If you own rental property in Aberdeen, the timetable for EPC reform has changed. The Scottish Government has announced that the new certificate framework will be delayed from 31 October 2026 to 30 April 2028, with most of the existing EPC system remaining in place until then. For landlords with one property or a substantial portfolio, understanding the distinction between certificate reform and proposed minimum rental standards is essential.
As October 2026 progresses and colder weather approaches, now is a sensible time for Aberdeen landlords to review their properties’ energy performance, consider practical improvements and prepare for future requirements without assuming that proposed standards are already legally enforceable.
This is not an English issue. The Renters’ Rights Act’s main tenancy reforms apply to England; Scottish landlords operate under Scotland’s separate tenancy framework. Scotland has its own legislative path, and Aberdeen’s distinctive housing stock means local landlords may face particular challenges when planning energy efficiency improvements.
What is changing in Scotland’s EPC timetable?
The Energy Performance of Buildings (Scotland) Regulations 2025 provide for reformed certificates, including a Heat Retention Rating (HRR), alongside other metrics. Most of the new framework is now planned to take effect on 30 April 2028, rather than replacing the current certificates in October 2026.
The HRR is intended to focus specifically on how well a property retains heat, providing information about its fabric energy performance. For tenants concerned about heating costs, this could provide useful additional information. For landlords, the proposed metric is intended to inform future energy efficiency standards.
The key deadlines you need to know
The proposed Minimum Energy Efficiency Standards (MEES) under the new framework have been discussed around two important milestones:
New tenancies: The consultation proposed HRR Band C from 2028, but the final start date remains unconfirmed following the delay to EPC reform.
Existing tenancies: The consultation proposed extending the standard to all privately rented homes by the end of 2033, subject to final regulations and exemptions.
These remain proposals, with the final minimum-standard timetable still to be confirmed. Properties with lower energy efficiency ratings may require improvements if the proposed standards are introduced.
For Aberdeen landlords, October 2026 offers an opportunity to begin reviewing property condition, insulation and heating performance before winter while allowing time to plan for future changes.
Why Aberdeen landlords face a harder challenge than most
Aberdeen is not like Edinburgh or Glasgow. The city’s architectural identity is defined by its granite, a beautiful and enduring building material that can present particular challenges when it comes to energy efficiency.
The granite wall problem
Many traditional tenement flats across AB25 (Rosemount and Kittybrewster), AB10 (the West End) and AB24 (Old Aberdeen) feature solid stone construction, including granite. Unlike conventional cavity walls, these structures generally require different approaches to insulation.
The two main options, external wall insulation (EWI) and internal wall insulation (IWI), can involve significant cost, disruption and technical considerations.
External wall insulation may alter a building’s appearance and require planning approval or agreement from other owners. Internal wall insulation can reduce usable floor space and may require substantial redecoration.
In tenement blocks, shared ownership arrangements can introduce further complexity, particularly where proposed works affect common parts or the external building fabric.These challenges can affect landlords with traditional properties around Rosemount Viaduct, Westburn Road, King Street and parts of Old Aberdeen.
For October 2026, the practical priority is to understand the construction of each property before committing to improvements. Specialist advice can help identify suitable options while reducing the risk of moisture-related problems or inappropriate alterations.
Conservation area constraints
A further layer of complexity applies to properties within Aberdeen’s designated conservation areas, including parts of Old Aberdeen near King’s College and the historic West End.
Planning restrictions may limit the type of external modifications permitted, particularly where changes could affect the character or appearance of a historic building.
Landlords considering insulation, replacement windows or other visible alterations should establish whether planning permission, listed building consent or other approvals are required.Where future minimum energy efficiency standards provide for exemptions or alternative compliance arrangements, the final rules will determine how technical and planning constraints are assessed.
Understanding the ‘feasibility’ clause
The proposed Scottish rental standard includes exemptions and feasibility considerations, but the final requirements and timetable are not yet settled.
For landlords with granite-built properties, obtaining qualified advice on appropriate improvements is a sensible first step. This may involve reviewing the building’s construction, assessing potential insulation methods and identifying any conservation or shared ownership restrictions.
Keeping records of surveys, contractor recommendations and relevant planning advice could support future decisions.Aberdeen City Council continues to oversee existing landlord obligations, but the enforcement arrangements and penalties for any future HRR minimum standard will depend on the final regulations.
