If you only work in England, a Scottish commencement date is easy to scroll past. This one is worth two minutes, because the Scottish Government has published its reasoning — and that reasoning is about the UK-wide Home Energy Model programme that everyone’s compliance work eventually depends on.
On 27 August 2026 the Scottish Government published an update confirming that the Energy Performance of Buildings (Scotland) Regulations 2025 will now come fully into force on 30 April 2028, rather than the 31 October 2026 date set when the Regulations were laid.
What’s actually changed
The Energy Performance of Buildings (Scotland) Amendment Regulations 2026 do two things:
- Move the full commencement date of the 2025 Regulations from 31 October 2026 to 30 April 2028, and shift the saving and transitional provisions to match.
- Allow the lodgement fee charged by the Keeper of the Register to rise as already planned on 31 October 2026 — from £2.60 to £6.00 for domestic properties, and from £12.10 to £15.50 for other properties.
Nothing else about the substance of the reforms changes. The new rating systems, the shorter five-year validity period, the redesigned certificate and Property Report and the strengthened quality-assurance regime all remain as approved by the Scottish Parliament in December 2025. The majority of the 2008 Regulations, and the EPC system assessors use today, stay in place until spring 2028.
One part of the 2025 Regulations is already live: Regulations 11 and 12, covering the new Scottish EPC Accreditation Scheme and the appointment of Approved Organisations, came into force on 1 January 2026 and remain in force. The scheme is open to applicants now, ahead of the rest of the Regulations landing in 2028.
Why the date moved — and why it matters in England
The Scottish Government is explicit that this follows “extensive engagement with the UK Government and with the EPC assessor industry” on the delayed launch of new EPCs in England and Wales. Three points stand out:
- The UK Government’s public commitment is still “the second half of 2027.” Scotland notes the UK Government had not reached final decisions on detailed implementation at the point Scotland had to lay its amending regulations to stop the 2025 Regulations biting on 31 October 2026.
- Scotland deliberately built in contingency. Rather than match the second half of 2027, it planned for April 2028 to reduce the risk of having to amend the regulations again — and the market uncertainty that would cause.
- The underlying programme is shared. The plan to finalise HEM, build and test the new EPC Register and the Energy Calculation as a Service (ECaaS) infrastructure, and train the assessor industry, “will remain the same across the UK.”
That third point is the useful one. The assessor market operates UK-wide and is partly covered by the UK Internal Market Act 2020, so the two governments are working to a common technical timetable even where commencement dates diverge. Scotland’s stated expectation is that the infrastructure will be tested and available for assessors to train on during 2027. That’s a reasonable read on when English assessors should expect HEM training to become real work rather than a diary note.
The Scottish transitional arrangements, in brief
If you do work north of the border, the transitions are worth knowing:
- Buildings for sale or let (other than short-term lets): a one-year grace period from 30 April 2028 to 30 April 2029. Old-style EPCs issued under the 2008 Regulations can still be used during that window, but from 30 April 2028 assessors can only issue new-style certificates. If a property is sold or let again within the transition, a new-style EPC is then required. After 30 April 2029, only new-style EPCs are allowed.
- Short-term lets: the same full one-year grace period, recognising that around 30,000 Scottish short-term lets are continuously advertised and couldn’t all be re-certified on day one.
- Large non-domestic buildings frequently visited by the public (the display duty under Regulation 13): can keep displaying their existing old-style EPC until it expires or until 30 April 2033, whichever comes first.
- New construction: for buildings completed on or after 30 April 2028, the developer must give the owner a valid new-style EPC and Property Report within seven days of submitting the completion certificate to the local authority verifier. This moves the requirement out of standard 6.9 of Schedule 5 to the Building (Scotland) Regulations 2004 and into the EPC regulations.
Elmhurst also reports that the Scottish Government is aiming to launch the new onsite audit regime in the second half of 2027 — ahead of the main reform date — and that the next changes to Scottish Building Standards, expected to use HEM, are currently planned for autumn 2029. That would leave an interim period where SAP is used for Building Standards compliance while HEM produces EPCs, which will need working through for the new-build sector.
What to do about it
For most English assessors and housebuilders, the practical answer is: nothing changes today. SAP 10.3 remains the compliance methodology for Part L and the Future Homes Standard, and the fabric work underneath it — U-values, air permeability, and thermal bridging — is exactly the same set of numbers whether the calculation engine is SAP or HEM later.
That’s the quiet advantage of a slipping methodology timetable. The inputs are stable even when the tool isn’t. Junction detail and PSI values in particular carry more weight under the Part L 2026 targets than most schemes budget for, and modelled junctions beat default values by a margin that usually pays for itself.
If you’d like your junctions modelled properly now — so the fabric is right whichever engine ends up running the numbers — get in touch and we’ll tell you how we’d approach it.
Sources: Energy Performance Certificate Reform: updates — 24 August 2026 update, gov.scot (published 27 August 2026) · Energy Performance of Buildings (Scotland) Regulations 2025 — EPC reform consultations: SG response, gov.scot · The Energy Performance of Buildings (Scotland) Regulations 2025 (SSI 2025/417), legislation.gov.uk · Scottish Government confirms EPC reform delayed until April 2028, Elmhurst Energy