EPC Requirements for Scotland Landlords and Energy Efficiency Rules

Energy performance is one of the quieter repairing standard obligations. It does not generate the same urgency as a gas safety certificate or an EICR. But it is changing, and the proposed rules for 2028 will affect what landlords need to spend.

The Current Requirement

Under the Energy Performance of Buildings (Scotland) Regulations 2008, you must have a valid Energy Performance Certificate before you advertise a property for let. The EPC must be obtained from an accredited energy assessor and is valid for 10 years.

As of October 2026, there is no statutory minimum EPC band for existing private lets in Scotland. You need to have the certificate, and you need to make it available to prospective tenants, but the law does not currently prohibit letting a property with a low rating.

This is different from England, where Minimum Energy Efficiency Standards (MEES) already require a minimum EPC Band E for private lettings.

The Proposed 2028 Changes

The Scottish Government consulted on Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations during 2025. The consultation outlined plans to introduce minimum EPC targets starting from 2028, with an initial target of EPC Band C.

These are proposed measures, not operative law. The final statutory details depend on secondary legislation that has not yet been laid before Parliament. The timeline and band targets could shift.

What this means in practice: if your property currently sits at Band D or below, it is worth getting an energy assessment to understand what improvements would lift it to Band C. Common measures include loft insulation, cavity wall insulation, boiler upgrades, and double glazing. But committing to major capital expenditure before the regulations are finalised carries a risk of over-investing against requirements that may change.

What to Do Now

Get the certificate. If your property's EPC is more than 10 years old or you have never had one, commission a fresh assessment before your next tenancy advertisement.

Check the current rating. If it is Band D or below, get indicative quotes for the upgrades that would move it to Band C. Loft insulation and draft proofing are typically the cheapest per band improvement.

Don't over-invest yet. Until the 2028 regulations are finalised, the most cost-effective approach is to address the low-cost, high-impact measures (insulation, heating controls, LED lighting) and defer major structural work (external wall insulation, full heating system replacement) until the final requirements are clear.

Budget for it. When the minimum band does arrive, properties that cannot meet it will either need upgrading or an exemption. Scotland's 2025 consultation proposed a £10,000 cost cap exemption, but this remains a proposal rather than a current legal rule.

EPC and the Repairing Standard

The EPC itself sits alongside the repairing standard rather than inside it. But several repairing standard elements directly affect your EPC rating. The requirement for a fixed space heating system (portable heaters do not count under the March 2024 statutory guidance) means your property must have permanent heating, which also contributes to the EPC's heating score. Similarly, window and door integrity under Section 13(1)(a) (wind and watertight) affects the building fabric assessment.

Addressing repairing standard compliance and EPC improvements at the same time — during a void period between tenancies — is the most efficient approach. A property that meets the repairing standard in full is already partway to a reasonable EPC band.

For a dated breakdown of every repairing standard element and how it overlaps with energy efficiency, the Repairing Standard Compliance Guide maps the current operative duties alongside proposed future measures so you know exactly what is mandatory today and what is still under consultation.

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