Net Zero and Decarbonisation in Scottish Housing

By Luke Beard · 10 December 2025

Estimated reading time: 7 minutes

On International Human Rights Day (10 December), it’s important to remind ourselves that all tenants and residents, irrespective of tenure, have the right to an adequate standard of living, in homes that are well maintained, safe, and affordable.

Recently the Scottish Housing Regulator (SHR) revealed the stark reality that fewer than one in three registered social landlords (RSLs) in Scotland have made financial provision for net zero. Present estimated costs of £28,000 per flat and £42,000 per house mean that a total sector bill is projected to be between £4.6 billion and £9.3 billion. The impact of this on tenants and residents living in warm and affordable homes cannot be underestimated

Uncertainty around the Scottish Government’s proposed Social Housing Net Zero Standard, which will replace current energy efficiency standards, has led many landlords to delay planning which potentially risks compressed timelines, higher costs, and missed funding opportunities later.

The benchmark set out in 2023 requires:

• EPC rating of B by 2040
• Removal of fossil fuel heating by 2045

These targets are ambitious, and expensive. While ministers acknowledge the need for public investment, Scotland’s capital budget is under pressure, and private finance will have to play an expanding role. Social landlords need robust investment plans to navigate this landscape and deliver high quality homes for their tenants and residents.

Looking across the UK, Scotland’s challenge becomes even clearer. While Scotland has a slightly higher proportion of homes rated EPC C or above compared to England and Wales, it remains some way off achieving the required EPC B standard by 2040. England and Wales are working toward EPC C by 2030, supported by significant funding streams such as the Social Housing Decarbonisation Fund (SHDF) and the Optimised Retrofit Programme (ORP). These initiatives have already delivered thousands of upgrades—England’s SHDF Wave 2.1 improved around 30,000 homes, and Wales’ ORP has supported more than 13,000 homes since 2020.

The Cost of Retrofit in Scottish Housing

The financial gap is stark. In England, grants typically range from £7,500 to £15,000 per home, while Welsh ORP funding averages £8,500 to £20,000. Scotland’s estimated costs of £28,000 to £42,000 per home dwarf these figures, leaving landlords with a significant shortfall. This is compounded by the fact that Scottish social tenants already spend around 38% of their income on housing costs—almost half for the lowest income households—making affordability a critical concern. With average UK energy bills sitting at £1,720 per year, improving energy efficiency isn’t just about compliance; it’s about reducing fuel poverty and protecting tenants.

So what should Scottish Social Landlords be doing now?

Drawing on lessons from other decarbonisation projects, here are six practical actions to take immediately:

1. Shape the Funding Framework

Don’t wait for the rules—help write them.
When future consultations or feedback opportunities arise, Scottish landlords should continue to provide input to ensure funding models reflect real delivery challenges. England’s early SHDF waves were rigid, but later rounds became more flexible thanks to sector feedback.

2. Build Delivery Capacity Early

Successful programmes in Wales and England show that coordination is critical. ORP allocates up to 10% of funding for project management, modelling, and tenant liaison. Scottish landlords should continue to secure retrofit coordinators, assessors, and delivery partners now, to avoid bottlenecks later.

3. Engage Tenants Proactively

Tenant refusal rates in England reached 40% in some projects due to poor communication. Wales overcame this with resident workshops and dedicated liaison officers. Scottish landlords should start engagement early—use newsletters, door-knocking, and co-design sessions to build trust and reduce disruption concerns. Our recent work with Ardenglen HA demonstrates the importance of having a fit for purpose customer engagement strategy.

4. Strengthen Supply Chains

Both SHDF and ORP faced delays due to limited contractor capacity. Welsh landlords mitigated this by working with local SMEs and hosting supply chain engagement events. Regional collaboration on procurement frameworks and support skills development to ensure labour availability will grow in significance. Partnership working is critical.

5. Use Data to Drive Decisions

ORP success relied on property-level EPC data and archetype modelling to target measures efficiently. England’s SHDF evaluations highlight the same. Scottish landlords should continue to update stock condition survey data, and identify priority homes, and model costs under different retrofit scenarios to inform funding bids.

6. Embed Technical Standards

Early adoption of PAS roles (Coordinator, Assessor) and whole-house retrofit principles will streamline delivery and avoid costly rework. Investment in existing and new staff will contribute to ensuring your success.

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Planning is key

If there’s one clear takeaway from the lessons learned in England and Wales, it’s this: planning is everything. Funding will remain competitive, standards will tighten, and costs will rise, but landlords who prepare now will be in the best position to deliver.

This means planning in four key areas:

• Plan for Better Data
  Gather accurate stock condition and EPC data. Without this, it’s impossible to model costs, prioritise homes, or build credible funding bids.
  
• Plan for Delivery
  Secure retrofit coordinators, assessors, and supply chain partners early. Utilise frameworks for procurement and consider collaborative approaches to achieve economies of scale.
  
• Plan for Upskilling
  Invest in training for internal teams and local contractors. PAS 2035 compliance and whole-house retrofit principles will be essential for future funding and quality assurance.
  
• Plan Financially
  Model different cost scenarios, identify funding gaps, and explore blended finance options. Don’t wait for grants to appear—position your organisation to act when opportunities arise.

Net zero isn’t just a compliance target—it’s a strategic opportunity. The landlords who plan now will lead the way in delivering affordable, sustainable homes for Scotland’s future.

At ARK, we work with social landlords to turn the challenge of net zero into a manageable, strategic plan. Our expertise lies in helping you understand the true cost of compliance and building a roadmap that aligns with Scottish requirements.

Here’s what we do:

• Investment Plan Review
  We assess your current investment plans and identify gaps related to energy performance and decarbonisation targets.
  
• Procurement Support
  We advise on procurement strategies that deliver value and scale, including collaborative frameworks, contractor engagement, and supply chain development to ensure timely and cost-effective delivery.
  
• Asset Management Strategy
  We integrate net zero objectives into your long-term asset management plans, ensuring that investment decisions align with compliance requirements and future-proof your housing stock.
  
• Data Strategy
  We help you build a robust data foundation. Accurate EPC ratings, stock condition data, and archetype modelling allow you to make informed decisions and strengthen funding bids.

• Cost Forecasting
  We model the additional costs required to achieve EPC B by 2040 and remove fossil fuel heating by 2045, giving you clarity on future financial commitments.
  
• Scenario Planning
  We create financial projections under different policy and funding assumptions, so you can plan for uncertainty with confidence.
  
• Funding Strategy
  We help you navigate available grants, loans, and partnerships.
  
• Compliance Roadmap
  We align your asset management strategy with upcoming Scottish standards and best practice from across the UK, ensuring you’re ready for regulatory change.

Our approach is practical, data-driven, and tailored to your portfolio. We don’t just advise, we help you build a plan that works.

Contact us today to start a conversation about how ARK can help you and your organisation navigate the challenge that providing safe and decent homes presents.

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