Scotland’s planned EPC delay: what short let hosts should check

The planned delay needs an amendment to existing law

Scotland’s EPC reform is already in legislation. The Energy Performance of Buildings (Scotland) Regulations 2025 were made with a main commencement date of 31 October 2026. On 24 August 2026, the government announced a plan to move that date to 30 April 2028 and the short let transition end to 30 April 2029. The delay is the proposed change; the original reform is not a new proposal.

The committee recommended approval of the draft amendment on 29 September. The 8 October Parliament Business Bulletin still listed it as subject to approval, and the official legislation entry remains in the draft collection on 19 October. Parliament approval and ministers making the amendment are needed to change the legal timetable. The government’s current guidance expressly says its new dates are subject to Parliament approval.

Check the certificate and the listing you use today

The Scottish Government’s current guidance says short term lets generally require a valid EPC. If you let an entire house or flat, its EPC rating must also be displayed in the listing. A room only let, caravan, bed and breakfast or guest house can have different treatment, so check the specific accommodation rather than copying another operator’s answer.

Find the certificate for each whole property short let. Check that its address and property description match the advertised accommodation, it remains valid and its rating appears in every current listing. If a certificate is missing, expired or describes a different arrangement, ask a Scottish assessor or the local authority what applies.

This timetable does not itself introduce a new minimum EPC rating for short lets. The committee report explains that EPCs primarily provide information rather than set mandatory improvement standards. Certificate reform, any separate minimum energy efficiency policy, licensing and planning each need their own check.

The October fee rise is separate from the planned delay

The government’s published plan retains the register fee increase on 31 October 2026. Its figures are £2.60 to £6 for domestic EPC registration and £12.10 to £15.50 for other properties. These are register lodgement fees, not the total assessment cost. An assessor may include them in a quote, but a host should not assume that the full invoice will rise by exactly the same amount.

If you need a certificate soon, ask what the quote covers, whether the lodgement fee is included and which certificate system will apply on the assessment date. Do not order early solely to avoid a small fee change. Compare the whole assessment cost and the certificate you actually need for the property and date.

Review the position before the October changeover date

Keep a valid certificate with the property records and assign someone to check the final amendment before 31 October. Record the made instrument and its commencement date when available. If an assessment, new listing or booking arrangement crosses a changeover date, confirm the applicable rules with the assessor or local authority before relying on the announced delay.

Under the proposed April timetable, short lets could use a valid existing EPC and recommendation report or a new style EPC and property report from 30 April 2028 to 30 April 2029. After that transition, the new style certificate and report would be required. Do not assume an old certificate will remain acceptable until 2029 merely because those dates have been announced. The amendment must first be approved and made.

Our short let preparation guide covers the wider launch checks. The UK permissions guide separates Scotland’s licensing and planning questions from the rules in other nations. The editable record below keeps the certificate details, quote and next status check together.

Use Scotland’s final rules for the property and date

This is a Scotland specific certificate update. It does not replace a short let licence, resolve planning permission or establish that an operator may use a property. It should not be applied to England, Wales or Northern Ireland.

The source position was checked on 19 October 2026. The published 2025 regulations retain the October 2026 date, while the government guidance and draft amendment set out the conditional April 2028 and April 2029 plan. For a decision near the changeover, use the latest made legislation and current Scottish Government guidance together.