Scotland Delays 2025 EPC Rules and Raises Register Fees

If you were expecting Scotland’s newer EPC rules to switch on at the end of October 2026, that date has now moved. According to legislation.gov.uk, the Energy Performance of Buildings (Scotland) Amendment Regulations 2026 were made on 28 October 2026, signed by Stephen Gethins for the Scottish Ministers, and apply only in Scotland. Most of the instrument came into force on 30 October 2026, while the fee change in regulation 2 came into force on 31 October 2026. The draft had already been laid before and approved by the Scottish Parliament. For most readers, the two big changes are these: the fee for lodging EPC data has gone up, and the full start date for the 2025 EPC regulations has been pushed back to 30 April 2028.

It helps to pause on the jargon. An EPC, or Energy Performance Certificate, is the document that shows how energy efficient a home or building is. You will usually see one when a property is sold or let. A recommendations report sits alongside it and points to ways energy performance could be improved. Behind that public-facing certificate is a register. The register is where the energy performance data is stored so that an EPC and recommendations report can be produced. The amended 2008 rules restate that there may be one or more registers, each maintained by a keeper, and that different registers can exist for different purposes or for different types of buildings.

The technical part matters because it sets out how the system must work day to day. Where a member of an approved organisation issues an EPC or recommendations report, that person must make sure the energy performance data is sent to the relevant register before the document is issued. Each entry must be given a unique reference. Once the data is registered, it cannot normally be altered. The main exception named in the regulations is Green Deal information, which can be updated by the Green Deal provider under the relevant framework rules. The data must also stay on the register for at least 10 years from the date it is entered. That is a long paper trail, and it matters for compliance, auditing and public confidence in the certificate system.

The fee rise is the change that many practitioners will notice first. The new rules say that, where the keeper of a register is a Scottish public authority, that keeper may charge £6.00 to enter data for a dwelling. The previous fee was £2.60. For a building or building unit that is not a dwelling, the fee rises to £15.50 from £12.10. **What this means:** this is a register-entry fee, not a direct charge invented for every household by itself. But register fees often sit inside the wider cost of producing and lodging an EPC, so the change may still be felt by sellers, landlords, businesses and the professionals doing the work. In simple terms, the administrative part of the EPC process has become more expensive.

The second change is less visible but arguably more important. The Energy Performance of Buildings (Scotland) Regulations 2025 had been due to come fully into force on 31 October 2026. This amendment moves that full commencement date to 30 April 2028. The knock-on dates move as well. In the transitional rules for approved organisations and accreditation schemes, dates that had pointed to 30 or 31 October 2026 now point to 29 or 30 April 2028. Several dates that had pointed to 31 October 2027 now move to 30 April 2029, and one date that had pointed to 31 October 2031 now moves to 30 April 2033. Put plainly, the timetable for moving from the old arrangements to the newer 2025 system has been stretched out.

For households, the key point is that this does not mean EPCs disappear or stop mattering. If you are selling or letting a property in Scotland, the current EPC rules still matter. What has changed is the launch date for the newer 2025 framework, not the basic idea that energy performance information must be recorded and available. **What this means for you:** if you are a homeowner, tenant or landlord, the practical effect is a slower handover to the new regime and a higher register fee in the background from the end of October 2026. If you are an assessor, adviser or part of an approved organisation, the delay gives more time for systems, accreditation and transitional arrangements, but it also means working with the older structure for longer than expected.

There is a useful lesson here for anyone trying to make sense of technical law. Big policy changes are often not one single moment. They arrive through date changes, fee changes, register rules and transition periods that look dry on the page but shape what happens in practice. That is exactly what this Scottish instrument does. It tidies and restates the rules around the EPC register, raises the fees for entering data, and delays the full start of the 2025 regulations until 30 April 2028. For readers and practitioners alike, the clearest reading is this: Scotland is still moving towards the newer EPC system, just more slowly, and with a higher administrative cost attached in the meantime.