Stage 2 - Scottish Passivhaus Equivalent Consultation

Help shape the future homes and buildings of Scotland!

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

The Passivhaus Trust is calling on individuals and organisations to take action and respond to the consultation to help support, improve and refine what is being proposed. It is open for responses until Friday 16 October 2026. 

 

The Passivhaus Trust's position

We recognise that these consultation proposals represent an important step toards a Passivhaus equivalent. We therefore recommend referring to the new standard as ‘Passivhaus Informed’ rather than ‘Passivhaus Equivalent’, recognising the steps taken, while avoiding an incorrect assumption of equivalent performance.

The Passivhaus Standard is defined by clear performance and comfort criteria, developed and rigorously tested over more than 30 years through application, research and post-occupancy evaluation across different building typologies and climate zones. While elements of the proposed Scottish standard are aligned with Passivhaus principles, it should not be described as ‘Passivhaus Equivalent’ until its performance in practice, and any unintended consequences arising from differences in performance and comfort criteria, have been demonstrated.

We strongly support the proposed deemed-to-satisfy route for fully Certified Passivhaus buildings, which provides a clear mechanism for recognising the established Passivhaus Standard within Scottish Building Standards.  

An overview of the Passivhaus Trust's position is shared at the bottom of this page.. 

 

The Passivhaus Trust's detailed response

Read the Passivhaus Trust's detailed response to the Scottish Government’s stage 2 on its proposed Passivhaus equivalent policy.

If you are an organisation, please consider submitting a response to all 33 consultation questions, drawing on our detailed answers. Full responses will take a minimum of 1-2 hours. 

 

TAKE ACTION

1. Respond to consultation

2. Share on social media

3. Contact your MSP

 

1. Respond to the Consultation

In company with others at a lunchtime webinar

Respond live to the consultation during your lunchbreak, with our detailed step-by-step guidance.

Join our LAST CHANCE 'Respond-along' lunchtime webinar on Tuesday 13 October at 1pm, offering set-by-step support for consultation responses.

 

BOOK NOW

Or watch our recording of the previous 'respond-along' below. Skip ahead to specific questions using the "Chapters" button in the player controls.

 

In your own time

You can also use our key bullet points below to inform your responses to 16 (out of 33 in total) key questions, in your own time. It should take 30 minutes to respond.

Please put these into your own words and customise your answer to make it personal e.g. feel free to add your own comments on the importance of Scotland's climate leadership or draw on your experience of delivering Passivhaus buildings.  [Please note that identical and cut & pasted responses will not be counted.]

If you have more time, or you are an organisation, please consider submitting a response to all 33 consultation questions, drawing on our detailed answers. Full responses will take a minimum of 1-2 hours.

DEADLINE FOR RESPONSES:  Friday 16 October 2026 (cut-off point 23.59).

 

RESPOND NOW

 

SUMMARY ANSWERS

 

Section: Overview of the Scottish equivalent to the Passivhaus standard

ANSWER: YES

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Recognise Passivhaus Certification now as a deemed-to-satisfy route 30+ years of evidence and experience means no implementation risk Immediate recognition supports training, upskilling and industry readiness Make the standard mandatory as soon as practical Autumn 2029 should be the latest point, not a reason to delay Phasing should accelerate adoption, not defer it

ANSWER: OTHER

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Support Option 1 for fabric: U-values closer to what we see on optimised PH design in Scotland  Support Option 2 for MVHR: As this is the only one to include MVHR, but set limit on installed MVHR efficiency, not just unit efficiency Other: Windows: Must be well installed, meet criteria in ISO 7730 and fRsi values to prevent condensation. In Scotland this should be triple glazing, but may not need to have a u-value of 0.8. Other: Set a trajectory towards 0.6m³/(h·m²) airtightness – note: overall energy performance can be aligned with Option 2 outcomes even with Option 1 U-values when airtightness is improved to Passivhaus levels. Treat solar PV as a separate requirement, applying consistently across all options

ANSWER: NO

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Support the move towards absolute energy metrics, while recognising that excessive variation could make the approach unnecessarily complex. Limit variation in target rates as far as possible. In particular, variation by archetype and orientation could create unintended incentives for poorer design decisions, such as selecting an orientation primarily to access an easier target. Introduce a simple single Peak Heat Load metric as an alternative compliance metric, at the Passivhaus benchmark of 10 W/m², or a less ambitious initial target if supported by research. A single target for all dwellings would provide a simpler, more easily understood route within the standard. Maintain a clear relationship with established Passivhaus performance metrics, so that the new approach supports rather than adds unnecessary complexity to compliance.

