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Legal insights & industry updates

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Interim guidance for social landlords during the review of the Energy Efficiency Standard for Social Housing post 2020 (EESSH2)

The Scottish Government has released its interim guidance on what measures should be taken by social landlords during the review of EESSH2. The review commenced in September 2022 and is expected to take around nine months to complete. Following the completion of the review, the final proposals for a new target will be submitted for consideration by Scottish Ministers.

One of the key points highlighted by the guidance is that the 2025 and 2032 EESSH milestones are temporarily on hold.

What are the 2025 and 2032 EESSH Milestones?

2025: By 31 December 2025, no social housing is to be re-let below EPC Band D, and no energy efficiency improvements should worsen either the environmental impact rating or the air quality of a  of a home.

2032: By 31 December 2032, all social housing should meet, or can be treated as meeting, EPC Band B, or is as energy efficient as practically possible, within the limits of cost, technology and necessary consent.

So, what does "on hold" mean?

The Scottish Government advises the 2020 EESSH1 milestone continues to apply but, as it stands, social landlords are not required to show their stock meets EESSH or is progressing towards EESSH2 milestones in their performance reporting for 2023 and 2024.

Throughout the period of the review, social landlords are not required to report to the regulator on either the 2025 or 2032 milestones.

The Scottish Housing Regulator has paused its collection of EESSH2 data until after the conclusion of the review and for now, the focus will be on the quality of housing condition information and the effectiveness of asset management strategies.

Social landlords are however encouraged to continue to collect energy efficiency data for their own use on matters including the EPV banding of each property within their housing stock and the value of investment in energy efficiency improvements throughout the review period.

The guidance gives social landlords an action plan to bear in mind throughout the review period, noting that priority should be given to what has the biggest impact for the lowest cost. The following areas should be prioritised: 

  • Fabric first - measures to improve thermal efficiency and heat loss, and any associated ventilation required;
  • Measures that use zero emission electrical heating;
  • Reducing the energy use of the property (kWh/m2 /year);
  • Projects for connecting to district heating;
  • Projects for communal heating systems;
  • Projects that make a significant difference to hard-to-treat properties; and
  • Projects that help to model the actual performance of new technologies, their impact on buildings, and their use by tenants; 
  • Improving data collection and management.

The guidance highlights that the Scottish Government recognises the additional pressures on existing programmes due to recent rises in inflation and the impact of increased costs for installers and materials as well as existing commitments for maintenance and repair of housing stock. 

It seems that the general message from the guidance is that the pressure is off somewhat in relation to the obligation to report throughout the review period. Social landlords should continue to monitor progress and seek funding opportunities to achieve their action plans for improvement of their existing housing stock and providing additional energy-efficient socially rented homes.

Landlords and tenants are under exceptional financial pressure in the current climate, but the suspension of EESSH2 milestones must not be used as a rationale for non-investment in the improvement of housing stock.


housing, local government