The government announced in their Warm Homes Plan that “landlords will need to upgrade their properties to meet EPC Band C across two metrics by October 2030, unless their property has a valid exemption”. There will be a new cost cap of £10,000, which will reduce to 10% of the value of properties worth less than £100,000.
Also, from 1 October 2029, the way in which EPCs are measured will change, and instead of the cost-based “Energy Efficiency Rating” or EER metric, using the SAP (and RDSAP) methodology, the methodology will change to dual metrics under a new Home Energy Model.
The first of the dual metrics under the Home Energy Model is “fabric performance”, which is roughly similar to the current EER, albeit that the current EER is a cost-based metric, and is affected by all aspects of a property, not just building fabric elements.
Landlords will then have a choice of either the Heating System Metric (under which a gas boiler would not receive a C) or the Smart Readiness Metric (solar panels, batteries, smart meters).
There will be a transition period when Home Energy Model will run alongside the current EER from the end of 2027 until 1 October 2029. From 1 October 2029, it will be compulsory to use the Home Energy Model system.
Importantly, if a landlord receives an EPC C under the current EER regime before 30 September 2029, that EPC will be “grandfathered”, which means that the landlord will be deemed to comply with the new rules until it expires.
This means there is a short period of time to obtain an EPC C under the current rules, before it will be compulsory to be assessed under the new Home Energy Model.
I’m a landlord with four late Victorian and early Edwardian terraced houses, all of which have EPC Cs. In this blog post, I share how I managed to increase the EPC rating for one of the properties from an EPC E (48) to EPC C (77). It will help those landlords who want to improve their rating to an EPC Band C before the rules change.
Sharing advice from Chartered Building Engineer and EPC expert, Graham Kinnear, this blog post includes 5 practical tips to help you reach EPC C.
>> Related Post: The proposed new EPC energy efficiency rules for landlords explained
Tips to improve your EPC rating to an EPC C at a glance
What EPC rating do landlords in England need now (2026)?
Under the current rules for landlords, known as the “Minimum Energy Efficiency Standards” or “MEES”, domestic private rented properties must have an EPC rating of at least a Band E, unless the property has a valid exemption.
A private landlord must commission an EPC before they market a property to let. (See below for more detail).
The above image is from the EPC of my first buy to let, which I bought in 2019. It’s a mid-terrace Victorian house with a cellar. It shows the then current energy efficiency currently, as calculated by the software, and its potential for improvement to a 72. It’s not always accurate, as the last EPC rating was a 77 (see image at the top of the page).
Here is more detail:
Which rental properties need to have EPCs?
All domestic private rented properties must have an EPC of at least Band E, or qualify for an exemption.
Section 42 of the Energy Act 2011 defines “domestic private rented properties” as assured tenancies and tenancies regulated by the Rent Act 1977. This means that the MEES rules don’t apply to high and low rent tenancies (above £100,000 pa, and below £1,000 pa in London and £250 pa outside London respectively) or tenancies with a resident landlord.
Listed properties do not currently need an EPC, although the requirement is due to be introduced on 1 October 2030. Listed properties may well qualify for one of the exemptions.
There is currently a cost cap of £3,500 for spending to reach an EPC E, which means that landlords are not required to spend more than £3,500 to reach an EPC E under the present rules.
Here are the current exemptions from the Minimum Energy Efficiency Standard of an EPC E:
All relevant improvements made exemptions (with links to the government pages):
- All relevant improvements made exemption
- High cost exemption
- Wall insulation exemption
- Third-party consent exemption
- Property devaluation exemption
- Temporary exemption due to recently becoming a landlord
If a property qualifies for an exemption, the landlord must register it here: Register a private rented sector energy standards exemption.
When must a landlord obtain an EPC?
The requirement for an EPC is triggered by marketing a property for let. A landlord or their agent must make available a valid EPC to the tenant by the time they view the property, if not before.
If the property doesn’t have a valid EPC when the landlord wishes to let the property, they must commission an EPC before marketing the property and use all reasonable efforts to have one within seven days.
However, an additional 21 days are allowed if the landlord made reasonable efforts to obtain the EPC in the first seven days.
The advertisement or listing must show the energy performance indicator, which is the coloured graph with the numerical score and letter. The landlord must give a full copy of the EPC, including the assessor’s recommendation report, to the person who rents the property.
How long is an EPC valid for?
An EPC is currently valid for 10 years, although an owner can commission a new EPC at any time.
Landlords often update an EPC after carrying out energy efficiency improvements, although that isn’t compulsory. I did this in June 2026 on one of my early Edwardian houses, as I had made some improvements (including more insulation, new window and a new UPVC back door). The EPC increased from EPC C (72) to EPC C (76).
