Historic Environment Scotland froze the official Buildings at Risk Register in September 2024 after a review found that it was incomplete and inconsistently maintained. The consultants did not recommend that it should simply be closed and warned against leaving Scotland without an equivalent system. Almost two years later, the official register remains frozen, while a separate conservation charity has more than doubled the number of Scottish buildings on its own watchlist from 46 to 88.
Scotland stopped accepting new entries for its official register of endangered historic buildings without first putting a replacement system in place.
The Buildings at Risk Register identified listed buildings and historically important properties that were vacant, neglected, structurally unsound, damaged by fire, open to the weather or threatened with demolition.
It was established in 1990 amid concern about the growing number of listed buildings and buildings in conservation areas that had become vacant and fallen into disrepair. Historic Environment Scotland had operated it as an in-house service since 2015.
Historic Environment Scotland stopped accepting nominations and updating existing entries on 30 September 2024. The website remains accessible, but it shows the position when the service was paused rather than a current national picture.
Its last published count, from January 2024, recorded 2,219 buildings. Since the pause, a historic school, church, tenement, house or industrial building could have become vacant or suffered serious damage without being added. A property already recorded may have been restored, demolished or lost to fire while continuing to appear in its former condition.
Historic Environment Scotland says it is exploring alternative ways to support buildings that are vacant, neglected or at risk of demolition. It has not published details of a replacement official system or given a date by which one will be introduced.
What Has And Has Not Been Stopped
Historic Environment Scotland has not closed and has not stopped maintaining Scotland’s statutory list of protected buildings.
The Buildings at Risk Register was a separate service. It identified buildings believed to be endangered, but inclusion did not create their legal protection.
Listed buildings remain protected under planning law whether or not they appear on an at-risk register. Listed-building consent is generally required for alterations affecting their character, including partial or complete demolition.
The loss is therefore not the immediate removal of statutory protection. It is the loss of a current official warning system capable of drawing attention to deterioration before a building reaches the point at which demolition is proposed.
How Deterioration Can Lead To Redevelopment
A listed building cannot lawfully be demolished merely because another use would be more profitable.
National Planning Framework 4 says proposals to demolish listed buildings will not be supported unless exceptional circumstances are demonstrated and reasonable efforts have been made to retain, reuse or adapt the building.
Planning authorities can consider whether a building is incapable of physical repair, whether restoration is no longer economically viable after adequate marketing, or whether demolition is essential to delivering substantial benefits to economic growth or the wider community.
A building identified early may still be secured, repaired, marketed or adapted. Its condition can be publicised, funding can be sought and prospective buyers or community organisations may have an opportunity to intervene.
If deterioration continues, the position can change. Water entering through a failed roof can damage timber, masonry and interiors. Repair costs rise, while the value of the building as a viable restoration project falls.
That does not automatically lead to demolition consent. Each application must be decided on its own evidence, and the legal protections remain in force.
Deterioration may, however, change the evidence presented to the planning authority. A building that could once have been repaired may eventually be described as physically incapable of restoration or financially uneconomic to save.
If demolition is approved, the historic building is lost and the cleared site can become available for redevelopment. The replacement might be housing, commercial premises, industry, energy infrastructure, transport works or another use.
There is no evidence that Historic Environment Scotland paused the register to facilitate development, or that buildings are deliberately being allowed to deteriorate so their sites can be cleared.
The risk is structural. Listing can restrict demolition, but it cannot repair a roof, secure an abandoned building or find a sustainable new use. Without early identification and intervention, neglect can help create the circumstances later cited in support of demolition.
New Cases Continue To Emerge
Evidence published in July 2026 shows that concern about endangered Scottish buildings has continued to grow during the official pause.
SAVE Britain’s Heritage, an independent UK conservation charity, added 42 Scottish buildings to its separate Buildings at Risk register. The additions increased its Scottish entries from 46 to 88, more than doubling the number on its list.
The new entries include Lennox Castle in East Dunbartonshire, two listed Art Deco cinemas in Edinburgh, the former Scottish Ambulance Service building in Glasgow and other vacant or deteriorating properties across the country.
