Stage 2 - Scottish Passivhaus Equivalent Consultation

Passivhaus Trust initial response

The Scottish Government has just launched the Stage 2 consultation on its proposed Passivhaus equivalent policy. 

The Passivhaus Trust is preparing a detailed response to the consultation and will be sharing the details of that in the coming weeks, ahead of the consultation deadline of Friday 16 October 2026. We will also be running 'respond-a-long' webinars to help our members and supporters complete their consultation responses. Below we share the Passivhaus Trust's initial response to the proposals.

Passivhaus Trust Response

The Passivhaus Trust welcomes the progress made by Scottish Building Standards to move towards a Scottish Passivhaus Equivalent policy. The Trust is particularly impressed with the extensive and collaborative process undertaken with the wider construction industry across Scotland as part of the Working Group, set up and managed by the Scottish Building Standards team, that reached a consensus position from which these consultation proposals have been developed

The Passivhaus Trust welcomes the direction of travel laid out in the Consultation document and is  very encouraged by several of the proposals including:

• Passivhaus to be ‘deemed to satisfy’ Scottish building standards “Amend standard 6.1 ‘Energy demand’ to recognise Passivhaus certification as an alternative means of compliance. This change will be progressed for implementation alongside wider review changes”.
• Stronger focus on actual building performance, with use of absolute energy targets, including space heating demand targets and delivered energy targets.
• Recognition of PHPP as a compliance methodology.
• Improved compliance and assurance mechanisms, as outlined in the proposed compliance handbook.*  

However, the Passivhaus Trust notes a number of ways that the proposals could be improved:

• Include ventilation losses within the space heating metric: Ventilation losses must be included otherwise, the metric is not representative of real building performance. At the very least, this should be an option.
• Set more ambitious airtightness targets: The proposed upper limit of 5 m³/(h.m²) is an improvement but is still too high. Airtightness is one of the cheapest and lowest embodied-carbon ways to reduce energy demand and acts as a key quality driver. We recommend that the Best Practice/ High targets for residential/ non-residential buildings should be aligned.
• Amend solar PV requirements: For domestic projects, PV should either apply across both uplift levels (as is proposed for non-domestic buildings) or be used to compensate for weaker fabric standards rather than stronger ones. As it is, the current positioning makes the uplift cost from Good to Best Practice unduly high.
• Use of a single space heating metric: The Passivhaus Trust understands why space heating target range tables are being proposed in the consultation and applauds the pragmatic solution and improvement on the current notional building method. The pure Passivhaus methodology is simpler because it has a single metric for space heating. We suggest that Scotland considers the proposed London Plan space heating metrics  as an alternative solution (eg baseline target plus aspirational target).

• Use of peak heat load Passivhaus metric: A potential future addition that the Trust would like to put forward is that an alternative optional peak heat load metric around 10–15 W/m² is also permitted. This could help simplify compliance, support heat pump sizing, and aligns better with Passivhaus methodology.

Conclusion

The decision to allow Passivhaus to be ‘deemed to satisfy’ Scottish building standards is a massive step forward, of global significance. We hope that the Scottish Government can implement the policy with immediate effect and that other parts of the UK might quickly follow.

The other proposed changes to building standards within the consultation are positive, and represent a step towards a ‘Scottish Passivhaus Equivalent’, drawing on the Passivhaus methodology.

Watch this space for the Passivhaus Trust's detailed response to the Stage 2 Consultation, which will go live in the next few weeks. We will be encouraging our members to respond to the consultation, to help improve and refine what is being proposed.

 * A further detailed response to follow

The Passivhaus Trust wholeheartedly welcomes the Scottish Government's commitment to accept buildings certified to the Passivhaus standard as 'deemed to satisfy' building standards. It also welcomes moves towards the use of absolute energy targets and accurate tools such as PHPP.  The Trust is pleased that the Scottish Government's proposals for upgrading building standards are informed by the Passivhaus standard. The proposals represent a very good move in the right direction towards a Scottish Passivhaus Equivalent, with scope to be improved in the future, and we applaud the Scottish Building Standards team for delivering a significant step change for Scottish building performance.  Jon Bootland, Chief Executive, Passivhaus Trust

 

Thanks to our campaign sponsors

The Passivhaus Trust's Scottish Passivhaus equivalent policy work is kindly sponsored by the following Passivhaus Trust members:

 

11th August 2026

---

Get involved with the UK Passivhaus community

---