While Propertymark broadly welcomes the proposed changes, further increases in charges should be avoided unless there are significant changes in circumstances. We have also stressed to the Scottish Government that ongoing monitoring and evaluation are critical to ensuring improvements deliver genuine benefits to consumers.
What are the key proposals?
Firstly, the statutory lodgement fee will increase by £3.49 for domestic and non-domestic EPCs. The Scottish Government asserts that this increase is necessary to fund improvements to the EPC regime, including strengthened governance arrangements for assessors and new assessment procedures.
Secondly, penalty charges will rise to £500 for domestic properties and £1,000 for non-domestic properties. The figures are higher than those proposed by the UK Government, which are £325 and £815, respectively to provide a stronger deterrent against non-compliance.
Impact on agents
Propertymark acknowledges the necessity of funding improvements to the EPC system, but we urge the Scottish Government to consider the economic challenges landlords and property agents face.
For remote areas such as the Scottish Highlands and Islands, properties often require more frequent EPC assessments due to unique heating systems and, increased fees could disproportionately impact property professionals operating in these areas.
Monitoring and enforcement must be effective
We strongly support reviews of the proposed changes within two years of the new regulations coming into force and have offered to work with the Scottish Government to support future reviews.
Our consultation response highlights the importance of ensuring local authorities have sufficient resources to enforce the standards effectively, as disparities could result in a postcode lottery of compliance across Scotland.
Next steps
The consultation represents the final stage of discussions before the new regulations are laid before the Scottish Parliament. Propertymark will continue to engage with Ministers and officials and provide support to ensure the effective implementation of the revised EPC regulations.