ANSWER: YES

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Repeat Question 10 reservations / suggestions

Section: Fabric performance for new dwellings

Question 12

Do you agree with the proposal to set a provision in guidance for a maximum ‘upper limit’ to the declared design air infiltration rate? 

ANSWER: YES

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Support a maximum upper limit for design air infiltration 5 m³/(h·m²) is not ambitious enough for a Passivhaus Equivalent Use 1.5 m³/(h·m²) as the initial regulatory backstop - still may not fully address moisture in building fabric as research backs PH levels of airtightness for building health - see https://passivhaus.uk/thermal-bypass-risks/  Create a clear trajectory towards 0.6 m³/(h·m²) - Passivhaus-level airtightness Improved airtightness is one of lowest cost and carbon ways to reduce energy demand in our buildings

Section: Standard 6.1 approved compliance methodologies for new dwellings

Question 14

Do you agree with the proposal to recognise a modified version of PHPP as an additional tool that implements the approved methodology for standard 6.1 ‘Energy demand’ for new dwellings? 

ANSWER: YES

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Strongly support PHPP as an approved compliance methodology Proven, reliable and widely used internationally Retain the established PHPP methodology and calculations Modifications should enable Scottish Building Standards outputs Develop the approach with the Passive House Institute and Passivhaus Trust Maintain the integrity and consistency of PHPP

Section: Level of challenge for new non-domestic buildings

Question 16

What level of uplift to the current energy standards for new non-domestic buildings do you consider should be introduced as an outcome of this review? 

ANSWER: OTHER

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Support Medium for fabric Support High for MVHR as the preferred uplift Specify installed MVHR efficiency, with 75% as the minimum where 90% is stated as unit efficiency Allow greater window flexibility for non-domestic buildings, while meeting appropriate comfort and condensation criteria, including ISO 7730 and fRsi Set an airtightness trajectory towards 0.6 m³/(h·m²), aligning with our residential recommendations Clarify the rationale for the reduced g-value Ensure requirements deliver meaningful overall performance improvement Maintain consistency with the Passivhaus Equivalent ambition

Section: Method of target setting for new non-domestic buildings

Question 18

Do you agree with the proposal to allow the building target rates to fluctuate based only on the location, building type, activity types, heat source and orientation of the new building?

ANSWER: NO

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Support the move towards absolute energy metrics, while recognising that excessive variation could make the approach unnecessarily complex. Limit variation in target rates as far as possible, while recognising that specialist non-domestic buildings and activities may require bespoke energy targets. Variation should not create unintended incentives for poorer design decisions, such as selecting an orientation primarily to access an easier target. Introduce a simple single Peak Heat Load metric as an alternative, at the Passivhaus benchmark of 10 W/m², or a less ambitious initial target if supported by research. This could provide a simpler, more easily understood compliance route within the standard, rather than being limited to those using the Passivhaus deemed-to-satisfy route. Many Scottish non-domestic projects are now targeting Passivhaus peak heat load. Maintain a clear relationship with established Passivhaus performance metrics, while allowing appropriate flexibility for specialist building types and activities.

Question 19

Do you agree with the proposal to present the target rates for new non-domestic buildings within a target range table, replacing the notional building specification currently shown in Table 6.1 in the Technical Handbooks? 

ANSWER: YES

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Repeat Question 18 reservations / suggestions

Section: Fabric performance for new non-domestic buildings

Question 20

Do you agree with the proposal to set a provision in guidance for an ‘upper limit’ to the declared design air infiltration rate? 

ANSWER: YES

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Support a maximum upper limit for design air infiltration 5 m³/(h·m²) is not ambitious enough for a Passivhaus Equivalent Use 1.5 m³/(h·m²) as the initial regulatory backstop - still may not fully address moisture in building fabric as research backs PH levels of airtightness for building health - see https://passivhaus.uk/thermal-bypass-risks/  Create a clear trajectory towards 0.6 m³/(h·m²) - Passivhaus-level airtightness Improved airtightness is one of lowest cost and carbon ways to reduce energy demand in our buildings.

Section: Standard 6.1 approved compliance methodologies for new non-domestic dwellings

Question 22

Do you agree with the proposal to recognise a modified version of PHPP as an additional tool that implements the approved methodology for standard 6.1 ‘Energy demand’ for new non-domestic buildings? 

ANSWER: YES

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Strongly support PHPP as an approved compliance methodology Established across a wide range of non-domestic building types for 30+ years Scottish Government modelling demonstrates PHPP across offices, healthcare, hotels, schools, retail and warehouses. Clarify what is meant by ‘modified version of PHPP’ Modifications should support Scottish compliance reporting and outputs Retain the established PHPP methodology and underlying calculations Develop the approach with Scottish Government and Passive House Institute

Section: Ventilation and indoor air quality

Question 25

Do you have any views on the proposal to decouple the link between fabric air infiltration and ventilation solution? 

