EPC proposals for landlords: Your questions answered

The government launched a consultation on Improving the energy performance of privately rented homes on 7 February 2025, and the consultation entitled Reforms to the Energy Performance of Buildings regime on 4 December 2024. Taken together, they contain proposals that would completely overhaul the way in which energy efficiency is assessed in 2026, and increase the minimum energy efficiency standards to an EPC C from 2028 for new tenancies.

I originally published the blog post The proposed new EPC energy efficiency rules for landlords explained on 7 February (since updated), which was followed by my YouTube video New EPC proposals: What landlords need to know.

Since then I have had hundreds of questions from concerned landlords, wanting to understand the detail. I decided to answer the top 15 questions in a new YouTube video, and this blog post is the written version with additional resources.

NB: The proposals I discuss in this blog post and in the video are just proposals for which the government is carrying out a consultation. The detail may well change and the dates may slip.

>> Related Post: The proposed new EPC energy efficiency rules for landlords explained

>> Related Post: Mission EPC C and the Warm Homes: Local Grant

Will it be harder to get an EPC C with the new metrics?

Whether it will be easier or harder to get an EPC C once the new metrics are launched in 2026 will very much depend on the particular circumstances of the building.

The government said in the February EPC consultation that they wish to “prioritise meeting a standard set against the fabric performance metric, which is likely to require similar improvement measures as meeting an EPC C on current EPCs, and then to meet a standard set against either the heating system metric or the smart readiness metric”.

They want landlords to install “measures that could improve the building’s heat retention, reduce the energy required to operate the building’s heating systems, and enable the occupier to optimise their energy use, to maximise the overall energy efficiency of the building and reduce its running costs”. 

At the moment, the system is based on a cost-based Energy Efficiency Rating (EER). As gas is cheaper than electricity, properties with gas boilers do better in their EPCs than properties with electric heating and hot water, even if they don’t have good insulation. This is because gas boilers are cheaper to run.

In the future, the “fabric performance” will be more important, so it will be importance to have good insulation, double-glazed windows or secondary glazing and draft excluders. 

A heat pump is likely to do well because it is a low-carbon system and the government is looking to reduce carbon.

This means that a property with excellent insulation, double glazing and an electric heating system is likely to score higher under the new metrics, and a poorly insulated house will go down.

But the good news is that it’s comparatively cheap to put more insulation in the loft. Windows on the other hand are expensive. I replaced mine over a couple of years to spread the cost, as you can see in this blog post: Mission EPC C.

However, as a big caveat, we don’t yet know the metrics and have not been told how typical properties will fare under the new system.

Please explain the EPC implementation timetable for landlords

This is what the government is proposing:

• Late 2026. The new way of measuring EPCs is due to come into force in “late 2026”. After this date, all new EPCs will be assessed using the new system. This means if you want a new certificate under the old system, say you already have a C and want to benefit from the transition arrangements, you’ll need to get a new EPC before the new system comes into force. We don’t yet know the exact date the government has in mind.

• 2028 – After this date, all NEW tenancies will need to have an EPC C – either an EPC C from the old system that will still be valid until it expires, or an EPC on the new metrics from 2026. We don’t know what the month will be.

• 2030 – This is the backstop date for landlords with long term tenants who have been there since before the 2028 date. After this date, all rental properties will need to have an EPC C – either one from the old system, or a new one with the new metrics.

As an aside, this timetable is very short given that the metrics are changing as well. More time was given for the original Minimum Energy Efficiency Standards (MEES) for landlords. Landlords were originally required to provide new tenants with an EPC certificate in October 2008, with the original The Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations 2007 having come into force in April 2007.

The MEES regulations for landlords imposing EPC E as a minimum for landlords were laid before Parliament in March 2015, and they didn’t come into effect for new tenancies and renewals from 1 April 2018. Compliance was extended to all tenancies (including existing ones) from 1 April 2020.

This means that landlords had 3 years’ notice to get ready to improve their EPCs to a relatively low EPC E from the publication of the regulations, and the cost cap was low (£3,500 in 2015 or £4,744 in real terms in 2025, using the Bank of England Inflation Calculator). Increasing energy efficiency to an EPC C is far more complex, and the cost cap is more than three times the inflation-adjusted figure.

Will the EPC proposals affect HMOs?

Yes. The government is proposing that there is a valid EPC for an entire house when a single room is rented out. A EPC C would be required even if just one room is let. 

Currently, this isn’t required when rooms are let out on a room only basis, and is required when there is a joint tenancy for the whole HMO, eg with students. This will bring more HMOs into scope, as and when there is a new tenancy after 2028. Given that HMOs tend to have a higher turnover of tenants than single lets, this means HMOs will need to be ready for 2028.

The government is doing this to ensure the whole building meets the same standards as other rental properties. 

The December consultation proposes a “24-month transitional period for any HMO landlords newly brought into the scope of the regulations to obtain a valid EPC. This would also ensure reasonable time to comply with MEES requirements if these were applicable”. As with everything else, this is just a proposal.

Will I need to get a new EPC each time I sign a new tenancy agreement?

Currently an EPC is valid for 10 years, and you don’t need to renew it for a new tenancy if it is still valid.

However, the December consultation proposed that rental properties will need a valid EPC at all times. This is just a proposal (as is everything!), so it has not been confirmed. 

If landlords do need to have an EPC at all times, from the second half of 2026, landlords will begin replacing their properties’ existing EPCs with a new EPC once they expire, even if they have a continuing tenancy. It’s possible that a property with an EPC C now might drop to an EPC D.

I have EPC Cs – should I renew them before 2026?

Properties with EPC Cs under the old system will be deemed to comply with the new rules until their EPC certificate expires. In other words, they’ll be “grandfathered”.

