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Trigger Points for Regulations – Point of Sale
Purpose
1. The purpose of this paper is to set out recommendations for issues around
‘sale’ to be specified in draft regulations for consultation.

These issues include under what circumstances should these
regulations come into force (ie. is this a cash sale only or any change
in the property’s title?)

Should it be possible for the obligation due to the regulations be
passed on from the seller to the buyer (and what timeframe should this
be as to when the work should be done);

To note the potential routes to enforcement, which includes potential
sanctions.
2. To aid navigation, the following should be read and noted, in the order
given below:a) DECIDE if you agree that the principle for the obligation can be passed
from the seller to the buyer (the reasons for this is in Section 2, Part A)
b) Section 1 should be read in conjunction with Annex A, then ask
yourself do you AGREE that only sales (meaning a cash transfer)
should be considered within the scope of the draft regulations for
consultation.
c) If you and all the REEPS members AGREE that sales (meaning a cash
transfer) is the way forward for regulations, then the only aspects to
further consider are equity issues (paragraphs 47-48); changes to the
physical aspects of the property (demolition and sub-division)
d) Should you NOT all agree, then we will come back to this after
Section 2 and we will go through Annex A in its entirety. [Please note
that the project team’s preliminary conclusion is that if the obligation
can be passed on, there would only be a few circumstances where it
may be prudent not to enforce the obligations]
e) Go through the issues in Section 2, which is the outcome from the joint
subgroup workshop, and the SUBSTANTIVE part of this paper.
Background
3. This paper is in three sections:Section 1: - what is a definition of “sale”, and how different legislation
defines “sale”.
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Section 2: - Discussion from the joint workshop, including
recommended principles, and early thinking on routes to enforcement.
Annex A: - different circumstances around sale eg negative equity, as
well as different types of sales, such as repossessions.
Recommendations are presented at the end of each section.
SECTION 1: - WHAT IS A DEFINITION OF “SALE”, AND HOW DIFFERENT
LEGISLATION DEFINES “SALE”.
Background: ‘sale’ and ‘title’
The subgroups proposed that REEPS regulations are applied at point of sale.
There are however, different situations for example properties being marketed
and sold, and property changing hands through inheritance. This section
therefore considers options for the actual scope of REEPS.
4. Scotland has its own legal system and law governing the ownership of land
and property, and process. A quick overview of the process could be as
follows:
 The solicitor will complete the conveyancing process on the buyer’s
instructions;
 A lender or an independent mortgage or financial adviser will assist in
arranging a suitable mortgage package; and
 Where a mortgage is being arranged the lender will require a valuation
inspection to be undertaken by a qualified surveyor. (This is usually
provided as part of the home report.)
5. There are legal terms used in Scotland such as “conveyancing”, “missives”,
“title” etc. HMRC has produced a document on Scots land law terms1 which
includes definitions of such terms.
6. One of these terms is “disposition”, and an abbreviated extract from the
HMRC site is given below:
“This is a formal document transferring ownership, or 'title', to land.
Following the first stage in the sale of a property (the missives or
contract), the purchaser has a personal right against the seller - that is,
a purely contractual right to make the seller confer ownership on the
purchaser in exchange for payment of the price. …Ownership of the
property, however, which is a real right, …does not pass to the
purchaser until the disposition is registered in the Register of Sasines
or Land Register of Scotland.”
1
HMRC: Scottish land law terms,
http://customs.hmrc.gov.uk/channelsPortalWebApp/channelsPortalWebApp.portal?_nfpb=true&_page
Label=pageLibrary_ShowContent&propertyType=document&id=HMCE_CL_000157
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7. There are a number of situations which could require a change in the title, and
these have been initially explored in Annex A.
8. As previously discussed, our working assumption is that draft regulations will
be created under section 64 of the Climate Change (Scotland) Act 2009,
which gives Scottish Ministers powers to provide for the assessment of the
energy performance of living accommodation, and to require owners to carry
out improvements. Living accommodation is defined as a dwelling.
9. At this point it would be useful to look at the different legislation, relating to
sale.

The Energy Performance of Building (Scotland) Regulations 2008
requires that an EPC must be available for a dwelling that is to be sold.

