Commercial EPC in Scotland
Scotland runs its own non-domestic energy rules, so the England and Wales band E letting rule does not apply north of the border.
Does Scotland have a minimum EPC band for let commercial property?
No. The band E letting rule sits in the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, which gov.uk describes as establishing a minimum level of energy efficiency for rented property in England and Wales. The government's interim response of 18 June 2026 proposes EPC B from 2031 for larger let buildings, again in England and Wales, and nothing changes until secondary legislation is passed.
Scotland's route for larger non-domestic buildings is section 63 of the Climate Change (Scotland) Act 2009. The regulations apply to a non-domestic building or building unit with a floor area of more than 1000 square metres, and a sale or a lease to a new tenant triggers them. A building unit is a part of a non-domestic building designed or altered to be used separately, so a large floor let on its own can qualify. The section 63 guide sets out the process step by step, and anyone who wants a certificate quoted can send an enquiry through the form.
Where do the 2025 Regulations stand on 22 October 2026?
The Energy Performance of Buildings (Scotland) Regulations 2025 (SSI 2025/417) come into force on 31 October 2026, apart from provisions on approved organisations and accreditation schemes that started on 1 January 2026. A draft amending instrument would change the main date to 30 April 2028. Legislation.gov.uk shows it as a draft that has not yet been made as a Scottish Statutory Instrument (checked 22 October 2026), so the later date is not settled.
The Economy, Tourism and Energy Committee considered the draft on 29 September 2026 and recommended that Parliament approve it, publishing its report on 7 October 2026. If the draft is made, the date change takes effect on 30 October 2026. The Scottish Government says the majority of the 2008 Regulations and the current EPC system would then remain in place until spring 2028, while lodgement fees still rise on 31 October 2026 as planned.
Three further points matter to commercial owners if the amendment is made:
- A building sold or let between 30 April 2028 and 30 April 2029 can keep using a valid EPC issued under the 2008 Regulations, until its first sale or letting in that period.
- Buildings that must display an EPC, meaning those the public visit at least weekly (public authority buildings over 250 square metres, and other buildings over 500 square metres that have an EPC), can keep an old-style certificate until it expires or until 30 April 2033.
- New buildings completed on or after 30 April 2028 need a new-style EPC and property report given to the owner within seven days of the completion certificate being submitted.
If the draft is not made, the 2008-rules transition in regulation 38 of the 2025 Regulations runs from 31 October 2026 instead.
Where is a Scottish commercial EPC registered?
The Scottish EPC Register holds EPCs, action plans, Display Energy Certificates and advisory reports, and has a separate search for EPC assessors, section 63 advisors and DEC assessors. It notes that central lodgement was phased in, so not every EPC is on it: non-domestic buildings sold or rented to a new tenant, and public buildings, are held from January 2013.
What does Scotland's commercial building stock look like?
The Scottish Government's 2018 baseline report, built on almost 30,000 non-domestic EPCs issued between January 2013 and July 2017, estimated 196,000 non-domestic heat controlled premises, excluding military and agricultural buildings. Retail and financial premises made up 32 per cent of them and offices and workshops 27 per cent. It put almost three in four premises at band E or worse, with 5 per cent at B or better.
Hospitality stood out: 86 per cent of hotels and 85 per cent of restaurants, cafes and takeaways were in band G, which the report put down to the model assigning more energy use to those activities. Only 16 per cent of storage and distribution premises were in band G, and 17 per cent were at B or better. These are 2018 findings under the current rating method, which the 2025 Regulations replace, so read them as background rather than a forecast.
Which cities and districts shape commercial EPC demand?
| Council area | Population, 30 June 2025 (NRS) | Commercial focus named by official sources |
|---|---|---|
| Glasgow City | 654,330 | International Financial Services District |
| City of Edinburgh | 531,370 | City centre heritage, Edinburgh Park |
| Aberdeen City | 230,180 | Energy Transition Zone, Altens |
| Dundee City | 148,390 | Dundee Waterfront |
Scotland's population was estimated at 5,545,500 at mid-2025.
Glasgow
Glasgow City Council says the International Financial Services District was launched in 2001 by the council and Scottish Enterprise to regenerate the Broomielaw and the west city centre, and has since expanded across a much wider area. In a multi-let office building, a floor or suite designed or altered for separate use is a building unit, and one of more than 1000 square metres is caught by section 63 when it is let to a new tenant.
Edinburgh
City of Edinburgh Council counts 50 conservation areas, and the Old and New Towns of Edinburgh joined the UNESCO World Heritage list in 1995. Historic Environment Scotland puts the national total at around 47,000 listed buildings. West of the centre, Edinburgh Park describes itself as home to some of Scotland's most established office occupiers.
Aberdeen
Invest Aberdeen describes the Energy Transition Zone as a 250-hectare site close to Aberdeen South Harbour, with an Energy Incubator and Scale Up Hub at Altens Industrial Estate as the anchor project of its innovation campus. Under the 2025 Regulations an EPC is required when a new property is constructed, so a new unit there needs one once it is finished.
Dundee
Invest in Dundee describes the Waterfront as 240 hectares stretching 8km along the River Tay, divided into five zones: Dundee Port, City Quay, Central Waterfront, Seabraes and Riverside.
The two Green Freeports
The Scottish and UK governments jointly announced two Green Freeports on 13 January 2023. The announcement said the Forth site includes the ports at Grangemouth, Rosyth and Leith, Edinburgh Airport and a site at Burntisland, and the Inverness and Cromarty Firth site includes the Ports of Inverness, Cromarty Firth and Nigg and Inverness Airport. The Scottish Government calls a Green Freeport a large zoned area that includes a railway, seaport or airport.
What changes just across the border in England?
Premises in Northumberland or on Tyneside follow the England and Wales rules, including the E minimum for covered lettings. See commercial EPCs in the North East and in Newcastle for that side of the border.
Commercial EPC questions in Scotland
Does a Glasgow landlord need EPC band E before letting an office floor?
No band E letting rule applies in Scotland, because it comes from regulations for England and Wales. A valid EPC is still needed when the floor is let. If the floor is a building unit of more than 1000 square metres, a lease to a new tenant also triggers a section 63 action plan.
Does an 800 square metre unit in Dundee need a section 63 action plan?
No. The section 63 regulations apply to non-domestic buildings and building units with a floor area of more than 1000 square metres. The unit still needs an EPC when it is sold or let.
Which EPC rules apply if I sell an Aberdeen building in November 2026?
That depends on whether the amending regulations are made. As at 22 October 2026 legislation.gov.uk lists them as a draft. If they are not made, the 2025 Regulations start on 31 October 2026 and an existing valid EPC can be used for the first sale or letting after that date, for a limited period.
Does the proposed EPC B standard for larger let buildings apply in Scotland?
No. The government's interim response of 18 June 2026 refers to private rented buildings over 1,000 square metres in England and Wales, and it needs secondary legislation before it takes effect. Scotland's reforms run through its own regulations.