Scotland delays EPC reforms to 2028 and raises fees
"The fee which may be charged ... is increased" is the flat wording in the explanatory note, but the real message from Edinburgh is wider than a line about admin costs. The Energy Performance of Buildings (Scotland) Amendment Regulations 2026 do two clear things: they put up the fees for lodging EPC data, and they push back the full start date for Scotland's 2025 energy performance rules. Published on legislation.gov.uk after being made by the Scottish Ministers on 28 October 2026, the instrument applies in Scotland only. Even so, it will be watched closely by landlords, assessors, housing bodies and property firms on both sides of the Border, especially those with Scottish homes, offices or mixed portfolios to manage.
Most of the regulations came into force on 30 October 2026, with the changes in regulation 2 following on 31 October 2026. That split start date looks fussy on the page, but it matters in practice because regulation 2 rewrites the rules around the register where energy performance data is stored. Under the new wording, there can be one or more registers from which an energy performance certificate and a recommendations report may be produced. Each register must be maintained by a keeper, data has to be sent to the relevant register before a document is issued, every entry must have a unique reference, and the information must stay on the register for at least 10 years. Apart from limited updates to Green Deal information, entries cannot simply be changed later.
The part most readers will notice first is the price rise. The explanatory note states that the fee for registering energy performance data for a dwelling goes up from £2.60 to £6.00. For a building other than a dwelling, the charge rises from £12.10 to £15.50. That increase only applies where the keeper of the register is a Scottish public authority, but it still lands at a time when property compliance is already a cost centre for many firms. On their own, these are not eye-watering sums. Added across volumes of work, though, they are another expense for assessors, landlords, agents and businesses dealing with the Scottish market.
The second half of the instrument resets the clock on the Energy Performance of Buildings (Scotland) Regulations 2025. What had been due to come fully into force on 31 October 2026 will now come fully into force on 30 April 2028. The transitional dates move with it. References that had pointed to late October 2026 now shift to late April 2028, later dates move into April 2029, and one long-stop date is carried out to 30 April 2033. In plain terms, the sharper deadline has gone. Ministers have given the sector more time before the newer regime bites in full.
For households, that means no immediate full switchover to the 2025 framework at the point many in the sector had been preparing for. For assessors and approved organisations, it means the existing arrangements stay in play longer. For housing associations, commercial landlords and firms with Scottish property on the books, planning assumptions now need another look. That is where this becomes more than dry legal drafting. Policy made in Edinburgh often arrives without much noise in London, yet it shapes real decisions on sales, lettings, retrofit work and compliance budgets. For northern businesses working across the Border, the message is simple enough: the bigger EPC overhaul has been delayed, but the administrative cost has gone up straight away.
The draft instrument was laid before and approved by the Scottish Parliament, then signed at St Andrew's House by Stephen Gethins on behalf of the Scottish Ministers. There is nothing flashy about it, and that is part of the point. This is government changing dates, rewriting register rules and lifting fees in the small print. Still, small print has a habit of turning into real pressure once it reaches the housing market. Scotland's EPC system is not standing still; it is being slowed down in one area and made dearer in another. For households and businesses already juggling standards, paperwork and energy costs, that is likely to be the part that sticks.