A Home Report must be provided at the point when the house is on the
market, and “on the market” is defined as “when the fact that it is or
may become available for sale is made public”. “Sale”, in relation to a
house, means a disposal, or agreement to dispose, by way of sale of:(a) the ownership of the house,
(b) the interest of the tenant under a long lease of a house,
and “seller” means a person contemplating such a disposal (and
related expressions are to be construed accordingly).
10. Therefore a ‘sale’ would result in a change in the ‘title’ to confirm that the
seller has ‘ownership’.
Recommendations
11. REEPS members are invited to note the distinction between ‘sale’ and other
circumstances where there may be changes in the titles, which does not
involve a ‘sale’ (ie a cash transfer).
12. REEPS is invited to note other legislation which already exists relating to
sale. This may also provide (some options) to routes into enforcement, which
was explored at the joint subgroups workshop.
13. REEPS is therefore invited to provide a steer as to whether the project team
should further:

Explore regulations only when this applies to where a sale (ie cash
transfer) of some description has taken place (with specific
exemptions?)

Explore every situation where there is a change in title (this would
include sale). This could be quite extensive, as Annex A demonstrates.

To note the latter option, would have more resource implications.
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SECTION 2: - DISCUSSION FROM THE JOINT WORKSHOP, INCLUDING
RECOMMENDED PRINCIPLES, AND EARLY THINKING ON ROUTES TO
ENFORCEMENT.
Background
14. Bearing the above in mind, the joint subgroups workshop (“the group”)
focussed on a straight forward sale, to establish what happens in the majority
of sales:Scenario: a homeowner decides to sell, markets their property through an estate
agent/solicitor property centre, and buyer purchases outright or using mortgage
finance.
15. Further for the purpose of the workshop, the property currently does not meet
whatever standard set and the group explored what could happen next. This
leads to what enforcement routes might look like (see section 2C).
16. This section is broken into four parts:Part A: - Point of Sale
Part B: - Current Restrictions and Obligations
Part C: - Possible routes to enforcement For a REEPS standard
Part D: - Sanctions (or penalties)
Part A: - Point of Sale
17. The group discussed whether the property should meet whatever standard
prior to sale, or whether this requirement to improve could be passed on.
18. Though the group acknowledged there would be less bureaucracy if
improvements were to be done before sale, the group noted there should be a
choice as to whether the seller undertakes the energy efficiency
improvements prior to sale or this (requirement) can be passed on to the
buyer. The reasons given by the group are as follows:




