Citizens Advice Scotland welcomes proposals to introduce a minimum standard of energy efficiency in the private rented sector (PRS). 

› From our evidence, a range of harms are caused by poor energy efficiency, including damp and mould, high energy bills and fuel poverty which in turn lead to poor physical and mental wellbeing, financial hardship and even homelessness. It is therefore imperative that action is taken to improve energy efficiency for tenants in all tenures. 

› The minimum standard should be set at EPC HRR band C. 

› Support will be needed for tenants and landlords to understand and achieve the minimum standard within the proposed timescales - this includes an early awareness raising campaign. If a cost cap is introduced, there must be clarity on what it will mean, and protections must be put in place to ensure costs are not passed to tenants. 

› There must be a limited range of exemptions from the minimum standard – in particular, short term lets must not be excluded from minimum standards as this risks permanent homes for people being lost to the short term let market. 

› Financial penalties for non-compliance with the regulations must be robust enough to ensure adherence but also be realistically recoverable.