Quick Summary
- Proposed, not yet law — the Scottish Government has consulted on a minimum energy efficiency standard for private lets: new tenancies from 2028, all tenancies by the end of 2033
- The standard is Heat Retention Rating band C, not today's EPC C — the rating measures the building's fabric only, and the consultation says a property with an existing EPC band C would not count
- New-style EPCs start on 30 April 2028 — moved from October 2026 (announced 24 August 2026); until then there is no way to get a Heat Retention Rating at all
- Use our Buy-to-Let Tax Calculator to model how upgrade costs affect your yield and tax position
Most guides still describe this as "EPC C by 2028". That is the shorthand, and it is misleading in the way that costs landlords money: a new boiler or better heating controls can lift a current EPC to C and do nothing at all for the rating the proposed standard actually uses.
Quick Answer: There is no minimum EPC for private lets in Scotland today. The Scottish Government has consulted on regulations that would require private rented homes to reach band C on the Heat Retention Rating (HRR) — a new headline rating on reformed EPCs that measures how well the building's fabric keeps heat in — before a new tenancy from 2028, and for all tenancies by the end of 2033. It is not yet law. New-style EPCs, which carry the HRR, now come into force on 30 April 2028. The consultation proposed a cost cap exemption of £10,000 per property and penalties of £600 or £3,000.
What is an EPC?
An Energy Performance Certificate (EPC) rates a property on a scale from A (best) to G (worst). It's produced by an accredited energy assessor who records the insulation, glazing, heating system and controls, hot water and any renewables, and it gives a current rating, a potential rating and a list of recommended improvements.
For lettings, the EPC must be available to prospective tenants. Today's certificates are issued under the Energy Performance of Buildings (Scotland) Regulations 2008.
Scotland's current rules (no minimum EPC yet)
There is no minimum EPC rating for private lets in Scotland today. The Scottish Government consulted in 2019 on an EPC E minimum for the private rented sector, but did not introduce the regulations because of the impact of Covid-19. What you do need now is a valid EPC to show prospective tenants, and the property must meet the Repairing Standard — enforced through the First-tier Tribunal for Scotland (Housing and Property Chamber).
What is proposed
The proposals come from the Scottish Government's consultation on draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations, published on 6 June 2025 and closed on 29 August 2025.
| Date | Proposal |
|---|---|
| Now | No legal minimum EPC for private lets |
| 30 April 2028 | New-style EPCs, with a Heat Retention Rating, come into force |
| From 2028 (proposed) | Heat Retention Rating band C before a property is let to a new tenant, unless exempt |
| End of 2033 (proposed) | The same standard for all private tenancies, even with no change of tenant |
The consultation gives "2028" for new tenancies without a day and month, and the regulations have not been laid, so treat any exact 2028 date you see elsewhere as someone's guess. The Government has separately published a draft Bill on heating and energy performance in buildings (18 November 2025), which still has to be introduced to the Scottish Parliament.
New-style EPCs are later than planned
The 2025 EPC Regulations were due to bring in new-style certificates in October 2026. On 24 August 2026 the Scottish Government said they will now come into force on 30 April 2028, to line up with the UK Government's delay. Between 30 April 2028 and 30 April 2029 a property being sold or let can use either an old-style or a new-style EPC; after 30 April 2029 only new-style EPCs will be accepted for sale or let.
The Heat Retention Rating
New-style EPCs will carry three headline ratings:
- Heat Retention Rating (HRR) — how well the building's fabric keeps heat in, from insulation and other factors
- Energy Cost Rating — similar to today's Energy Efficiency Rating, based on the cost of running the home
- Heating System Rating — about the installed heating system
The proposed standard uses the HRR only. The consultation defines band C as 71 to 120 kWh/m² a year, a "good level of energy efficiency", and says that "a property with an existing EPC band C will not be deemed compliant".
That has two consequences worth planning around:
- Heating upgrades do not help you meet it. A new boiler, a heat pump or smart controls change the Energy Cost Rating and the Heating System Rating, not the HRR. Fabric does: insulating walls, roofs and floors, better windows and doors, and reducing draughts.
- You cannot know your rating yet. No HRR exists until new-style EPCs start on 30 April 2028, so any figure quoted to you before then is an estimate.
What improves the fabric
The work that moves a Heat Retention Rating is building work, and HomeSCOT covers it in detail — which measures to do first in an older house, and how to insulate a solid stone wall without trapping moisture.
For tenement flats, roof and wall work usually needs agreement from the other owners, typically through the factor. That can take a long time, which is a reason to start the conversation early rather than a reason to wait.
Try it yourself
Factor upgrade costs into your yield calculation — including the tax deductibility of improvement works.
Open Buy-to-Let Tax CalculatorNo sign-up required.