Seller may be cash poor (and also equity may be ‘locked’ in the
property) ;
Seller may need to sell quickly;
‘Hassle factor’, if the ability to ‘pass it on’ was not available, this could
lead to extensive and protracted negations;
A new buyer might want to do even more in terms of energy efficiency
improvements2.
A new buyer may well have chosen to site a recently ‘improved’
installation (if the requirement was before sale) elsewhere, eg. would
have relocated a boiler elsewhere altogether. This would be then be an
unnecessary potential ‘double expense’.
2
ClimateXChange, Home energy efficiency - review of evidence on attitudes and behaviours, May
2014, quoting research by the Energy Saving Trust, [page 18 - 85% expressed a willingness to
stretch their budget to include energy efficiency improvements – this includes those planning
refurbishments as well as those moving home.]
http://www.climatexchange.org.uk/files/6114/0628/6972/CXC_Brief_Home_Energy_Efficiency_Revie
w_-_Full_Report.pdf
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19. For these reasons, the group would recommend choice and flexibility, as
to whether the seller or the buyer undertakes any improvements to reach a
standard. Therefore the group also agreed and would recommend to
REEPS that the principle of ‘passing it on’ is included.
20. Whether the improvements were done prior to sale, or passed on, the project
team will have to undertake further work to ensure the seller have sufficient
and timely information to make that decision. For the buyer he or she will also
need this information, if the requirement to improve was passed on.
21. It was also noted that if regulations become the ‘norm’, it may well be easier
for the seller to improve the property to meet a standard bearing, in order to
reduce any perceived bureaucracy for the buyer. Should this become the ‘new
norm’, there would be fewer instances for the need to ‘pass the obligation on’.
22. The period for ‘passing it on’ needs to be set (a notional 12 month was used
for the purpose of the discussion) or should a ‘set date’ be given?
Part B: - Current Restrictions and Obligations
23. The group discussed situations where restrictions and obligations may
currently happen in ‘sale’ situations, for example something needs
repaired/checked and a sum of money is withheld until the task has been
completed, and this may be conveyed through the solicitors. Alternatively, this
could be more informal and negotiations around price might take place
(depending on prevailing local market conditions).
24. More formal situations, where ‘obligations’ are currently recorded are noted
below [Also, where a Landlord purchases a property for letting, the situations
below would also apply.]
Common Repairs situations – what is currently recorded
 An agreement is already in place to carry out common repairs, and the
seller would inform the buyer that this is outstanding. In practice, the
seller may negotiate a price with the buyer or the seller may lodge
funds, which are paid out when the work is completed. The Title
Conditions (Scotland) Act 2003 and the Tenements (Scotland) Act
2004 make provision on registering a notice of potential liability for
costs when a property changes hands.
 A Statutory Notice for Common Repair could be in place in accordance
with Section 30 of the Housing (Scotland) Act 2006, if the council
deemed that necessary repairs were not being undertaken – ultimately
the council can carry out the work, and seek reimbursement. This
notice is registered and when title is checked with the Land Register,
the “Burdens Section”, would list all of the burdens and conditions
affecting the property3.
3
Scottish Government, Management And Maintenance Of Common Property
http://www.scotland.gov.uk/Publications/2005/11/2194749, 2005
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 The Tenements (Scotland) Act 20044 would also be highlighted to the
seller by their solicitor (should future communal works be required).
 The Property Factors (Scotland) Act 2011 places a duty on all factors
to register the address of the properties which they factor on a public
Register of Property Factors, which is maintained by the Scottish
Government 5.
What information is already available when buying a property?
 The Energy report (within the Home Report) is an EPC, and helps to
inform the buyer what they could do to improve the energy efficiency.

Where Green Deal finance is attached to the property, it is formally
acknowledged by the buyer6. It is not registered in the Land
Register/Sasines.

Conveyancing solicitors can ask local authorities for a property enquiry
certificate, which brings together various pieces of information about a
property. The information is often required when buying or selling a
house. The seller's solicitor will normally request it as part of the
property search.
Statutory Permissions for Work, where required
 Relevant Building Warrants and/or Planning Permissions for
extensions etc. These would be sought by the buyer’s solicitors.
Part C: - Possible routes to enforcement For a REEPS standard
25. To sum up the above and from the discussions from the workshop, the
following options are possible:
Potential for the conveyancing process to have a role – this
implies that either there is something in the title and/or this is
‘flagged up’ such as through property enquiry certificate.

Potential for local authorities to have a role? (and what would this
be?)

Potential for EPCs to have a role.

Potential for financial incentives to have a role.
26. The group discussed these potential routes for enforcing and monitoring a
standard.
Scottish Government, The Tenements (Scotland) Act 2004,
http://www.scotland.gov.uk/Topics/Justice/law/17975/11023 , 2004
4
5
Scottish Government, The Scottish Property Factor Register,
http://sedsh119.sedsh.gov.uk/propertyfactorregister/
6 The Green Deal (Acknowledgment) (Scotland) Regulations 2012,
http://www.legislation.gov.uk/ssi/2012/214/contents/made
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27. It noted that the conveyancing process could have a role.


Would this be ‘some sort of agreement’, for example the seller
becomes responsible if the work is agreed before the sale takes place?
How would this work? Would there need to be a formal
acknowledgment process (to ensure disclosure), or if this was part of
the title, the solicitor would point this out as part of his/her duties?
What if a requirement existed? This would be similar to the process for
Works notice. (Also, as noted in paragraph 24 above, a “Burdens
Section” already exists, could we build on this?)
28. Who else could have a role in potential enforcement routes?
During the brainstorm, where all possibilities were explored, the following
were suggested:




