FOI Request - EPC Governance and Data Reliance
Request 101003961308
This request relates to Energy Performance Certificates (EPCs) relied upon by Moray Council in relation to its council housing stock. I am seeking aggregate, non personal data only.
1. EPC Coverage
a) The total number of council owned dwellings for which Moray Council currently holds an EPC that is relied upon for housing management, reporting, or rent setting purposes.
2. EPC Commissioning
The number of EPCs commissioned by Moray Council for council housing stock in each of the following financial years:
a) 2023/24
b) 2024/25
c) 2025/26 (to date)
3. EPC Replacement, Withdrawal, and Non Compliance
For the same periods above, the number of EPCs relating to council housing stock that were:
a) replaced or superseded;
b) invalidated or withdrawn;
c) identified as non compliant following audit by an accreditation body.
Please provide totals only.
4. Audit Outcomes (Aggregate)
Where EPCs were found to be non compliant, please provide (in aggregate):
a) the number of EPCs affected; and
b) the categories of reason recorded for non compliance (for example: insufficient evidence, incorrect insulation assumptions, incorrect application of RdSAP conventions, data quality issues).
No individual assessor or property level detail is requested.
5. Internal Assurance / QA Arrangements
a) Whether Moray Council operates any internal quality assurance, sampling, or verification process to check the accuracy of EPC inputs derived from:
i) void property inspection records; or
ii) contractor supplied information.
If so, please provide:
b) the name of the policy or procedure; and
c) the date it was last reviewed.
If no such process exists, please confirm this.
6. Whether Moray Council has a policy or standard practice to notify tenants where an EPC previously relied upon by the Council is later:
a) replaced; or
b) found to be non -compliant.
If such a policy exists, please provide a copy.
If not, please confirm that tenants are not routinely notified.
Response 09-04-2026
1. a) 3997 properties as at 01/03/2026
2. a) 2023/24: 803
b) 2024/25: 1740
c) 2025/26 (to date): 1424
3. a) 651
b) 1
c) 1
4. a) & b) Not held. Information that is not held falls under Section 17 of the Freedom of Information (Scotland) Act 2002 - Information not held.
5. There is no internal QA; these EPC surveys are carried out by surveyors independent to Moray Council
6. a) As part of the Rent Setting Policy development and convergence process, it was acknowledged that the energy efficiency of some properties was below recommended standards. In such instances the rent setting structure incorporates a discount. The tenant will benefit from the discount until improvement works are completed and the EPC rating improved/amended. The rent is adjusted to reflect this change as per the Rent Setting Policy, and the tenant is provided with written notification in advance of the rent increase in line with housing legislation.
b) Not applicable
Please find the Rent Setting Policy here: http://www.moray.gov.uk/downloads/file154344.pdf