Food Storage and Fixed Heating: Scotland's March 2024 Repairing Standard Additions

The statutory guidance update that took effect on 1 March 2024 added several requirements to the repairing standard that catch landlords off guard. Two of the most practical are the food storage and preparation provisions under Section 13(1)(j) and the fixed heating confirmation under Section 13(1)(c). Both sound straightforward, but the detail matters — especially if your property is an older conversion or a bedsit.

Food Storage and Preparation Space

Your property must have satisfactory provision for, and safe access to, both food storage and food preparation space. In practice, this means:

Hygienic food preparation surfaces — worktops in the kitchen area must be cleanable, non-porous, and in reasonable condition. Cracked, delaminated, or visibly damaged worktops don't meet the standard.

Secure food storage — the property needs cabinetry or a pantry where food can be stored hygienically. The guidance references lined or lockable storage, though a standard set of kitchen wall and base units with doors in working order satisfies this for most properties.

Safe access — the tenant must be able to reach both the food preparation area and the storage without obstruction or hazard. In a flat where the kitchen doubles as a corridor or where the route to the kitchen passes through an unsafe area, this could be a problem.

This requirement doesn't mean you need to fit a new kitchen. It means the kitchen or cooking area must have functional worktops and cupboards. A bedsit with a kitchenette still needs proper worktop space and a place to store food securely — a bare shelf won't satisfy the guidance.

Fixed Heating System

Section 13(1)(c) has always required space heating installations to be in reasonable repair and working order. The March 2024 guidance made one thing explicit: the property must have a permanently installed, fixed space heating system. Portable plug-in electric heaters do not qualify as the primary heat source.

This means:

• A gas central heating system with a boiler and radiators — compliant
• Electric storage heaters or panel heaters wired into the fixed electrical installation — compliant
• An oil-fired or LPG heating system — compliant
• A solid fuel stove or fireplace as the primary heat source — compliant, provided it meets ventilation and carbon monoxide detection requirements
• Plug-in portable electric heaters as the sole heating — not compliant

The distinction is between heating that's part of the building's infrastructure and heating that a tenant could unplug and carry to another room. If your property relies entirely on portable heaters, you need to install a fixed system.

What This Means for Older Properties

These requirements affect certain property types more than others:

Pre-war tenement flats — many have been extensively modernised, but some still have original kitchens with worn worktops and minimal cabinetry. A pre-let inspection should verify that the kitchen surfaces and storage meet the current standard.

Bedsits and studio flats — the food preparation and storage requirement applies even in very small properties. A single-room let with a kitchenette still needs a functional worktop and food storage.

Properties with gas fires only — if the only heating is a gas fire in the living room with no radiators in bedrooms, check whether this constitutes adequate fixed heating for the whole property. A gas fire in one room doesn't heat the bedroom or bathroom. The guidance expects the whole dwelling to be served by a fixed heating system.

Properties converted from commercial use — the food storage requirement assumes a residential kitchen setup. If the conversion didn't include proper kitchen fittings, this needs addressing before letting.

Enforcement

Both requirements are part of the repairing standard, enforced through the First-tier Tribunal in the same way as any other element. A tenant can apply using Form A, and the tribunal can order you to install compliant heating or kitchen facilities within a fixed deadline.

The fix for food storage is usually straightforward — replacing damaged worktops or fitting a set of base units. The fix for heating depends on the property but typically means installing electric panel heaters or extending the existing central heating system.

For the complete list of March 2024 additions (including RCD protection, lead pipes, and common parts), contractor briefing sheets, and pre-let inspection checklists, see the Scotland Repairing Standard guide.

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