Funding and tax
Warmer Homes Scotland
The Warmer Homes Scotland scheme provides free energy efficiency improvements for qualifying households — primarily owner-occupiers and private tenants on low incomes or benefits. Landlords themselves don't usually qualify for Warmer Homes, but tenants in your property may qualify — and if the work is done through Warmer Homes, it improves the EPC at no cost to you as the landlord.
Ask your tenants if they'd like to apply to Warmer Homes. The scheme is accessed through Home Energy Scotland: 0808 808 2282.
Home Energy Scotland
Home Energy Scotland runs the Scottish Government's grant and interest-free loan funding and is the first call for current amounts and landlord eligibility: homeenergyscotland.org.
Capital allowances and tax deductibility
EPC improvement works to a rental property are generally:
- Revenue expenses (repairs and maintenance): deductible in the year incurred
- Capital expenses (major improvements): subject to capital allowances
Work that replaces like-for-like (e.g. replacing an old boiler with a new one) is revenue expenditure — fully deductible against rental income in the year. Major structural improvements (external wall insulation) are typically capital and may be added to the property's cost base for CGT purposes rather than deducted immediately.
Seek advice from a tax adviser on how specific works are treated. The distinction matters significantly at Scottish Higher (42%) and Advanced (45%) rates.
Proposed exemptions
The consultation proposes exemptions for:
- Consent — where the landlord cannot get the required consent from tenants, neighbours or the planning authority. Proposed to last five years; a tenant-consent exemption ends sooner if the tenancy ends
- Negative impacts on fabric or structure — where a relevant person advises in writing that a measure would be inappropriate or could damage the building
- Cost cap — a proposed cost cap of £10,000 per property, cumulative, lasting until the property next changes to a new landlord
- Temporary exemptions
A property that does not meet the standard could only be let if the landlord has made all suitable relevant improvements or holds an exemption.
Proposed enforcement
Local authorities would enforce the standard. The proposed financial penalties are:
- £600 where the property has been in breach for less than six months, and £3,000 for six months or more
- £600 for false or misleading information given for registration
- up to £600 for not complying with a compliance notice
These are proposals from a consultation that closed on 29 August 2025. The final regulations may change any of them.
Frequently Asked Questions
Will an EPC C certificate I get now count?
Not under the proposals. The consultation says a property with an existing EPC band C would not be deemed compliant; only the Heat Retention Rating on a new-style EPC would count, and new-style EPCs start on 30 April 2028.
I have a tenant on a long PRT — do I need to upgrade before 2028?
Under the proposals, the 2028 requirement applies when you let to a new tenant. A continuing tenancy would fall under the end-2033 backstop instead. The final wording on what counts as a new tenancy will be in the regulations, which have not been laid.
Will a new boiler get my property to the standard?
No. The proposed standard uses the Heat Retention Rating, which measures the building fabric. Heating upgrades show up in the Energy Cost and Heating System ratings, not the HRR.
Can I claim improvement costs against my rental income tax?
Revenue improvements (replacing like-for-like) are generally deductible against rental income in the year. Capital improvements add to your property's base cost for CGT. The distinction is fact-specific — get advice from a tax adviser familiar with Scottish property tax.
What EPC rating does my property have?
Check the Scottish EPC Register at scottishepcregister.org.uk for an existing certificate, or commission one from an accredited domestic energy assessor. It will show today's ratings, not the Heat Retention Rating, until new-style EPCs start.
What happens if I let a property below the standard after the deadline?
Nothing yet — the standard is not law. Under the proposals, a local authority could issue a penalty notice of £600 or £3,000 depending on how long the breach has lasted. Check the Scottish Government's energy efficiency in homes page for the current position before planning works around a date.
Try it yourself
Check how much you can legally increase rent under Scotland's Private Residential Tenancy rules.
Open Rent Increase CalculatorNo sign-up required.
Related Articles
- Landlord Insurance Scotland — insurance implications of Repairing Standard compliance
- Private Residential Tenancy Landlord Guide — full PRT obligations
- Buy-to-Let Tax Scotland — tax treatment of improvement costs
- Section 24 Mortgage Interest at Scottish Rates — other major cost pressures on Scottish landlords
- Warmer Homes Scotland — grants available for your tenants
This article is for informational purposes only and does not constitute financial, tax, or legal advice. Tax rates and thresholds can change — always verify current rates with Revenue Scotland, HMRC, or mygov.scot, and speak to a qualified financial adviser for advice specific to your circumstances.
Sources: Scottish Government — Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations: consultation, section 4, Scottish Government — Energy Performance Certificate reform: updates (24 August 2026), Scottish Government — Energy efficiency in homes, Scottish Government — Delivering net zero for Scotland's buildings: Heat in Buildings Bill consultation, Home Energy Scotland — Grants and loans, Scottish EPC Register