Local authorities?
A ‘body’ being responsible for holding a ‘funding pot’ link with the
Seller/ the Lender?
The EPC database – a UPRN (Unique Property Reference Number),
house Number, and a ‘Transaction’ field – why a new EPC was
generated already exists. If a new field could be created – does it meet
the standard? – this could be used to verify subsequent compliance.
(The buyer improves the property and a new EPC is generated and
recorded in the database.)
EPCs also indicate whether a Green Deal plan is in place. (Green Deal
checkmark on the EPC certificate.) However, it was noted that this was
‘early days’ for Green Deal plans.
[NB: an EPC workstream is underway by the Project team]
29. Could financial incentives have a role? - the group wondered if
enforcement could be linked to funding (ie could public funding play a role in
enforcement? It was noted that REEPS would not be designed to ‘fit’ with
incentives, but incentives could take account of REEPS. For example, if public
money is being paid out to carry out work, should it take account of a
standard?
30. For incentives such as Green Deal/ ECO, a (second) post-assessment EPC
already takes place (ie. already paid with some public funds), so could it now
flag up it now meets the standard too?
31. More broadly, ie not linked to public funding, the mortgage lender may ‘hold
back’ some of its loan until the new Buyer improves the property to the
standard. This might happen, if meeting a standard is the norm and especially
if it is ‘passed on’ only the once. This would make it more imperative to get the
work done earlier. [The lender may also require this to protect its investment.].
However, a lender would also weigh up the added bureaucracy costs of
negotiating, recording, enforcing and possibly checking that this has been
done.
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32. Noting all of the above, do REEPS members think that these are the
right enforcement routes we should be exploring? For reference these
are:
Potential for the conveyancing process to have a role – this
implies that either there is something in the title and/or this is
‘flagged up’ such as through property enquiry certificate.

Potential for local authorities to have a role? (and what would this
be?)

Potential for EPCs to have a role.

Potential for financial incentives to have a role.
Part D: - Sanctions (or penalties)
33. Overall, the group were of the view that it would be preferable to encourage
adoption of energy efficiency, as if this is more understood, more measures
could be undertaken. This will be taken up as part of the Comms plan.
34. It was noted that if the requirement could only be passed on once, this would
help with sanctions (see paragraph 31 – mortgage lender may use its funding
loan as a lever).
35. If a ‘restriction’ was placed on the title, people may be put off buying that
property, if another property does not have that restriction.
36. Bearing this in mind, sanctions would only apply if the new buyer did not fulfil
their obligation, and therefore the restriction would still be in place.
Possibilities around this could include: “Someone” stepping in to undertake the repair – ie like the Repair
Notice situation in paragraph 24.
 Cannot sell the property on? Or should this be linked to some form of
penalty? If the sanction was to upgrade before the next sale, this would
be a disincentive to carry out the improvement within the ‘set period’,
and carbon savings would be delayed. This would indicate an
additional penalty should be considered – should this be on a sliding
scale to avoid a ‘perverse incentive’ to delay improvements?
 Could fiscal ‘incentives’ be considered – eg increase the Council Tax?
 No access to incentives once the ‘set period’ expires, to encourage
earlier action?
 Looking more widely, could there be a blend of legislative and more
informal sanctions? These would be like REEPS setting a Framework,
and other policies “failing in”.
The above possibilities may have ECHR implications, and would need to be
explored further by the project team. Should there be any proposed criminal
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offences (and associated penalties), the project team would also need to
check with the Scottish Government’s Criminal Justice team that these were
proportionate and reasonable.
Recommendations
37. That REEPS recommend that i) in principle the obligation to bring a property
up to the regulated standard could be passed on to the buyer of the property
and ii) the house seller would make the choice whether to pass on the
obligation.
38. Further to paragraph 37 REEPS is invited to consider what timescale
should be given for the new owner who takes on the obligation to undertake
the improvement should be. Would 12 months be reasonable, or should it be
by a set date for example?
39. Further to paragraph 37 REEPS is invited to consider the principle that the
obligation to undertake improvement to meet the regulated standard should
only be passed on once and not permitted to be passed on for subsequent
sales.
.
40. REEPS is invited to note that in terms of conveyancing for a sale
situation, processes already exists to notify the new buyer of existing
burdens on the property and the project team can explore this further.
41. REEPS is invited to note whether the improvements were done prior to sale,
or passed on, the project team will have to undertake further work around the
following issues:



