What next for the Scottish Passivhaus Equivalent policy?
The Scottish Government’s Passivhaus Equivalent policy is on track to make significant changes to building standards, according to an update published on 19th December 2025. The progress report sets out some useful indicators of the direction of travel and outlines the next steps following the Stage 1 consultation in July 2024. A Stage 2 consultation on the policy will be launched later in 2026, which will give more detail on the policy proposals with a range of options.
Key updates
- The 31st March 2028 is re-confirmed as the date that ‘Passivhaus Equivalent’ Building Standards will come into force, ‘to enable the construction sector to prepare for the changes’.
- The new Passivhaus Equivalent standard will not mandate all new buildings to be fully Passivhaus certified.
- It is proposed that Certified Passivhaus buildings will be 'deemed to comply' with standard 6.1 (‘Energy demand’) of the building standards. This proposal will be progressed separately to the Stage 2 consultation for implementation at the appropriate time between 2026 and March 2028.
Stage 2 consultation
The following measures are to be proposed within the stage 2 consultation:
Metrics
- The introduction of absolute energy targets
- Regulated delivered energy use will remain the primary compliance metric for standard 6.1 ‘Energy demand’.
- Unregulated energy use (cooking and appliances), will be reported but will not be a compliance requirement.
- The introduction of a secondary compliance metric based on space heat demand – the Target Space Heating Rate (TSHR)
- Targets are still to be determined. A modified method of target setting will be presented in the stage 2 consultation.
Calculation method options
- Modified versions of UK Government approved methodologies HEM/ Scottish compliance ‘wrapper’ & SBEM – already released for testing in September 2025.
- A modified version of Passivhaus Planning Package (PHPP) as an alternative methodology – to be developed and released for testing during 2026.
Additional details
- The use of regional climate data within methodologies and targets
- The benefits of setting a reasonable limit on fabric infiltration (airtightness) are recognised. Consultation proposals will include an ‘upper limit’ for fabric air infiltration.
- Support for MVHR within the stage 1 consultation is noted, but the future proposals on ventilation look likely to continue to allow ‘all the available solutions’ as a means of meeting ventilation requirements.
- The use of PHPP modelling as an overheating risk tool.
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"The policies being put forward in the Scottish Government’s recent update closely correlate with our own recommendations and those of the cross-industry working group consensus report. The proposals represent a positive and pragmatic position that draws on key elements of the Passivhaus methodology. Although there are some omissions, we are pleased with the overall direction of travel. We are delighted that Passivhaus certified buildings are on course to be accepted as ‘deemed to satisfy’ Scottish building standards and that absolute targets are being considered. Consideration of PHPP (Passivhaus Planning Package) as a compliance tool is also a very positive sign." Jon Bootland, Passivhaus Trust |
Further information
Scottish Passivhaus Equivalent: FAQs
2nd January 2026
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