1 April 2028 – New Tenancies Must Meet HRR Band C

The countdown to Scotland’s new Heat Retention Rating (HRR) standards has begun. From 1 April 2028, landlords will only be able to grant new tenancies if their property achieves HRR Band C or higher. This new rule forms part of Scotland’s wider move toward improving energy efficiency, reducing emissions, and ensuring rented homes are comfortable, warm, and affordable for tenants.

Understanding the HRR Standard

The HRR, or Heat Retention Rating, is a new way of assessing how well a home retains heat. It will gradually replace the current Energy Performance Certificate (EPC) system used across the UK. While EPCs mainly measure estimated running costs, HRR focuses on how effectively a property keeps heat in once generated.

This new approach provides a clearer picture of a home’s actual energy performance and helps landlords and tenants understand where improvements are needed. For landlords, meeting HRR Band C will soon be a legal requirement for new lets, making preparation essential.

According to current government guidance, the HRR (Heat Retention Rating) framework is expected to be rolled out across the UK by 2026, gradually replacing EPCs as the main measure of home efficiency.

Why the 2028 Deadline Matters

The 1 April 2028 milestone is not just a guideline, it’s a firm legal threshold. From that date onwards, landlords cannot grant a new tenancy unless the property meets at least HRR Band C.

Properties rated below Band C will be classed as “substandard” and will not meet the minimum letting standard. This could mean delays in finding new tenants, reduced rental income, or potential enforcement action if landlords attempt to let a non-compliant property.

The 2028 deadline is designed to encourage early action, giving landlords several years to plan and implement energy upgrades before the rule comes into force.

What Landlords Should Do Now

Landlords should treat 2028 as the first major checkpoint in Scotland’s energy efficiency roadmap. The final compliance deadline for all properties comes later in 2033, but by preparing now, landlords can spread upgrade costs and avoid disruption when the regulation takes effect.

Here are some practical steps to take:

• Check your current EPC rating: This provides a useful benchmark to understand where your property stands before the HRR system launches.

• Plan an energy audit: An independent assessment can highlight areas of heat loss and prioritise improvements such as insulation, glazing, or heating systems.

• Budget and phase upgrades: Consider tackling the biggest efficiency gaps first, such as loft insulation or double glazing, and build from there.

• Keep records of improvements: Maintaining documentation will help demonstrate compliance and protect you in future inspections.

• Stay informed: Follow government announcements to keep up to date with any changes, exemptions, or financial support schemes.

Expected Costs and Financial Support

Regulatory assessments suggest that meeting HRR Band C will involve an average investment of £1,400 to £2,700 per property, depending on the building’s size, structure, and condition. However, landlords can access support through schemes such as Home Energy Scotland, which provides grants and interest-free loans for approved upgrades.

To support landlords, a cost cap of around £10,000 per property has been proposed, meaning you will not be expected to exceed that amount. Financial assistance may be available through schemes such as Home Energy Scotland, which provides interest-free loans and grants for approved energy improvements.

Common Upgrades to Reach Band C

Every property will require different measures to achieve HRR Band C, but the most common improvements include:

• Upgrading loft, wall, and floor insulation

• Replacing single glazing with double or triple glazing

• Draught proofing to minimise heat loss

• Installing energy-efficient heating systems or heat pumps

• Enhancing ventilation to maintain indoor air quality

Making these changes will not only ensure compliance but can also make your property more appealing to tenants who increasingly value energy-efficient homes.

What Happens if You Don’t Comply

Failure to meet the HRR Band C requirement by April 2028 means you cannot legally start a new tenancy. Local authorities may impose penalties for non-compliance, and continued failure could affect your landlord registration.

For landlords with multiple properties, this may require careful planning and phased upgrades to ensure each property reaches the required standard before it can be re-let.

FAQs: HRR Band C Compliance for 2028

Q: Will existing tenants be affected in 2028?
A: No. The 2028 rule applies only to new tenancies. Existing tenancies have until the 2033 deadline to comply.

Q: Can I still renew a tenancy agreement if my property is below Band C?
A: Renewing a tenancy is generally treated as a continuation, but creating a brand-new tenancy for a new tenant will not be permitted unless the property meets HRR Band C.

Q: How long will the new HRR assessment last?
A: Like EPCs, HRR certificates are expected to remain valid for ten years, though landlords should reassess after major property upgrades.

Q: Will there be exemptions?
A: Some properties, such as listed buildings or those with structural limitations, may qualify for exemptions. Details will be confirmed in the final legislation.

Preparing for a Sustainable Future

The introduction of the HRR Band C requirement marks a major turning point for Scotland’s private rented sector. It challenges landlords to invest in their properties now to avoid disruption later. By acting early, you can secure compliance, maintain steady rental income, and provide homes that are both energy efficient and desirable to tenants.

For more guidance on preparing your property for the 2028 HRR standard, get in touch with Cairn to speak to our property experts.