to ensure the seller and the buyer have sufficient and timely
information to make decisions around improvements. If the requirement
was to be passed on, a mortgage lender would also need to know what
was required to be done;
to carry out further work around sanctions;
as education and raising awareness of energy efficiency will have a
key role, the comms plan will pick up on this issue.
The project team will report back to REEPS, after working with the two
subgroups as appropriate.
42. In terms of enforcement, REEPS is invited to note that these have been
summarised in paragraph 25, and it is recommended that these options are
explored further by the project team, including speaking to relevant
stakeholders, such as COSLA, Council of Mortgage Lenders, and the Law
Society etc.
43. Some early thinking on sanctions has been detailed at paragraph 36, and
these would need to be explored further by project team, including any ECHR
issues.
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Annex A: - DIFFERENT CIRCUMSTANCES AROUND SALE DIFFERENT TYPES
OF SALES.
OTHER POTENTIAL TYPES OF SALE/ DISPOSITION
44. The workshop purposefully focussed on the most straightforward type of Sale,
and here some additional work has been carried out to consider different
circumstances around sale eg negative equity and repossessions. In addition
to equity issues, there can be a change in circumstances which may result in
a sale or changing the title (ie a disposition has taken place) of a home.
45. As noted in section 1 of this paper, there is a distinction between a ‘sale’
where there is a cash transfer and circumstances where they may be changes
in the titles, which does not involve a ‘sale’ (ie a cash transfer). These issues
are explored further here. The project team have listed a number of these
‘types of sale’, and notes there may well be others.
46. The rest of this paper, is broken into the different ‘types of sale’, namely: Equity issues
 Changes to the physical aspects of the property
 A change in circumstances
 Other situations around changes in the titles
And these are dealt with in turn, below.
47. Equity issues
“Negative equity” is when the current value of your home is less than the
amount you have outstanding on your mortgage. If the property is sold, the
owner is still responsible for paying back the whole (original) loan. Usually, the
sale proceeds would cover this, but in negative equity cases, there is a
shortfall. The mortgage lender may therefore allow you to sell your home and
then pay off any shortfall over a period of time. [See also repossessions
below]
48. If the property did not meet the standard, and the seller did not undertake the
improvements and allows the obligation to be passed on, what affect would
this have on the value of the property? Therefore, how would regulations
affect “negative equity”?
This question links into the work of the Financial Market Transformation (FMT)
team. REEPS is invited to note that this issue should be explored further by
the project and FMT teams, and brought back to REEPS.
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49. Changes to the physical aspects of the property
A dwelling sold for demolition and under the Energy Performance of Building
regulations in Scotland, an EPC is not required7, and therefore it would be
logical for this dwelling not to meet the REEPS regulations.
Where a building undergoes major alterations and is sub-divided, this will be
subject to Building Control, ie the current energy efficiency requirements at
the time of application for a building warrant. An EPC would also be required
for sale of the sub-divided properties.
50. A change in circumstances
 Situations around ‘financial distress sales’, eg.o sale due to mounting mortgage debt;
o repossession by the lender, the mortgage company that takes
possession and disposes of the property would hold the liability
(however, similar to negative equity, the previous owner
continues to be liable for any shortfall),
o bankruptcy due to business failure or other reason;
o Mortgage to rent;
o Equity release (where a ‘share’ of your home is sold);
o Selling to pay for care costs.
o Liferent (A liferent is a right to enjoy the use and benefit of
another's property for the lifetime of the beneficiary.)
 Situations around ‘family breakdown sales’ eg.o Co-habiting;
o Divorce/dissolution
 Situations around Inheritance/succession or gifting a building.
o Inheritance;
 including Death of one of the joint owners – change in
title, as the asset transfers to the surviving owner.
 Situations around change in circumstances, but the family remain in
the property, but a change in title may be required, eg.o Shared Ownership - both initial sale and subsequent purchase
of further shares (also known as “stair-casing”);
o Shared Equity – both initial sale and subsequent increasing or
decreasing equity;
o Right to buy – but this is being phased out;
 Sale in part exchange (eg. to purchase a new build property from a
developer).
Scottish Government, Building standards, Guidance leaflet ‘An Introduction to Energy Performance
Certificate (EPC) – EPC 01, http://www.scotland.gov.uk/Topics/Built-Environment/Building/Buildingstandards/publications/pubepc/epc01
7
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51. In some of the above situations the choice of improving the property or
passing on the obligation is still possible. This would include: Situations around equity relating to the property, eg. “negative equity”;
 Situations around ‘financial distress sales’;
 Situations around ‘family breakdown sales’
 Sale in part exchange (eg. to purchase from a developer).
52. In situations around Inheritance or gifting a building, the choice of improving
the property or passing on the obligation is still possible. Equally, this would
apply to intra-familial transfer situations.
53. This only leaves ‘situations around change in circumstances, but the
family/person remains in the property, but a change in title may be required’.
This category is explored further here.
54. ‘Other situations around changes in the titles’

