There are lots of legislative and regulatory difference between Scotland and the rest of the UK. But perhaps one of the most misunderstood differences in property has been the Energy Performance Certificate (EPC) rating system.

While, on the face of it, the scoring system appears to be the same – ranging from A to G – the way those ratings are arrived at differs meaningfully. That has meant a building which scores B in Scotland could plausibly be an A in England, and vice versa.

From October 31 2026, the difference between the two regimes will widen further, as a new EPC framework is brought into effect by the Scottish Government – the biggest shake-up in Scottish EPCs for more than a decade.

For non-domestic buildings, the longstanding single A–G label is being replaced by a multi-metric performance dashboard. This is intended to provide a more accurate view of how buildings operate in practice and identify assets that may appear efficient under the current system, but carry higher operational emissions.

Another feature of the new framework is the introduction of the ‘Direct Emissions Rating’. Under current rules, modern gas boilers often support a strong EPC score due to the relatively low cost of gas. With the revised methodology, however, the emissions associated with fossil-fuel heating systems will be more visible, leading to lower Direct Emissions Ratings.

Although no immediate regulatory action applies, occupiers and investors focused on ESG and net zero targets will be able to more clearly see how much of the energy used in their properties comes from fossil fuels. As a result, they may increasingly favour buildings with lower emissions profiles.

For operators of domestic properties, there are also specific changes to consider. The most visible is the move from a single headline score to a three-part assessment, designed to provide greater clarity and prevent efficient heating systems from masking weak insulation performance.

The first of these indicators is a Heat Retention Rating, which works along the lines of the current system with A–G scoring. It focuses exclusively on the fabric efficiency of a building, reflecting how well the structure resists heat loss and gain. Government-adjusted bands are intended to ensure fairness, with Band C now covering 91–159 kWh/m²/year and retaining around 80% of current C-rated homes.

Alongside this sits a new Heating System Rating, again scored from A–G, replacing the previous cost-based energy efficiency rating. This simplified methodology classifies different technologies in a straightforward way: heat pumps are Band A; oil, coal, and peat systems F–G; and gas boilers are typically capped at Band E.

The third element is the Energy Cost Rating. This provides a realistic estimate of the heating, lighting, and other energy-related running costs of a home, rather than just theoretical efficiency. This should be useful to buyers comparing properties, and help landlords assess compliance and asset management requirements.

For both domestic and non-domestic properties, perhaps the most notable change is the reduction in EPC validity periods from ten years to five. This should create a more active compliance cycle and will heighten the need for accurate portfolio tracking.

All of these changes are designed to better reflect real building performance, support net zero objectives, and provide greater transparency. And while it may seem like months away, from the end of October only EPCs assessed under the new methodology will be valid. So, the best time to take action and prepare your portfolio is now.