Reforming Scotland’s EPC Regime: What the 2025 Update Means for Net-Zero Buildings
As the race to net zero accelerates, the built environment remains both a challenge and an opportunity. Scotland’s new Energy Performance of Buildings (Scotland) Regulations 2025 — via the government’s response to the EPC Reform consultations — marks a pivotal shift in how we assess, regulate, and upgrade our building stock.
This isn’t just bureaucratic tinkering; it’s a structural re-frame of incentives, risks and obligations for owners, developers, landlords and public bodies. The move lays crucial groundwork for delivering meaningful decarbonisation across Scotland’s public estates and private sector portfolios.
Why this matters: EPCs, net zero, and the limitations of status quo
Energy Performance Certificates (EPCs) have long been a tool to measure and compare the energy efficiency of buildings. But critics — including the Climate Change Committee — have argued that traditional EPC metrics fall short in aligning with net-zero goals.
Key issues:
Single headline metric — current EPCs collapse energy, emissions and costs into one figure, hiding inefficiencies in building fabric and heating systems.
Outdated validity and data — 10-year certificates are often no longer accurate.
Weak retrofit signalling — EPCs haven’t consistently directed investment towards the most effective upgrades or aligned with regulatory targets.
The 2025 update aims to address this issue.
What’s changing: Key reforms to look out for
Change What It Means Implications
New metrics & HRR Shift to Heat Retention Rating (HRR)for domestic buildings EPC ratings will now reflect fabric efficiency more directly, influencing MEES compliance
Shortened validity EPCs valid for 5 years More frequent, accurate data and investment triggers
Redesigned certificates Clearer digital formats Easier for asset owners to plan retrofit pathways
Quality assurance Stronger oversight and auditing Improved reliability and enforcement
Link to MEES HRR Band C required for PRS from 2028 (new) / 2033 (all) Major driver of retrofit demand
HEETSA layer Technical suitability assessments More tailored retrofit planning
Strategic implications for the net-zero transition
Early diagnostics will be critical — organisations should assess their portfolios now to identify gaps and plan phased interventions.
Risk of stranded assets — low-performing buildings could lose value or become non-compliant.
Retrofit supply chains must scale — demand will surge across insulation, heating systems, assessment, and design.
Funding alignment matters — success depends on access to grants, investment, and procurement support.
Flexibility is vital — especially for heritage or constrained buildings.
Data quality becomes a core enabler — decisions will be driven by real-time, accurate performance data.
How Net Zero Club is helping bridge the gap
At Net Zero Club, we work at the intersection of policy, innovation, and delivery. Our events are designed to:
Match public-sector project needs with private-sector capabilities
Create partnerships that accelerate retrofit, energy efficiency, and infrastructure upgrades
Provide direct access to decision-makers in local authorities, NHS estates, housing, education, transport and more
Showcase real-world solutions, technologies and funding models needed to deliver at scale
Upcoming opportunities to connect:
Net Zero Scotland Projects Conference – 22 April 2026, Edinburgh
Net Zero Nations Projects Conference – 6 October 2026, London
If your organisation delivers innovative solutions aligned to EPC reform and retrofit goals, these events offer the ideal platform to engage with those shaping and delivering Scotland’s decarbonisation strategy.
Next steps for stakeholders
Run portfolio assessments ahead of 2026 to understand HRR implications.
Engage with technical partners early to scope retrofit pathways.
Align funding strategies to avoid bottlenecks when regulation kicks in.
Collaborate across sectors to pool expertise, capacity and delivery capability.
Final thought
Scotland’s 2025 EPC reforms are not simply a regulatory adjustment — they’re a signal of intent. A move towards more meaningful metrics, stronger accountability, and accelerated retrofit activity.
Those who move early, understand the new metrics, and build the right partnerships will be well-positioned to thrive in this changing landscape.