Death of one of the joint owners – change in title, as the asset
transfers to the surviving owner. How should REEPS deal with this
situation? Should this be an exemption?

Liferent (A liferent is a right to enjoy the use and benefit of
another's property for the lifetime of the beneficiary.) - There are
two types of liferent, proper and improper. A proper liferent of land is
where the liferenter has a real right in the land. An improper liferent is
where the property is held in trust and the liferenter is a beneficiary of
the trust.

Shared Ownership - both initial sale and subsequent stair-casing here a change in the title does occur eg. from a 25% share to a 50%
share. For the initial sale the choice of improving the property or
passing on the obligation is still possible. For subsequent movement in
shares (ie. the same people hold the title), how should REEPS deal
with this situation? Should this be an exemption?

Shared Equity – both initial sale and subsequent increasing or
decreasing equity – as for shared ownership, for the initial sale the
choice of improving the property or passing on the obligation is still
possible. As there is no change in the title (only the equity, whether
increased or decreased), there are no further issues to consider.

Right to buy – for social renting, this policy is being phased out. The
property would also have been improved (if required) to meet the
Scottish Housing Quality Standard (SHQS), which includes a certain
level of energy efficiency. The choice of improving the property (by the
social landlord, though unlikely for the reasons given) or passing on the
obligation to the buyer is still possible.
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55. In conclusion, if the choice of passing on the obligation exists, this would fit
most situations around ‘sale’. The only issues remaining is where there is a
change in the title (where the owners essentially remain the same). This is
death of one of the joint owners; liferenting or shared ownership staircasing. It is recommended that the regulations allow these instances to be
exemptions. In essence would these only be change in the title (where the
owners essentially remain the same)?
Recommendations
56. Issues around ‘negative equity’ need to be explored further and this will be
brought back to REEPS. There are similar issues in relation to repossession
by the mortgage lender, if they do not achieve a good price on the property.
This also links into the work of the Financial Market Transformation team.
57. Where a property is sold for purposes of demolition, it is recommended to
REEPS members that this would not be subject to regulations. This is
consistent with no need for an EPC for demolition sales.
58. As noted earlier (in section 1) REEPS is invited to note the distinction
between a ‘sale’ where there is a cash transfer and circumstances where they
may be changes in the titles, which does not involve a ‘sale’, as such.
59. REEPS is asked to note the range of situations around sale, and situations
where there may be a change in the title deeds have been explored. If the
choice of ‘passing the obligation’ was permitted, this would cover most of
these ‘not so straightforward’ situations.
60. If it is decided that only ‘sales’ involving a cash transfer is used to
define ‘point of sale’, this would mean other situations around changes in
the titles eg. the family/person remains in the property, would not be covered
by regulations. This could be seen as a positive outcome, and avoids intricate
situations around continued enjoyment of the property where there has been
a (sometimes traumatic) change in circumstances.
61. As noted earlier, existing legislative processes already exists around (a cash)
sale and there is great benefit in using existing publically know processes.
62. If it is decided that other situations around changes in the titles, should remain
in scope, the project team has so far identified three possible exceptions and
the principle here is that there has been a change in the title (where the
occupants essentially remain the same).
63. As noted earlier, REEPS members are invited to give a steer. [This Annex
merely explores change in the title, other than in relation to sale, in more
detail.]
64. Are there any other circumstances in which REEPS members would consider
exemptions (either for sale or other situations around changes in the titles)?
13