I think this is worthwhile as it keeps the EPC up to date, so you know where you stand
Do landlords need to renew EPCs for existing tenants?
No. Once a property has been let, a landlord is not currently under an obligation to obtain another EPC if it expires while tenants are in the property.
If you do get a new EPC, you’ll need to serve them with a copy of the new EPC certificate.
Consequently, it may be that some Rent Act tenancies do not have an EPC, as the tenants may not have moved.
When letting a property to new tenants, the EPC will need to have been done within the last 10 years.
Are grants for energy efficiency improvements available for landlords?
Yes, theoretically. Privately rented properties can be eligible for Warm Homes: Local Grant funding.
The government advice is to “contact your Local Authority directly if you are a private landlord and support an application for the Warm Homes: Local Grant for your rented property”.
You can also check if you’re eligible for the Energy Company Obligation Scheme.
What is the average EPC for the private rented sector?
In the private rented sector, Band C is now the most common energy efficiency rating, according to figures published in 2025. However, half of privately rented homes are still below band C, and those that are tend to be the older, harder properties.
It will be harder to improve the remainder, precisely because the properties below C are disproportionately older.
The 2023-24 English Housing Survey puts the average cost of bringing a rented home up to band C at £6,864. That rises to £10,788 for homes built before 1919, and almost £17,000 for those rated F or G. Around a quarter of all the homes that still need improving would cost more than the £10,000 cost cap.
Note that these are modelled figures, simulated using the government’s Standard Assessment Procedure (SAP), and are not based on what landlords actually spend to make improvements. With recent inflation on labour and materials, the cost is likely to have increased.
How to improve an EPC rating to C
The task of having to climb from EPC Band E to Band C is enormous. Very few landlords will be able to fund this out of free cash flow, unless they do it over a long period.
As mentioned above, the metrics are due to switch to the Home Energy Model in 2029, so this section is only relevant for the current system. The proposed new rules for minimum energy efficiency standards won’t just focus on the energy cost, but will take into account other metrics relating to the fabric of the building, the heating system and smart readiness.
Also be aware that any costs incurred since 1 October 2025 will count towards the new £10,000 cost cap.
In order to try and make this section as practical and helpful as possible, I’ve picked the brains of two experts. Firstly, Chartered Building Engineer and EPC expert, Graham Kinnear of Graham Kinnear Property Consultants. Secondly, Thomas Conneely, gives the perspective of a fellow property investor. He’s a Chartered Surveyor and founder of East Twenty, a property investment and advisory company.
I also share what I did to increase the EPC rating of E (48) on a mid-terraced late Victorian property to a high C (77).
>> Related Post: The proposed new EPC energy efficiency rules for landlords explained
1. Start with the EPC’s own recommendations
The very first thing to do is to study the existing EPC for your property (or one you’re thinking of buying). You can download it using the government checker. It will have a breakdown of property’s energy performance, which states the assumptions and the score.
Check whether any of the assumptions for the last assessment were incorrect. Next, think about whether any of the problems have been addressed since the date of the EPC.
In my example, the assessor made the assumption there was no roof insulation. The word “assumed” means the assessor didn’t check, probably because they didn’t have a ladder with them. There was actually 100 mm of insulation in the loft, according to the previous EPC. Yet, neither the owner nor the managing agent who supervised this assessment noticed this big anomaly.
Lesson: don’t rely on others! Check everything yourself!
When you look at the EPC, do note any quick wins, like the LED lighting, even if this will only improve the EPC by one point. However, one point is one point, and every point helps. It will also benefit your renters. As Graham Kinnear points out, it will reduce the electricity consumption on the lighting by up to 90%.
This is potentially the most useful part of the EPC, assuming it’s accurate. (This one turned out not to be accurate as the next EPC was a 77). It shows how many points you may potentially get if you carry out each recommendation.
For this one, I knew the previous owner had replaced the old boiler with a condensing combi boiler, so I could take that off my to do list.
However, every building is different, and your priorities for your plan of attack will depend on what will give you the most points. You should also take into account what needs doing to your particular property.
For instance, I insulated the suspended floor with 150mm insulation as the cellar ceiling had started to fall down and it made sense to add insulation when putting in the new ceiling. This cost me almost £3,000, including taking out the old ceiling and replacing the rotten wooden frame window with double-glazing. As I needed to replace the ceiling and window anyway, it made sense to do it in a way that would improve my EPC.
The quality of the recommendations vary, and this one didn’t even mention improving the insulation in the loft, which made a real difference.
Although I didn’t do it myself, it might be worth obtaining advice from an EPC expert, who can model what changes might move the needle for you.
2. Insulation: loft, suspended floor and (sometimes) walls
Graham Kinnear advises to start first with the insulation. Houses are in essence boxes, and “an EPC in broad terms models the building’s ability to retain heat”. Anything you do to increase its ability to retain heat will help your EPC rating.