If you would like to maximise your grandfather period, I would contact the assessor who did the previous EPC, tell them what improvements you’ve made since, and what they advise.

If it’s a marginal EPC C, say a 69 or a 70 (I have one of those), you might look at doing something to boost it a little, eg more insulation in the loft. But speak to your EPC assessor as it might equally go down!

Do I have to spend the full £15,000 for the cost cap?

The February consultation says that landlords must try the recommended improvements to achieve a new C without having to spend more than £15,000 inc vat.

The clock is due to start ticking in the second half of 2026, when the new metrics are due to come into force.

If you exceed £15,000 or the next recommended measure would push you beyond it and you still aren’t at “c”, you can register for the 10 year exemption.

You need to show you’ve done what you can. Say you are just under a C, but would need to spend £4k on a new heating system, and you’ve already spent £14,000, my understanding is you wouldn’t need to put in a new heating system if that would take you over £15k.

You don’t need to spend all the £15k if you manage to reach EPC C for less. 

Be aware that the government is also considering an affordability exemption that would lower the cost cap to £10,000 for some properties.

My property is worth £80k and does not merit spending £15k

For some properties, the value of the property does not merit spending £15k or even the “affordable” £10k exemption.

In this situation, check to see if you’re eligible for the Warm Homes: Local Grant, which is due to be launched in April 2025 by local councils. Landlords will receive 100% funding for the first eligible property up to £15k, and a 50% cost contribution for upgrading any additional properties, so long as the property is a D or below.

There are 3 routes to qualifying:

• Pathway 1. Eligible postcodes based on the Indices of Multiple Deprivation (IMD) Income Deciles (ID) areas).
• Pathway 2. The household receives specific means-tested benefits.
• Pathway 3. The household income is below £36,000, the income of every adult member of the household counts, other than those in full-time education.

There are also other grants available.

Will serviced accommodation need an EPC C?

At the moment, short term lets do not require a minimum EPC. However, the government is consulting on making it compulsory to have a valid EPC “irrespective of whether the occupier is responsible for meeting the energy costs”.

The government explains they are doing this: “to discourage landlords from changing their properties from privately rented properties to short-term lets to avoid improved MEES and reducing the availability of privately rented homes. This would add protection for tenants who are most at risk of being evicted, such as those in rural areas and popular holiday destinations where there are already pressures on housing supply, including within the PRS”.

Will EPCs expire after 5 years? 

In the December consultation, one of the questions was whether the 10 year validity period should reduce to, say, 5 years (although they give other options). They are also proposing to require landlords to renew them when they expire, even if the tenant doesn’t change. 

“The government’s preference is to allow all existing EPCs to remain valid until the end of their existing validity period and apply any new validity period to new EPCs.”

What if the freeholder won’t allow me to insulate or replace windows?

The February consultation says that if a landlord needs third party consent to carry out the energy efficiency improvements, eg a freeholder, planning authority or a listed building body, and they refuse to let you do what’s needed, or they impose unreasonable conditions, the landlord can apply for a third party consent exemption for 5 years. 

The landlord will need to produce evidence of refusal, and use “best efforts” to obtain consent. 

What if my tenant refuses to let me do the energy efficient upgrades?

If the tenant genuinely refuses consent, the February consultation says you will be able apply for an exemption that will last for so long provided the tenant remains in the property. However, this needs to be genuine, and you’ll need to provide evidence.

When they move out, you’ll have to do the work.

What if a landlord tries to game the system by telling tenants to deny consent?

If a landlord falsely claims that a tenant is refusing consent or if the landlord asks the tenant to deny consent, this will potentially be fraud. In order to qualify for the exemption, you would need to provide written evidence showing genuine refusal.

The tenants or anyone could report the landlord. 

Landlords should always comply with the spirit and intent of the law, and not seek to get around it by underhand actions.

If I buy a tenanted EPC D property, do I get a grace period?

Yes. The February consultation says you’d have 6 months from the date you become the landlord to make improvements or register an exemption.

So, if you take over a property that’s, say, EPC ‘E’ or below, you wouldn’t be penalised straight away, but you’d need to act fast, and make sure that you factor in the timelines before you buy. 

Do I have to insulate solid external walls?

In the February consultation, it states that the government “recognises that some fabric measures, such as solid wall insulation, may not be appropriate for particular properties.

There are a range of exemptions available under the existing regulations which landlords may register for in circumstances where fabric measures cannot be installed”.

Will I need to achieve EPC C if my house is listed or in a conservation area?

At the moment, listed buildings and heritage buildings (in a conservation area or of special architectural or historical interest) may be exempt from requiring an EPC – see the quote below is from Page 5 of A guide to energy performance certificates for the marketing, sale and let of dwellings.

The December 2024 consultation proposes removing that blanket exemption, meaning you would need an EPC for a listed or heritage property, even if the building is historically significant.

The aim is that owners and tenants have up-to-date energy performance information, with recommendations tailored so they do not damage historical features.

The government wants heritage buildings to have an EPC so that owners re informed of potential energy upgrades. They are exploring recommendations which don’t jeopardise heritage features.

However, that does not automatically mean you must achieve EPC C in every scenario. 

In the December consultation they said: “We will consider making changes to the EPC calculation methodologies to enable tailoring of recommendations for traditional buildings, those in conservation areas and other heritage buildings.

Final thoughts

It is clear that these two consultations contain proposals which would have significant implications for landlords. 

With the December consultation closing on 26 February, and the February consultation ending on 2 May, you still have time to submit your comments to the consultations.

>> Respond to December consultation: Consultation on Reforms to the Energy Performance of Buildings Regime (closes 26 February 2025)

>> Respond to February consultation: Improving the energy performance of privately rented homes in England and Wales – 2025 update (closes 2 May 2025)