The nominations came from members of the public, conservation professionals and local authorities concerned about the buildings’ futures.
SAVE’s register is not the official HES register. It is a selective UK-wide campaigning list designed to raise awareness and encourage retention and reuse. SAVE says the information is compiled from public sources and local contacts but is not independently verified by the charity.
The increase from 46 to 88 does not establish that all 42 buildings became endangered after HES paused its register. Some had been vacant or deteriorating for years before they were nominated to SAVE.
It also does not prove that those buildings are already beyond repair. SAVE’s purpose is to identify buildings whose futures remain uncertain and to encourage action before they are lost.
The increase nevertheless provides current evidence that buildings requiring attention continued to be identified while Scotland’s official register was no longer accepting nominations.
Delay carries its own risk. A building that was repairable when the official register was frozen may have suffered further water penetration, vandalism, fire or structural decline by the time a replacement system begins operating. In some cases, the cost of rescue may already have risen substantially.
The charity’s work does not replace the need for an official Scotland-wide system. Its 88 Scottish entries are a small and selective group beside the 2,219 buildings recorded by HES in January 2024.
Who Commissioned The Review
Historic Environment Scotland commissioned the review in 2023.
The published contract said its purpose was to examine the effect of the register in bringing buildings back into use since 2011 and to produce evidence-based options and recommendations informing HES’s long-term decisions.
The procurement used an open procedure. Three tenders were received, all from small or medium-sized businesses. Quality carried 60 per cent of the evaluation score and price carried 40 per cent.
The recorded tender values ranged from £27,580 to £29,650 excluding VAT. The contract award notice does not state which figure was the successful price. The contract was concluded on 14 August 2023 and awarded to Harlow Consulting.
Who Owns Harlow Consulting
The contractor trades as Harlow Consulting. Its legal entity is Harlow Consulting Services Ltd, an active English private company incorporated in October 2019 under company number 12246374.
The business was founded by Jennifer Brennan and Clare Vokes, who are its two directors.
Companies House records Brennan and Vokes as the company’s two active persons with significant control. Each owns more than 25 per cent but no more than 50 per cent of the shares and voting rights. Each also has the right to appoint or remove directors.
The filings do not reveal their exact respective shareholdings. They record no corporate parent, property developer, land company or infrastructure company as exercising significant control.
There is no evidence in the ownership records that Harlow Consulting had a financial interest in historic buildings being demolished or their sites becoming available for redevelopment.
How Independent Was The Review
The report described the work as an independent external review.
Harlow used desk research, interviews with heritage organisations, a public user survey, follow-up interviews, discussions with HES staff and analysis of register and planning data.
The survey received 120 responses: 95 from people who had used the register and 25 from people who had not. It was promoted through heritage networks and a media campaign that contacted more than 200 publications.
Historic Environment Scotland was involved as the commissioning body. The report’s acknowledgements thank an HES project reference group for its support and guidance and state that HES staff “reviewed and corrected draft text”.
That disclosed involvement is not evidence that HES ordered the consultants to reach a particular conclusion. It does establish that the report was developed with input and factual review from the organisation that would later decide the register’s future.
What The Review Found
The review identified serious weaknesses in the official register.
Only 14 per cent of buildings classed as being at risk had been updated during the preceding year. Twenty-nine per cent had last been reviewed between seven and ten years earlier.
The position varied substantially between council areas. Most entries in Glasgow and Shetland had been checked within a year. In Orkney, 80 per cent had not been updated for at least seven years. In Aberdeenshire, the figure was 73 per cent. More than half of the entries in Argyll and Bute were at least ten years old.
The differences largely reflected where the register’s three full-time staff had most recently carried out their rolling programme of surveys.
The review also compared the register with listed-building consent records for complete demolitions between 2011 and 2022. Only 53 per cent of those demolitions appeared on the register.
Other losses could be more difficult to identify, including buildings lost through fire, flooding, gradual collapse, emergency dangerous-building action or demolition without the required consent.
The consultants concluded that the register was not sufficiently complete, current or representative to measure national trends reliably.
