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Energy efficiency regulations in the PRS

By: Shelter Scotland  Published: September 2019

Shelter Scotland's response to the consultation on energy efficiency regulations in the private rented sector.


Shelter Scotland strongly supports the policy proposal behind the regulations to improve the energy efficiency of Scotland’s private rented sector homes. Under the proposal, landlords of privately rented homes will be required to ensure their properties achieve EPC Band E from 1 April 2020 at a change of tenancy, and then EPC Band D from 1 April 2022 at a change of tenancy, followed by a backstop date of 2025 for all properties regardless of tenancy change. The latest figures show that around a quarter of all private rented stock is below the proposed EPC standards and therefore stand to be improved by the new regulations. Currently, 360,000 households rent privately, with many there because they have been priced out of owner occupancy or because there is limited socially rented stock available. There is no justifiable reason that private tenants should be subjected to poorer property conditions than their peers in the social rented sector. Efforts to tackle fuel poverty by removing or mitigating the effects of energy inefficiency in the home are welcomed. Everyone, no matter what tenure they live in, should have the right to a safe, warm and affordable home.

Our consultation response does highlight some outstanding questions about achieving compliance with the regulations to ensure that this right is realised in practice. A clear route for tenants to enforce their rights as well as well-resourced enforcement bodies (in this instance, proposed to be local authorities) is essential for success. However, good awareness raising, support and advice for both tenants and landlords to encourage compliance is essential, as is supporting local authorities to be in a position to take a proactive approach. These factors will support good compliance as well as reducing the need for burdensome enforcement processes.