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How Scotland, Wales and Northern Ireland compare with the English Future Homes Standard — UK new build solar PV installation
Future Homes Standard

How Scotland, Wales and Northern Ireland compare with the English Future Homes Standard

Scotland's Section 6 already mandates direct-emission-free heating from 2024. Wales follows England closely. Northern Ireland lags. We explain each devolved regime and what it means for cross-border developers.

FHS in Scotland, Wales and Northern Ireland — Future Homes Standard guidance for new builds

Building Regulations are devolved across the four UK nations. The Future Homes Standard is an England policy — but Scotland, Wales and Northern Ireland are following parallel, broadly similar tracks. This page summarises each.

Scotland: ahead on heating, parallel on PV

Scotland's Section 6 of the Building Standards already prohibits direct-emission heating systems in buildings commencing warrant from 1 April 2024 — making Scotland the first UK nation to ban gas boilers in new builds. A 2026 consultation is expected to introduce a PV requirement aligned to England's 40% rule but with cold-climate-adjusted assumptions.

Wales: closely aligned with England

Welsh Part L follows the England/Wales framework. The 2026 Welsh Building Regulations consultation is expected to mirror England's FHS provisions with possible local tightening. Implementation is likely to lag England by 6–12 months as Welsh-specific drafting completes.

Northern Ireland: behind

Building Regulations (Northern Ireland) Technical Booklet F2 has not yet adopted FHS-equivalent provisions. Consultation is expected during 2026–27 with implementation no earlier than 2028. Cross-border developers should note the regulatory gap.

Implications for cross-border developers

Volume housebuilders operating UK-wide are mostly designing to a single UK-wide FHS specification — it is operationally cheaper than running parallel specs and protects the brand against future tightening. A few SME developers are taking advantage of the Northern Ireland gap to build to Part L 2021 spec for the next 18 months.

Why this matters for the supply chain

PV panel, inverter and ASHP supply chains scale to UK demand. Scotland's earlier ASHP mandate has already shifted UK new-build heat pump volume materially. England's 2027 PV mandate is the next major demand shift; lead times on premium 425W+ panels are expected to extend through 2027.

40% of ground floor area
PV / ground floor area
Mar 2027
FHS in force
75%
CO₂ vs 2013 baseline
£4,350 per dwelling
Per-plot premium (2025 prices, FHS Impact Assessment)
For developers and housebuilders

Fhs in scotland, wales and northern ireland on volume new-build programmes

On a multi-plot programme, settle four things at procurement: the per-plot price and how it moves with inflation; whether the array is modelled in the SAP 10.3 calculation for every house type; what your structural warranty provider needs to see for roof-integrated PV; and who issues the MCS certificate at handover, since buyers need it to claim Smart Export Guarantee payments.

Developer guide →
For self-builders and architects

Fhs in scotland, wales and northern ireland for one-off custom builds

On a one-off build the array is easiest to settle at RIBA Stage 2 or 3, while the roof geometry is still open. Your SAP assessor models the system for the Part L submission, your building control body signs it off, and PV installed as part of constructing a new dwelling is zero-rated for VAT under HMRC Notice 708.

Self-build guide →

How this fits into the FHS compliance pathway

Every FHS-compliant new build passes three regulatory gates. Fhs in scotland, wales and northern ireland sits mainly in the second, design-stage Part L compliance, but it affects building control sign-off and the handover documents too:

  1. 1
    Planning permission Solar PV designed into a new dwelling is normally covered by the dwelling's own planning permission. Conservation areas, Article 4 directions and plots within the curtilage of a listed building need extra planning evidence, usually prepared by the architect or planning agent.
  2. 2
    Building control: Part L compliance SAP 10.3 is the compliance calculation at FHS launch. The dwelling's emission and primary energy rates must meet their targets, with the PV array, heat pump, fabric U-values and air permeability all entered. The SAP assessor prepares the design-stage and as-built calculations that building control reviews.
  3. 3
    Completion: certificates and handover The MCS certificate (needed for Smart Export Guarantee payments), the Energy Performance Certificate and the homeowner's handover documents. If your structural warranty provider has requirements for roof-integrated PV, confirm them before the roof goes on.

For a fuller walkthrough of the compliance process, see the Part L 2026 guide and the FHS PV calculator, which sizes a compliant array from your ground floor area.

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FHS PV Calculator

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More on the Future Homes Standard

The 40% Ground Floor Area PV Rule Explained →

Part L 2026 sets a solar PV output target from a 0.22 kWp/m² reference array over 40% of the ground floor area. How it works, worked examples and the alternatives.

Future Homes Standard 2026 / 2027 Timeline →

The complete FHS rollout timeline — from the 24 March 2026 publication of the Approved Documents through to the 24 March 2028 end of the transitional period. Includes practical milestones for developers.

Gas Boiler Ban in New Builds: 2027 Rules →

Are gas boilers banned in new builds? Not by name, but Part L 2026 targets rule them out from 24 March 2027. Dates, what replaces them, and existing homes.

FHS U-Values for Walls, Floors, Roofs & Windows →

Every U-value change under Part L 2026: external walls down to 0.15, ground floor to 0.11, roof to 0.11, doors to 1.0, air permeability to 3. With practical buildup examples.

FHS Cost Impact: £4,350 Per Dwelling Decoded →

The Government Impact Assessment estimates an average £4,350 per dwelling FHS premium. We break it down by line item (solar PV, ASHP, MVHR, fabric, doors) and show how it varies by house type.

FHS Transitional Period: What Pre-2027 Projects Can Do →

Projects that commence Building Control approval before 24 March 2027 may complete to Part L 2021 standards until 24 March 2028. We explain the rules and the practical implications.
FHS in force from 24 March 2027

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Share your plot details and a solar installer can price a system sized to the Part L 2026 notional dwelling, with PV area equal to 40% of the ground floor area. There is no obligation to go ahead.

  • ✓ Sized to the 40% ground-floor-area rule
  • ✓ For developer programmes and one-off self-builds
  • ✓ Check any installer against the MCS register before you sign
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