Calls for balance as minimum PRS energy efficiency standards take shape

The consultation, which closed on 29 August, sets out a framework requiring privately rented properties to meet Energy Performance Certificate (EPC) Heat Retention Rating (HRR) band C for new tenancies from 2028, with a backstop date of 2033 for all PRS homes. A £10,000 cost cap per property and a range of exemptions have been proposed.

CIH Scotland has welcomed the principle of introducing minimum standards, saying all households should benefit from homes that are energy efficient, affordable to heat and contribute to Scotland’s climate change targets.

Ashley Campbell, CIH Scotland’s policy and practice manager, said alignment across tenures will be “key to improving homes in mixed tenure buildings and making progress towards the Scottish Government’s climate change commitments.”

However, she warned that the right support needs to be in place to avoid costs being passed on to tenants. CIH is calling for advice and information for landlords, resources for local authorities to monitor compliance, and financial support to ease the transition.

“We also think that bringing the proposed backstop forward to 2030, in line with UK Government plans, will create the right balance between allowing time for landlords to plan, and creating the urgency and momentum needed to improve conditions for private renters across Scotland,” Ms Campbell added.

Scottish Land & Estates (SLE) also supported the aims of the legislation but has raised concerns that the proposals risk undermining the rural rental sector. The group says older, traditional properties in rural and island areas face particularly steep costs and practical barriers to meeting a heat retention-based standard.

SLE points to cases where significant investment – such as £56,000 spent on improving a traditional Aberdeenshire cottage – has failed to achieve band C, leaving owners with few options under the proposed rules.

Anna Gardiner of SLE said: “Rural properties are typically much older and therefore much harder to treat. Owners of traditional rural homes, who are vital providers of rental housing, face higher upgrade costs, limited access to contractors, and lower rental incomes, compared with urban rental properties.  We support the aim of the legislation – reducing carbon emissions from property, but there are specific challenges in rural and island areas.

“In our meetings with government, we have stressed that focusing solely on heat retention means that a huge number of rural properties are unlikely to ever achieve compliance. Amending the regulations to take into account the efficiency, and consequently carbon emissions and running cost, of a heating system would result in a more effective and practical approach to energy efficiency, while reducing heating bills for tenants.

“The consultation presents an opportunity to address these points and ensure a more balanced outcome.”

The organisation has also warned that the £10,000 cost cap could be unaffordable for many rural landlords, leading to rent increases or a withdrawal of homes from the rental market. It is calling for a full rural impact assessment to ensure the framework is workable and fair.

Ms Gardiner added: “We would urge the Scottish Government to undertake a full rural impact assessment before these regulations are finalised. This is essential to ensure the framework is fair, workable, and aligned with Scotland’s housing, fuel poverty, and net zero ambitions, without compromising the resilience of rural housing supply or penalising rural property owners who are already investing to improve energy efficiency. We welcome the opportunity to submit a consultation response and contribute to the goal of a more energy efficient, resilient, rural housing sector.”