The Scottish Government has opened its Stage 2 consultation on proposed changes to energy and environmental standards that aim to deliver a Scottish Passivhaus Equivalent.

The Passivhaus Trust (PHT) is preparing a detailed submission and will run "respond-a-long" webinars to help members and supporters complete their responses ahead of the Friday 16 October 2026 deadline.

The Trust welcomes the momentum from Scottish Building Standards and praises the collaborative working group process with industry stakeholders that has underpinned the draft proposals.

Among the measures the Trust is most encouraged by is the plan to recognise certified Passivhaus projects as an alternative compliance route. The consultation states: "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".

PHT also backs a stronger emphasis on measured outcomes through absolute energy targets, including space heating demand and delivered energy targets; formal recognition of the PHPP methodology; and tighter assurance and compliance processes set out in the proposed compliance handbook.

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The Trust identifies several refinements that would strengthen the package:

- Include ventilation losses within the space heating metric to reflect real building performance; at minimum, offer this as an option.

- Tighten airtightness targets beyond the proposed 5 m³/(h.m²) and align best-practice levels across residential and non-residential buildings, noting airtightness is a low-cost, low-embodied-carbon driver of quality.

- Rework domestic solar PV requirements so PV either applies across both uplift levels (as for non-domestic) or can offset weaker fabric rather than stronger standards, to avoid making the step from Good to Best Practice unduly costly.

- Move towards a single space heating metric; consider the proposed London Plan space heating targets as an alternative approach (for example, a baseline plus an aspirational target).

- In future, allow an optional Passivhaus peak heat load metric of 10–15 W/m² to simplify compliance, aid heat pump sizing, and align with Passivhaus methodology.

The Trust describes the decision to accept Passivhaus as "deemed to satisfy" Scottish building standards as a globally significant advance and urges swift implementation, hoping other parts of the UK follow suit. It views the wider package as a substantive step towards a Scottish Passivhaus Equivalent grounded in Passivhaus principles. A full PHT response will be published in the coming weeks, alongside support to encourage robust consultation submissions.

Jon Bootland, Chief Executive, Passivhaus Trust, said: "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."