The 1st of April 2028 might seem like a distant thought, but for Scottish landlords it’s a date that will be on your doorstep before you know it. From that date, new tenancies will only be granted if a property meets a Heat Retention Rating (HRR) Band C or above. Existing tenancies aren’t affected until 2033, but 2028 is the first checkpoint and will affect thousands of homes across Scottish landlord portfolios. Waiting until the final months to upgrade is a gamble; as the deadline nears, the surge in demand for qualified tradespeople will inevitably drive up costs and create significant scheduling bottlenecks across Scotland.
What Is a Heat Retention Rating?
The current EPC framework is getting an overhaul designed to provide a more accurate understanding of a home’s energy performance and how it retains heat and highlight which improvements have the greatest benefit.
It will consist of three new ratings, Heat Retention Rating (HRR), Heating System Rating and Energy Cost Rating, as part of the Energy Performance of Buildings (Scotland) Regulations 2025. They’ll be phased in through transitional arrangements from autumn 2026.
HRR Band C: What Is Changing?
From 1 April 2028, landlords will only be able to grant new tenancies on properties that achieve HRR Band C or higher. It’s not all doom and gloom, the Scottish Government’s rating bands should broadly align with the current EPC Band C rating. So it means that if your property already claims an EPC rating of C, it has a good chance of remaining compliant. But for those whose properties fall beneath, read closely…
What’s new:
- HRR looks at how well a property actually keeps heat in, not just what it’s predicted to cost to run.
- New EPCs issued from October 2026 will include updated ratings and targeted improvement suggestions.
- The government is tightening standards and oversight for assessors, making the new system more reliable and giving landlords and tenants greater confidence in the results.
Why Does the Heat Retention Rating Matter for Landlords?
Under the new rules:
- You will not be able to grant a new tenancy on a property below HRR Band C from April 2028.
- Properties below this standard will likely face delay or local authorities may impose penalties for non-compliance, and continued failure could affect your landlord registration.
- Existing tenancies are not immediately affected, but will be expected to meet these standards by 2033.
The earlier you address any potential issues, the more you can spread cost and avoid last minute challenges.
What Should Landlords Do Now?
It’s time to ask yourself the following questions:
- What’s the property’s current EPC?
- Where is heat being lost, and should I commission an energy assessment or fabric audit to identify priority improvements?
- Which upgrades make the most sense to phase in first, insulation, glazing or heating efficiency?
- Have I set a realistic budget and timeline to spread costs ahead of the 2028 deadline?
- Am I keeping clear records of improvements for future certification and compliance checks?
- Are there any grants or interest-free loans available to me through schemes? (Check out Home Energy Scotland).
April 2028 is only two years away and the impact on rental income and void periods could be significant if your properties aren’t up to standard. Planning now gives you more control and far fewer nasty surprises later, which we all prefer to avoid.
At Ascension Letting, we help landlords plan for regulatory change, protect income and maintain a high standard of lettable, energy-efficient homes. If you would like support preparing for HRR compliance, we’d be happy to discuss it with you further. Reach out to our team today.
