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Energy efficiency Solutions for landlords
HELPING LANDLORDS GET AHEAD OF THE REGULATIONS
As of January 2026, the energy efficiency requirements for private rental properties in Scotland are currently in a major transition phase.
UPDATE*The government has in March 2026 announced a postponement until 2027.
The stated changes will come in at a date in 2027 which is still to be announced .
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As of January 2026*(see note above), the energy efficiency requirements for private rental properties in Scotland are currently in a major transition phase.
The most important thing to know is that while there is no mandatory minimum EPC rating today, a new system and strict deadlines are being introduced throughout 2026 and 2028.
1. Current Requirement (Early 2026)
- The "Paperwork" Rule: You must have a valid Energy Performance Certificate (EPC) to market or let a property.
- No Minimum Score (Yet):1 Unlike England and Wales (where a minimum of 'E' is required), Scotland does not currently have a minimum rating for existing lets. You can technically rent out a property with an F or G rating, provided the tenant is given the EPC.
2. The 2026 "EPC Overhaul"
The Scottish Government is introducing the Energy Performance of Buildings (Scotland) Regulations 2025, which change the rules significantly this year:2
- New Metrics: Starting in Autumn 2026 (expected October 31), the EPC will change.3 It will now focus on a Heat Retention Rating (HRR), which measures how well the building fabric (walls, roof, windows) keeps heat in.4
- Shorter Validity: New EPCs will be valid for only 5 years (down from 10 years) to ensure data stays current.5
3. Upcoming Mandatory Deadlines
The Scottish Government has proposed a clear timeline for reaching EPC Band C (or the equivalent under the new Heat Retention Rating):6
Deadline Requirement January 2028 All new tenancies must meet EPC Band C (Heat Retention).
By end of 2033All rental properties (including existing ones) must meet EPC Band C.
4. Financial Caps and Exemptions
If your property is old or difficult to upgrade, there are safety nets being finalized:
- Cost Cap: There is a proposed cost cap (likely around £10,000). If you spend up to this amount and the property still doesn't reach Band C, you may be able to register an exemption.
- Technical/Legal Exemptions: Exemptions will likely exist for listed buildings or cases where "all feasible measures" have already been taken.
What should you do now?
If you own a property with a rating of D, E, F, or G, you could start planning upgrades now.
Colin Kerr Limited can help you decide on some cost effective solutions that the mainstream advice does not cover.
An example of this
:An unused decorative flame fire was removed from a property by a gas safe engineer and the chimney capped which gave the landlord an increase from "D" to "C"
The tenant was happy the draughty room was now more comfortable.
Heat retention rating
The Heat Retention Rating (HRR) is the most significant change to Scottish property standards in decades. It shifts the focus from how cheaply you can heat a home to how well the building holds onto that heat.
Starting late 2026, this will become the primary metric on a new, redesigned Scottish EPC.
Why is it changing?
Under the old system (SAP), a house could get a "Good" rating just by having a cheap-to-run gas boiler, even if the walls had no insulation. The HRR fixes this "loophole" by measuring the building fabric (walls, roof, floor, and windows) regardless of the heating system.
How it is Measured
The HRR is calculated in kWh/m2/year. This represents the amount of energy required to keep your living area at a constant temperature of 21°C.
The score is placed on an A to G scale:
- Band A: ≤ 30 kWh/m2 (Very high efficiency/Passive house standard)
- Band C: 71 – 120 kWh/m2 (This is the "Target" for 2028/2033)
- Band G: ≥ 351 kWh/m2 (Extremely poor insulation)
Key Differences for Landlords
The transition to HRR means some properties will see their "letter" change even if no work is done:
Property Feature Old EPC Rating New Heat Retention Rating
Old gas boiler + thick insulation Likely a C Likely stays a C or B
Modern boiler + no insulation Could be a C Likely drops to D or E
Electric heating + great insulation Often a D or E (due to cost)Likely jumps to a B or C
The "Three Pillars" of the New EPC
From October 2026, your EPC won't just be one score. It will show three distinct ratings to give a full picture of the property:
- Heat Retention Rating: How well the "shell" of the house works.
- Heating System Rating: How efficient and eco-friendly the boiler/heat pump is.
- Energy Cost Rating: An estimate of what the tenant will actually pay in bills.
What does this mean for you?
If you are planning renovations, you must adopt a "Fabric First" approach. Installing a new boiler will no longer help you reach the mandatory Band C target if your walls aren't insulated. You must prioritize loft insulation, wall insulation, and high-quality glazing to satisfy the HRR requirements.
Simple and effective solutions can be found to help you comply, sometimes it is as simple as updating information or finding existing installed measures and updating certificates to reflect previous work.