particularly on heating systems given the incoming New Build Heat Standard (NBHS) which will prohibit the use of direct emissions heating systems in new buildings, both domestic and non-domestic, from 2024.

Non-domestic properties

A different regime and framework is required and we urge the Energy and Climate Change Directorate to be mindful of the potential complexity of making energy efficiency improvements in commercial buildings. A one-size-fits-all all approach will not work, and the use of the building must be considered.

Additionally, the responsibility for decarbonisation remains unclear for non-domestic stock, with tenants only being required to bring the building back to its original state at the end of leases.

Download the full consultation response