The proposed HRR Band C requirement should not be treated as an enforceable minimum standard in October 2026.
The broader Scottish regulatory picture
The EPC and HRR changes sit within a wider landscape of Scottish landlord regulation. Landlords in Aberdeen should also be aware of several existing responsibilities and legislative developments.
Housing (Scotland) Act 2025: Scotland’s housing reforms include provisions relating to rent controls and tenancy protections, with different measures subject to their respective commencement arrangements. Landlords should monitor official guidance to understand which requirements are in force.
Landlord Registration Scotland: Private landlords must generally register with their local authority unless an exemption applies. Aberdeen landlords should ensure their registration details remain accurate and renew their registration when required.
Tenancy deposit protection: Where a deposit must be protected, landlords must use a Scottish Government-approved tenancy deposit scheme and comply with the applicable protection and information requirements. SafeDeposits Scotland is one of the approved schemes.
These responsibilities are separate from the proposed HRR requirements. Meeting current obligations while preparing for possible future energy efficiency standards can help landlords maintain appropriate property management practices.
What Aberdeen landlords should do right now
Step 1: review your current EPC
If your property has an existing EPC, check its rating, recommendations and validity.
The reformed HRR framework is not yet operational, so landlords should not assume they can commission an official new-format HRR certificate in October 2026.
Instead, use the existing EPC as a starting point and consider obtaining specialist energy efficiency advice where the property’s construction makes improvements more complicated.
Step 2: understand your upgrade options
For granite properties, this means getting specialist advice on wall insulation, roof insulation, glazing and heating system improvements.
October is a particularly useful time to check heating systems, identify draughts and address maintenance concerns before winter.
Landlords with multiple properties may benefit from reviewing their portfolio as a whole, identifying which buildings could require more extensive work and prioritising improvements based on condition, technical suitability and available budgets.
Step 3: plan for the April 2028 deadline
The revised 30 April 2028 date relates to the planned introduction of the reformed EPC framework. It should not be interpreted as a confirmed deadline for every private rental property to achieve HRR Band C.
If you are planning a new let, ensure that the property meets the current applicable requirements and consider whether practical improvements would benefit tenants and support future compliance.
Early planning can also provide more flexibility when obtaining surveys, comparing quotations and arranging contractors.
Step 4: document everything
Whether you are proceeding with upgrades or considering how future exemptions might apply, thorough documentation is valuable.
Keep copies of EPCs, surveys, contractor quotations, maintenance records, planning correspondence and any relevant technical assessments.
These records can help you understand your property’s condition, demonstrate compliance with existing obligations and prepare for future regulatory requirements once the final rules are confirmed.
How Martin & Co Aberdeen can help
Navigating EPC reform, energy efficiency assessments, tenancy legislation and local authority requirements can be a significant undertaking, particularly for landlords managing traditional granite-built properties.
This is where working with an experienced, compliance-focused letting agent can make a difference. Martin & Co Aberdeen has been supporting landlords across the city for over 30 years. Our team understands the particular challenges of Aberdeen’s traditional housing stock, the requirements of Scottish lettings legislation and the practical steps involved in maintaining rental properties.
As part of the Martin & Co national network, our Aberdeen team combines local knowledge with the resources of an established lettings brand. We support landlords with property management, maintenance, tenancy administration and compliance responsibilities, helping them stay informed as requirements evolve.
Our fully managed service provides a local point of contact who understands your property, your portfolio and the Aberdeen rental market. As October 2026 brings the colder months closer, our team can also help landlords review their property management arrangements and consider practical steps to maintain suitable rental accommodation.
Ready to make sure your Aberdeen property is compliant?
The delay to Scottish EPC reform gives landlords more time to prepare, but Aberdeen’s granite housing stock can still present real challenges when planning energy efficiency improvements.
October 2026 is a sensible time to review your current EPC, assess heating and insulation performance, and consider suitable improvements before winter.It is also important to distinguish between existing legal obligations and future proposals, particularly while the Scottish Government finalises the timetable for minimum energy efficiency standards.
Get in touch with Martin & Co Aberdeen today to discuss your property’s compliance position and the practical steps you may wish to consider. Our team is ready to help you navigate changing requirements with confidence.
Book a free rental valuation to understand your property’s current market position and discuss how energy efficiency, property condition and future regulatory developments could influence your letting strategy.
