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EPC Reform Delayed & Housing (Scotland) Act 2025: What Landlords Need to Know

  • Writer: Sean McMahon
    Sean McMahon
  • 50 minutes ago
  • 4 min read

Landlords across Scotland have been watching the regulatory landscape closely over the past few years, particularly when it comes to energy efficiency rules and changes to tenancy legislation.


There have now been two important updates which every landlord should be aware of:


  1. A delay to EPC reforms

  2. New implementation dates for parts of the Housing (Scotland) Act 2025



As someone who has worked in property sales, lettings and management for over 35 years, I know how confusing these constant regulatory updates can feel. So here is a simple breakdown of what’s happening and what it means for landlords right now.


EPC Reform Delayed in Scotland

Delay to EPC Reform in Scotland



The UK Government has announced a delay to the introduction of new Energy Performance Certificate (EPC) reforms until the second half of 2027.


As a result, Scotland will no longer introduce the new EPC format on 31 October 2026, as previously planned.



What this means for landlords



For now:


  • The current EPC system will remain in place until further notice

  • There will be no immediate change to EPC certificates

  • The new EPC design and scoring system will not arrive in 2026



This delay also raises questions about the proposed minimum energy efficiency standards for rental properties.


Previously proposed dates were:


  • 2028 – minimum energy standards for new tenancies

  • 2033 – minimum energy standards for all PRS properties



However, with EPC reform delayed, many industry experts now believe these deadlines could also move further back.



Why this matters



Landlords have been concerned about the potential cost of upgrading properties, particularly older homes common across Edinburgh, Leith, Portobello and South Queensferry.


The delay provides more breathing space for planning improvements, rather than rushing expensive upgrades based on uncertain legislation.



Housing (Scotland) Act 2025 – Implementation Timeline



The Housing (Scotland) Act 2025 was approved by Parliament last year, but many of its provisions will not come into force immediately.


The Scottish Government has now published initial implementation dates for some measures.


Here are the key dates landlords should know.




Housing (Scotland) Act 2025 implementation timeline

1 April 2026 – Rent Control Framework Introduced


From 1 April 2026, Scotland will introduce the legal framework that allows rent control areas to be created in the future.


Local authorities will be required to:


  • Conduct Rent Condition Assessments

  • Submit findings by May 2027



Only after this process could the Scottish Government introduce rent control areas.



What this means right now



For the moment:


  • Landlords can still set rents at market value for new tenancies

  • Mid-tenancy rent increases remain allowed under current rules



In other words, nothing changes immediately for most landlords.


Any rent control zones are unlikely to appear before late 2027 at the earliest.



6 October 2026 – Changes to Wrongful Termination Orders



From 6 October 2026, the penalties for wrongful termination of a tenancy will increase significantly.


A Wrongful Termination Order (WTO) applies if a tenant believes they were misled into leaving a property based on an eviction ground that did not apply.


Currently, the tribunal can award a fine of:


  • 0–6 months rent



From October 2026, this will increase to:


  • 3–36 months rent



However, it’s important to note:


  • WTO cases are very rare

  • Tribunals often find no wrongdoing by landlords



6 October 2026 – Changes to Tenancy Succession



There will also be changes to tenancy succession rules following the death of a tenant.


Currently:


  • A partner, family member or carer must have lived in the property for 12 months before the tenant’s death to inherit the tenancy.



From October 2026:


  • This qualifying period will reduce to 6 months.



Again, these cases are fairly uncommon, so most landlords will not experience this in practice.



1 April 2027 – Rent Increase Appeals Change



From 1 April 2027, there will be an important change when tenants challenge rent increases.


Currently:


  • A Rent Officer can set the rent above the landlord’s proposed increase if they believe the market rent is higher.



From April 2027:


  • The Rent Officer cannot set the rent higher than the landlord’s proposed amount



They must:


  • Assess market value

  • But cap the rent at the figure the landlord proposed



This removes the risk of a tenant appealing and accidentally increasing their own rent further.



Ending Joint Tenancies – Also Changing in 2027



Another change arriving on 1 April 2027 relates to joint tenancies.


Currently:


  • All tenants must agree to end the tenancy.



Under the new rules:


  • One joint tenant will be able to end the tenancy for all tenants.



Detailed guidance is expected closer to the implementation date.



Changes Still to Come



Some parts of the Housing (Scotland) Act 2025 do not yet have implementation dates, including:


  • Rules preventing landlords unreasonably refusing pets

  • Allowing tenants to personalise the property

  • Preventing rent increases during the first 12 months of a tenancy

  • Powers to convert Assured and Short Assured Tenancies into Private Residential Tenancies



Further updates are expected over the next year.



What Edinburgh Landlords Should Do Now



Despite all the headlines, very little changes immediately for landlords.


The key takeaway is that most of these reforms are still years away.


However, this is exactly why professional advice and good property management are more important than ever. We're planning ahead with our landlords, for our landlords.


At The Letting Experts, we help landlords stay compliant while maximising rental income. Contact me, Sean McMahon, for a FREE review of your property rental. I can aim to save you money, keep you compliant and maximise your investment.


Our service includes:


✔ Clear communication 7 days a week – including evenings

✔ Secure PayProp rent collection and fast landlord payments

✔ Transparent service with no hidden fees

✔ Membership of The Property Redress Scheme

✔ Over 35 years of property industry experience



Get My EPC Reform Fact Sheet



If you would like a simple guide explaining EPC reforms and upcoming rental regulations, I’ve created a quick landlord fact sheet.


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