ANSWER: YES

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Support the principle that uncontrolled fabric infiltration should not be relied upon as a means of providing ventilation Airtightness is beneficial for all ventilation strategies and should remain an important part of the design of any well-performing building. Ventilation solutions should be determined from measurable performance requirements, including IAQ, ventilation rates, comfort, noise, draughts and energy. Ensure ventilation heat losses are reflected in space heating demand. Maintain high airtightness alongside technology-neutral ventilation solutions

Section: Overheating

Question 26

With regards to the proposal to reference the use of PHPP as an additional overheating risk assessment methodology option, do you know of any risks and opportunities that should be considered to inform the development of draft guidance? 

ANSWER: YES

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS] Strongly support PHPP as an additional overheating assessment methodology, with CIBSE TM59 where appropriate. Proven, transparent and widely used for summer comfort assessment Use a performance-based approach with clear comfort and resilience outcomes Define when PHPP is insufficient and when dynamic modelling is needed - https://passivhaus.uk/dynamic-thermal-modelling-for-summer-comfort/  Require all methodologies to include stress testing for future climate/ occupant behaviour, at least equivalent to the PH standard. Build on the established Passivhaus Summer Comfort Statement approach

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2. Share on social media

Please let us know you have responded, share the Passivhaus Trust's key messages and encourage others to respond!

Tag the Passivhaus Trust in any posts
Use the hashtag: #ScottishPassivhausEquivalent

 

3. Contact your MSP

Please email your MSP to ask them to support the Passivhaus Trust’s position on the Scottish Passivhaus equivalent consultation. Use the suggested email text below to get in touch and let us know if you hear back from them.

a)       Find your MSP

If you live in Scotland, please enter your postcode or location to find the email address of your local MSP. https://www.parliament.scot/msps/current-and-previous-msps

b)       Email using suggested text

Dear [Name of MSP]

As one of your constituents,  I wanted to share my concerns about some of the current Scottish Government Stage 2 consultation proposals for the Scottish Passivhaus equivalent policy. I would like to ask you would get behind amendments to the consultation proposals suggested by the Passivhaus Trust.

Introducing a Passivhaus equivalent would put Scotland on a global stage for climate leadership, help alleviate fuel poverty, and improve energy security in Scotland. 

The Passivhaus Trust is very supportive of the inclusion of a proposal for certified Passivhaus homes to be considered ‘deemed to satisfy’ Scottish building standards and the introduction of absolute energy targets, However, there is extensive room for improvement within the proposals. 

It would be fantastic if you could respond to the Consultation, making the points that the Passivhaus Trust has identified, to help ensure the consultation outcomes are the best they can be. 

I look forward to hearing from you.

Best wishes

[Name]

[Address]


c)       Send us any MSP responses

Please forward any MSP responses you receive to info@passivhaustrust.org.uk

It will be helpful for the Passivhaus Trust to know which MSPs are supportive of the Scottish Passivhaus equivalent policy, which will be useful at later stages as the legislation comes to the Scottish Parliament. 

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Overview of Passivhaus Trust position

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 fabric heat loss rates (although we recommend these are Space Heating Demand targets, see below) and delivered energy targets.
• Recognition of PHPP as a compliance methodology.
• Improved compliance and assurance mechanisms, as outlined in the proposed compliance handbook.

However, there is significant room for improvement:

• Ventilation losses must be included in any Space Heating metric otherwise the metric is not representative of real building performance. A new Fabric Heat Loss Rate could be introduced but this MUST be named appropriately and should not replace the need to report the actual Space Heating Demand.
• 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 1.5 m³/(h·m²) as an initial regulatory backstop, with a clear trajectory towards 0.6 m³/(h·m²) and Passivhaus-level performance.
• The Passivhaus Trust has some concern that allowing target performance rates to fluctuate could make the approach unnecessarily complex and create unintended consequences. The Passivhaus methodology is simpler because it uses fixed targets. Any factors used to vary the targets should be clearly justified by their impact on energy performance, and the methodology should remain as simple and transparent as possible. It should also encourage good design decisions, rather than creating incentives to design around the target.
• We also recommend that a single Peak Heat Load metric is recognised as an alternative route to compliance, at the Passivhaus benchmark of 10 W/m², or a less ambitious initial target if supported by research. This would provide a simple, readily understood metric with a clear relationship to Passivhaus performance.

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Thanks to our campaign sponsors

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

 

 

Further information

Building regulations - proposed changes to energy and environmental standards: stage 2 consultation and BRIA

Scottish Passivhaus Equivalent: FAQs

Passivhaus for Scotland showcase

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2nd October 2026

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