They also found insufficient empirical evidence that inclusion on the register had a substantial overall effect in returning buildings to use. The report did, however, acknowledge anecdotal evidence of a small positive effect.
Most surveyed users were heritage professionals. Eighty-nine per cent used the register mainly to obtain information about a building in which they already had an interest rather than to search for a building to buy or restore.
That did not mean users regarded the service as worthless. Ninety per cent described it as useful or very useful to themselves or their organisation.
The Report Did Not Recommend Closure
Harlow Consulting did not tell HES to close the register.
The report presented five options:
- discontinue the register and redirect its resources;
- maintain it in its existing form;
- make targeted changes to its scope, information and functions;
- redesign it to attract restoring purchasers and greater publicity;
- replace it with a comprehensive cyclical survey of listed-building condition.
The report did not identify discontinuation as the required or preferred outcome. It said the options could be combined or introduced at different stages as part of a wider strategy for Scotland’s endangered historic buildings.
Its examination of discontinuation contained substantial warnings.
The report said that without the register or an equivalent Scotland would “become an outlier among the four UK home nations”.
It warned that discontinuation could harm HES’s reputation, place it at odds with recently adopted national planning policy, weaken opportunities to target attention and resources, and make any future attempt to recreate the evidence base more difficult.
It also said those risks could probably be mitigated only by introducing a convincing replacement strategy, which might cost more than the savings produced by ending the register.
The review therefore supplied HES with reasons to reform the register, reasons to discontinue it and reasons not to leave Scotland without an equivalent.
HES Made The Decision To Pause It
Historic Environment Scotland announced the pause on 30 September 2024.
Its public explanation concentrated on the finding that there was insufficient evidence to demonstrate that the register had a substantial effect in bringing buildings back into use.
The announcement then stated: “HES has therefore taken the decision to pause the BARR”.
The pause was an HES decision. It was not an instruction issued by Harlow Consulting and was not identified in the report as the only course HES should follow.
HES said the pause would allow it to consider alternative approaches and that it remained committed to supporting the sustainable reuse of vacant, neglected and endangered buildings.
The report had been completed in March 2024. HES announced the pause six months later.
Almost two years after that decision, the HES website remains frozen, its downloadable information still represents the position in 2024 and the organisation is not accepting new nominations.
During that period, a separate conservation organisation has found enough concern to more than double the number of Scottish buildings on its own risk list.
That does not prove all 42 newly added buildings have deteriorated beyond repair. It does show why leaving Scotland without an updated official national system is difficult to defend.
What The Register Achieved
The register did not guarantee rescue, funding or legal protection. It provided a public record that could be used by councils, grant bodies, community organisations, researchers and prospective restorers.
The review found that the formal assessment undertaken before a building was added could strengthen a funding application.
Since 2017, HES had approved 23 of 39 grant applications involving registered buildings, a success rate of 59 per cent. The approval rate for applications concerning buildings outside the register was 46 per cent.
The report cautioned that the two groups were not directly comparable because buildings on the register were generally in poorer condition. It nevertheless found that some funding organisations gave additional weight to applications involving a formally recognised building at risk.
Registration could also draw press attention, support a community campaign and influence council action, although the review said those effects were variable and difficult to quantify.
Built Environment Forum Scotland told MSPs in June 2025 that about 22 per cent of buildings historically placed on the register had eventually been demolished. It described the register as Scotland’s best available early warning of possible heritage loss while arguing that it needed to be connected to stronger practical action.
The old official register was defective. Some entries were years out of date, its coverage was inconsistent and three members of staff could not maintain a reliable national picture.
The review made a persuasive case for reform. It did not establish that Scotland no longer needed to identify its endangered historic buildings.
Nor did it recommend that HES should simply close the register. It expressly warned of the consequences of leaving Scotland without an equivalent.
HES nevertheless paused the system before identifying its replacement.
Without early identification, a repairable building can become an uneconomic one. An uneconomic building can become the subject of a demolition application. If demolition is approved, the site can be redeveloped after the opportunity to save the historic building has been lost.
Sources
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