2033 Deadline – All Scottish Rentals Must Reach HRR Band C

Scotland’s journey toward greener, more energy-efficient housing continues with a key milestone on the horizon. By 31 December 2033 (sometimes cited as 1 April 2033), all rental properties, including existing tenancies, must achieve a minimum Heat Retention Rating (HRR) Band C.

This is the final stage of the government’s phased approach to improving energy performance across the private rented sector. For landlords, it represents a clear deadline to ensure that every property in their portfolio meets the new national standard.

The Shift from EPC to HRR

The Heat Retention Rating (HRR) is part of a reformed Energy Performance Certificate (EPC) system. Instead of focusing on estimated running costs, HRR measures how effectively a home retains heat, offering a more practical assessment of real-world energy efficiency.

By 2033, all Scottish rental homes will need to meet HRR Band C. Properties rated below this level will be considered “substandard” and cannot legally be let.

This move aligns with Scotland’s long-term net zero targets, aiming to reduce carbon emissions and improve the quality of housing available to tenants.

A Gradual Transition with Clear Milestones

The HRR rollout begins in autumn 2026, when new EPCs featuring the updated metric will become available. Then, from 1 April 2028, landlords will be prohibited from granting new tenancies for properties below Band C.

The final milestone arrives in 2033, when this standard will apply to all tenancies, including those already in place. This ensures that by the end of the decade, the entire private rented sector will have reached a consistent baseline for energy efficiency.

Landlords who plan ahead can manage improvements gradually and cost-effectively over several years, ensuring smoother compliance.

Why the 2033 Deadline Matters

While 2033 may seem distant, it is closer than many landlords realise when considering the work involved. Improving a property’s HRR can take time, especially for older buildings with limited insulation or outdated heating systems.

Delaying upgrades risks a rush of demand closer to the deadline, potentially leading to higher costs, longer waiting times for contractors, and difficulties finding tenants for non-compliant homes.

By taking a phased approach, landlords can spread the financial and practical workload over several years, making compliance more manageable.

Typical Costs and Support Options

Government assessments suggest that bringing a property up to HRR Band C could cost between £1,400 and £2,700, depending on the size, age, and condition of the building.

To limit financial pressure, a cost cap of around £10,000 per property is expected to apply. This means landlords will not be required to spend beyond this cap to reach compliance.

Financial support is available through initiatives such as Home Energy Scotland, which offers grants and interest-free loans for approved improvements, including insulation, efficient heating systems, and renewable technologies.

Upgrades to Help Reach HRR Band C

Achieving HRR Band C typically requires improvements to insulation, heating, and building fabric. Common measures include:

• Loft and roof insulation: Reduces heat loss from the top of the property.

• Wall and floor insulation: Improves overall heat retention.

• Upgraded windows and doors: Double or triple glazing helps prevent draughts.

• Modern heating systems: Replacing old boilers or installing heat pumps can boost efficiency.

• Air tightness and draught proofing: Keeps warm air in and cold air out.

Landlords should also consider the long-term benefits of these improvements, such as lower maintenance costs, enhanced tenant comfort, and increased property value.

How to Prepare for 2033

With a clear timeline in place, landlords should begin planning now to ensure compliance well before the 2033 deadline. A structured approach can make the process straightforward and cost-effective.

Here’s how to start:

1. Assess current performance: Check your property’s EPC and identify potential weak points.

2. Prioritise upgrades: Focus on the most impactful improvements first, such as insulation or heating.

3. Create a long-term plan: Spread works over several years to manage costs and minimise disruption.

4. Document progress: Keep records of all work, receipts, and certificates for compliance verification.

5. Stay informed: Regulations may evolve, so continue monitoring government updates and local council guidance.

Proactive landlords who act early will have more flexibility to choose the right improvements and contractors, avoiding the challenges of a last-minute rush as 2033 approaches.

FAQs: The 2033 HRR Band C Deadline

Q: Does the 2033 rule apply to existing tenants?
A: Yes. By 31 December 2033, all tenancies, including those that began before the new rules, must meet HRR Band C.

Q: Can I sell a property that does not meet the HRR Band C requirement?
A: Yes, you can still sell, but buyers will need to ensure compliance before letting it to new tenants after the deadline.

Q: What happens if my property cannot reach Band C due to structural limits?
A: Some properties, particularly listed buildings, may qualify for exemptions. Details will be set out in the final legislation.

Q: Will there be penalties for non-compliance?
A: Landlords who fail to meet the standard could face enforcement action, including fines or restrictions on letting the property.

A Long-Term View for Scottish Landlords

The 2033 HRR Band C requirement represents a significant step in modernising Scotland’s housing stock. It ensures that all tenants can live in warm, efficient, and sustainable homes while supporting the country’s environmental goals.

For landlords, the key is preparation. Starting upgrades early will make compliance easier, preserve rental income, and maintain the long-term value of your portfolio.

For advice on preparing your properties for the 2033 HRR standard, get in touch with Cairn to speak to our property experts.