Scotland introduces a Passivhaus equivalent standard for all new homes

As part of Scotland’s ongoing drive toward higher-performing, lower‑carbon homes, the Scottish Government has now set out its intentions for a significant update to Technical Handbook Section 6, including the retirement of SAP and a tightening of fabric performance requirements. This decision is part of a wider consultation that is ongoing, but it could mean one of the most consequential regulatory shifts in years, reshape how homes are designed, modelled, and assessed across the UK.

While the finer points of the new standard will be confirmed later in 2026, the Government has already committed to a firm ‘Go Live’ date of 31 March 2028. This gives the industry a defined runway for preparation, testing, and adaptation, something we know our clients value as they plan future projects.

SAP and HEM

In alignment with England and Wales, Scotland intends to retire SAP as the approved compliance tool for new homes. The consultation highlighted concerns among respondents that HEM was untested, and more work was needed on tools.

However, Scotland is taking a distinctive path by proposing PHPP—the Passive House Planning Package—as an alternative route to compliance. Consultation response were overall positive views of PHPP as a calculation tool

PHPP is the calculation engine behind the Passivhaus standard, renowned for its precision and its focus on ultra‑low energy demand. What remains unclear is how “Passivhaus‑aligned” the Scottish compliance route will ultimately be. Targets, thresholds, and modelling rules are still under development, so the strength of the commitment will only become apparent once those numbers are published.

Delivered Energy and Space Heating

Scotland intends to keep the Delivered Energy Rate (DER) as its main compliance metric, a notable change given that the Target Emission Rate (TER) has already been phased out there. Officials are also considering replacing the Notional Recipe with a single absolute benchmark for all home, a significant shift that could streamline comparisons, though it’s still under review.

A second metric, the Space Heating Rate, is being explored to emphasise fabric performance and heating efficiency. It will differ from Wales’s proposed Energy Use Intensity approach, so cross‑border assessors will need to track the methodological nuances.

Other Key Updates:

• Air Tightness: Scotland will introduce a maximum air‑test target, bringing it in line with England and Wales’ 8 m³/m²·h limit, though the exact figure is still pending.
• Ventilation: Mandatory MVHR is no longer being considered; any system that meets airflow and energy standards will remain acceptable.
• Overheating: Section 3 will be reviewed later this year, reflecting the broader UK focus on managing climate‑driven overheating risk.

Consultation Insights

The Government’s Part 2 response reflects broad agreement that “equivalent” standards do not necessarily mean mandating Passivhaus for all new homes. Instead, the emphasis is on robust, reliable compliance tools that accurately represent building services and fabric performance.

To that end, Scotland will collaborate with the Passivhaus Trust and research partners to adapt PHPP for use as a Building Regulations compliance tool—ensuring it is fit for purpose well before the 2028 implementation date.

Industry Impact

Scotland is clearly shifting toward a fabric‑first, performance‑driven regulatory approach. The move away from SAP signals a major change in how homes will be modelled and delivered, even as final details are still to come.

The CBC sustainability team are monitoring updates closely and will continue translating emerging guidance so clients can plan with confidence. With significant changes ahead, early preparation will be essential so please do contact us with your questions.