The easiest place to put insulation is usually the loft, unless it is boarded. Going from no insulation to 300 mm will increase the EPC score by around 8 or 9 points (something not mentioned in my previous EPC!). Graham adds you will get little benefit from an EPC scoring perspective if you increase the insulation beyond 300 mm for existing buildings.
Do not use spray foam insulation. To read why you shouldn’t, this has a good summary: House of Commons Research Briefing: Spray foam insulation and mortgages.
Solid wall insulation is very expensive, and very disruptive and messy if you go back to brick. But this will lead to larger savings on heating bills. Cavity wall insulation, on the other hand, for more modern houses is cheaper. Any sort of wall insulation is likely to have a big impact on the EPC rating.
However, Thomas Conneely explains there are some practical drawbacks to insulating walls. “It’s important to understand the walls are solid, so moisture has a harder time escaping and circulating in the air”. This means that landlords need to explain to tenants that they need to keep an eye on mould. This is particularly true if tenants use radiators or unvented tumble dryers to dry clothes with the windows closed. Or not putting on the extractor fan when having a shower. Landlords should explain this to their tenants.
Graham Kinnear warns about the considerable upheaval to tenants if wall insulation is done when the property is tenanted. It’s better to leave back to brick work for when the property is empty. Get advice from an expert, as old walls still need to breathe and not trap condensation.
In 2022, I increased the loft insulation by 200mm to 300mm, which should get me a “very good”. (There was previously 100mm insulation in the loft, which the previous assessor had not taken into account). This extra roof insulation cost £800 at the time.
As I mentioned above, I also took the opportunity to add insulation to the suspended floor when replacing the cellar ceiling, also helping the EPC rating. The suspended floor insulation itself only cost £150, but the total cost to take down and replace the crumbling cellar ceiling was £2,300, excluding the new window. I provided proof of this to the EPC assessor, which included the paid invoice and photos.
Next time, I will include an “inspection hatch” somewhere so that the assessor can easily measure the insulation and take a photo.
>> Related Post: How should landlords best tackle damp and mould?
3. Boilers, heating, thermostatic radiator valves
Heating systems are an important part of a property’s EPC rating. If your existing boiler is the old fashioned type with a hot water tank, replacing it with a modern condensing combi boiler will considerably improve your energy efficiency rating.
The new boiler also needs to be programmable with a thermostat. Thermostatic radiator valves should be added to at least 50% of the radiators. You can get extra points if your property has different zones, with different thermostats. For instance, one for living space downstairs, and the other for the bedrooms upstairs.
Surprisingly, no extra points are currently given for a smart thermostat. However, if you’re putting in a new boiler, it makes sense to put one in. I have them in all my rental properties. They’re very popular with renters, as they give them full control over the heating from their phone. It also shows them that their landlord is looking after their interests.
Note that the government consultation say that they are proposing that “no home that relies on a primary fossil-fuel space or water heating system (such as a gas boiler) should be able to achieve a C on the new Heating System Metric”. As explained above, the Home Energy Model is due to be the only methodology to assess EPCs from 1 October 2029. Landlords will be able to choose the Smart Readiness Metric as an alternative metric, but the detail is yet to be confirmed.
4. Double and triple glazing
Installing double or secondary glazing is very costly, and has a lower impact on the EPC than installing insulation per £ spent.
For my EPC, the rating for the windows came out as “poor” because it was only partially double-glazed. Also, the EPC states that the rating would improve a mere 2 points if I installed double-glazing in the rest of the windows. Replacing the windows should be a lower priority than increasing loft insulation, because of the cost. It’s also possible to replace the windows gradually, starting with the ones in worst condition.
(As an aside, it’s likely that double glazing will have more of an impact under the “fabric first” metrics of the new EPC system).
In 2022, I replaced the 3 small windows in my Victorian buy to let that need replacing anyway. The frames had started to rot, and it was time to do something about it. These 3 small windows cost £2,000. This just left the main front elevation to do.
After a bit of shopping around, I decided to take the plunge on the final big sash windows in 2023 as they were drafty. I replaced the front elevation windows shown in the image with six double-glazed UPVC windows. You can see them being installed in the image above. This cost me £5,400 inc VAT. Why six windows? The bay window itself has four separate windows, as you can see.
I’m delighted to say that this all contributed to improve the EPC rating of my property to a high C of 77.
5. Be present for the EPC assessment yourself
As the EPC assessment is so important, this is not something to delegate.
Find someone local, and go direct. An easy way to find someone is to look at the Find an energy certificate on GOV.UK to see who has assessed similar properties in your area.
