The Scottish Government has just launched the Stage 2 consultation on its proposed Passivhaus equivalent policy
Following the consultation launch, the Passivhaus Trust has welcomed the progress made by Scottish Building Standards to move towards a Scottish Passivhaus Equivalent policy.
The Trust said it was 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.
Jon Bootland, chief executive at the Passivhaus Trust, commented: “The Passivhaus Trust wholeheartedly welcomes the Scottish Government’s commitment to accept buildings certified to the Passivhaus standard as ‘deemed to satisfy’ building standards.
“The Trust is pleased that the Scottish Government’s proposals for upgrading building standards are informed by the Passivhaus standard.”
Passivhaus ‘encouraged’ by several proposals
The Passivhaus Trust says it is encouraged by several aspects of Scotland’s Passivhaus equivalent policy, 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.
Scotland’s Passivhaus equivalent policy still needs improvements
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.
- 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.
- 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.
- Use of peak heat load Passivhaus metric: A potential future addition the Passivhaus 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 align better with Passivhaus methodology.
Encouraging the rest of the UK to adopt Passivhaus standards
The decision to allow Passivhaus to be ‘deemed to satisfy’ Scottish building standards is a massive step forward, of global significance.
The Trust hopes 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.
Trust members are encouraged to respond to Scotland’s consultation
The Trust is preparing a detailed response to the Stage 2 Consultation and will share the details in the coming weeks, ahead of the consultation deadline of Friday, 16 October 2026.
The Passivhaus Trust will encourage its members to respond to the consultation to help improve and refine what is being proposed.
“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,” Bootland concluded.
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