Commercial property owners in Scotland are being urged to prepare for major changes to the Energy Performance Certificate (EPC) regime, as the Scottish Government moves ahead with reforms that will take effect over the next few years.
With old-style EPCs set to become invalid on 31 October 2026, and a final transition deadline of 31 October 2027, owners who plan to sell or let property will need to take action well in advance.
Looking back at the EPC reform consultation
In 2023 the Scottish Government consulted on wide-ranging changes to the domestic and non-domestic EPC system as part of its efforts to reach net zero by 2045. The aim was to update how EPCs work, make the ratings more meaningful, and help building owners understand potential improvements more clearly.
That consultation has now shaped the new Energy Performance of Buildings (Scotland) Regulations 2025, which will replace the current 2008 Regulations.
The new framework will come into force on 31 October 2026 and is designed to modernise EPCs, reduce confusion between the Scottish and English systems, and give owners clearer, more practical information.
Importantly, all existing EPCs issued under the 2008 Regulations will automatically expire at that point, regardless of when they were issued.
Every property will therefore need a new-style EPC unless it falls within a transitional arrangement.
Transitional arrangements explained
To ease the shift, the Government has set out a number of grace periods.
- For most property sales and new lettings, there will be a 12-month period from October 2026 to October 2027 where either an old or new EPC can be used. If the property is then sold or let again within that year, a new-style EPC will be required for the later transaction.
- After 31 October 2027, only EPCs produced under the 2025 Regulations will be accepted.
- Short-term lets will also have until October 2027 to obtain the new certificate, recognising that many are advertised continuously.
- Some large non-domestic buildings that are required to display an EPC to the public can continue showing their existing certificate until its expiry, or until 31 October 2031, whichever comes first.
- For new construction, developers will need to provide the new-style EPC and accompanying Property Report for any building completed on or after 31 October 2026.
Key changes for non-domestic buildings
One of the most significant updates is the introduction of a revised EPC rating system for non-domestic properties. The new approach will measure energy performance, energy use and direct emissions in a way that is more comparable with the rest of the UK.
However, there will still be differences, and Scotland is not introducing minimum energy efficiency standards like those used in England and Wales.
The new certificates will also come with a Property Report offering practical guidance on how owners could improve energy performance, cut running costs and consider alternative heating options. This additional layer of information is intended to make EPCs more useful as a planning tool rather than simply a compliance requirement.
Another important change is the reduction of EPC validity from ten years to five, meaning owners will need to refresh certificates more frequently. Oversight of assessors will also be strengthened, with updated accreditation requirements and on-site audits intended to improve consistency across the sector.
EPCs will still be required for new construction, sales and lettings, and certain larger buildings will still need to display one. Local authorities will continue to enforce the rules, with the current penalty levels remaining in place.
What commercial property owners should do next
The most immediate issue for commercial property owners is timing.
Anyone expecting to sell or let property after 31 October 2026 should plan ahead for obtaining a new-style EPC subject to the transitional arrangements narrated above. Owners may also want to consider whether future energy-efficiency improvements could affect their rating under the new methodology.
Taking steps early will help avoid delays to transactions, ensure compliance with the new rules and give owners a clearer picture of their building’s long-term energy performance.
Published 4 December 2025
