Scotland is set to press ahead with new energy efficiency standards for rental properties, requiring newly let homes to meet a minimum Energy Performance Certificate (EPC) rating of C by 2028, under draft regulations published this week.
The move, outlined in the Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations, aims to reduce carbon emissions from the housing sector while bringing rental stock in line with long-term climate goals.
If approved, the regulations would also apply to all existing private rented sector (PRS) tenancies by the end of 2033, giving landlords more time to upgrade properties compared to the 2030 deadline currently proposed in England.
52% of Scottish PRS Stock Already Meets Target
According to Scottish Government figures, just over half (52%) of homes in the private rented sector already meet or exceed an EPC rating of C. But the new rules mean a substantial portion of landlords will still need to invest in energy upgrades—ranging from better insulation and windows to new heating systems.
Industry Concerns Over Cost and Impact on Rental Supply
The proposals have prompted pushback from industry groups, with Propertymark, the professional body for estate agents, warning of a potential knock-on effect on Scotland’s already strained rental market.
“Any proposals for Minimum Energy Efficiency Standards for the private rented sector in Scotland must be realistic and achievable,”
said Timothy Douglas, Head of Policy and Campaigns at Propertymark.
Douglas cautioned that landlords are already grappling with higher mortgage and building costs, while the Housing (Scotland) Bill—which includes new rent control measures—adds further financial pressure.
“Policymakers must recognise that landlords in Scotland are not immune to financial challenges… and will experience further financial challenges with the onset of rent control measures.”
Rural and Island Communities May Be Hit Hardest
There are also fears that the EPC mandate could disproportionately affect rural, island, and older urban properties, where retrofitting costs tend to be higher and construction logistics more complex. Propertymark has called on the government to ensure any future regulation is evidence-based and regionally sensitive, so it doesn’t lead to unintended reductions in rental supply in harder-to-reach areas.
Next Steps: Draft Regulations and Consultation
The Scottish Government has not yet confirmed a timeline for implementation, but the regulations are currently in draft form, and stakeholders expect a formal consultation process to begin soon.
If passed, the rules would bring Scotland in line with other European countries adopting similar efficiency standards in response to climate goals. However, the longer lead time compared to England is seen as a concession to market realities and the cost of compliance.
Policy Context: EPC in the UK and Beyond
The EPC framework—measuring a property’s energy efficiency from A (most efficient) to G (least efficient)—has become a key tool in the UK’s net-zero transition. Scotland’s push aligns with broader UK-wide aims to decarbonise housing, though political appetite varies across the nations.
In England, landlords have faced criticism over a lack of clarity around EPC reforms, with some proposals delayed or shelved. In contrast, Scotland’s firm timeline for the PRS may signal a more determined approach.