I recommend being there for the assessment yourself, so you can provide the necessary proof of your improvements.
Contact the EPC assessor beforehand to ask what evidence will be helpful or necessary so that any improvements are correctly reflected. For instance, Fensa certificates for new windows, paid invoices showing insulation has been installed, photos of work undertaken, mention if they need to bring a ladder for the loft.
Also check that an incorrect assumption about the thickness of the roof insulation isn’t made, just because the assessor doesn’t check the loft (see below). If this isn’t practical, then make sure the person you choose to be there has been fully briefed and has the supporting documents. Don’t leave it to your tenants to do.
Final thoughts
With the EPC metrics due to change to the Home Energy Model on 1 October 2029, and properties who already have an EPC C able to benefit from transition arrangements until their EPC expires, it is worth looking at whether you can make improvements so that you receive an EPC C certificate before the rules change. Anything you spend after 1 October 2025 will count towards the £10,000 cost cap.
It’s worth checking whether you’re entitled to a grant, for instance under the Warm Homes: Local Grant.
Watch this space. I will keep this blog post updated.
>> Related Post: The proposed new EPC energy efficiency rules for landlords explained
You may also find useful
- Why ESG and sustainability matter to landlords
- How to self-manage your own rental properties
- My 5 biggest mistakes as a newbie landlord
- What all new landlords need to know
- How to find renters without letting agents
- What landlords should provide in unfurnished properties?
I couldn’t agree more with your points in this post about EPC landlords. It’s refreshing to see someone addressing this issue, and your suggestions for tackling it are spot on. Looking forward to reading more.
Thank you! Much appreciated.
Some amazing insight into the impact of EPC measures, thanks for such a detailed article.
Suzanne, (so as not to hijack your post) I’ve separately contacted you RE: retrofit WWHRS for this type of property. It would be good to discuss when you have a moment: ellis@recoup.co.uk
Oh, it’s worse than I thought. I see that step 1 of 1-6 is to fit internal insulation. So the work you have done will not achieve a C rating. How are you going to do that, even if you do the wall insulation?
I’ve not fitted wall insulation, but have done roof insulation, new windows and the cellar ceiling, plus a new efficient boiler with thermostatic radiator valves. I’ll see where this gets me, but based on my other similar properties with a C, this should be enough. I replaced the windows as they were rotten and drafty. Fingers crossed.
Great article – Thankyou – VB
Three points, following a good article – thank you:
– while EPCs have a life of 10 years, you don’t need to get a new one if there hasn’t been a change of tenants (two lots of agents wrongly advised on this point);
– the average for all properties in England is EPC ‘D’, so expecting landlords to do better than average would be a bit steep, particularly if measures to get to a ‘C’ would be very expensive. Some help to landlords, to in turn help tenants, wouldn’t go amiss; and I’m guessing that PRS tenants might be some of the poorest households who could do with lower bills (but not very high rents to pay for the expensive measures); and
– if we are going to be required to meet a higher EPC standard, some of the anomalies in the EPC system should be sorted out first.
I’m selling a 1970s house that I got up to an EPC ‘D’ though a combination of a Government Fossil Fuel Obligation scheme and my own investment. But sale prompted by the then imminent loss of Section 21. So a new owner can install the solar PV; and selling agents said not worth me doing this if selling.
Good points. Thank you.
Small correction! Well, quite major actually.
You said you don’t need to get a new EPC if there hasn’t been a change of tenants. In fact, you don’t need to get a new EPC even if you have had a change of tenants. The EPC doesn’t change just because the tenant changes. It lasts 10 years, regardless of how many tenant changes you have.
Yes, I know. You seem to have missed the part when I clearly state: “An EPC is valid for 10 years, although an owner can commission a new EPC at any time. Landlords often update an EPC after carrying out energy efficiency improvements, although that isn’t compulsory. It’s also not required to renew the EPC if it expires while tenants are in the property. If you do get a new EPC, you’ll need to serve them with a copy of the new EPC certificate. When letting a property to new tenants, the EPC will need to have been done within the last 10 years.”
Can I just confirm , I’ve an existing valid EPC D and a tenant who is currently in the property that I’ll need to upgrade this to EPC C by 2030?
That is what the proposals currently say, but be aware there are exemptions, which I explain here: https://theindependentlandlord.com/new-epc-rules/
If there’s to be a cap on the amount you have to spend, then I wonder when the clock starts ticking on that spend. I’m not doing any EPC improvements right now as any spend now may not count towards that cap. Ludicrous I know, but in properties where you know you’ll be spending to that cap, it makes financial sense. We need clarity and quickly.
I agree. I’m aware that all the money I’ve spent since 2019 will be discounted if there’s a cap, but I’m hopeful it’s enough for a C based on my other properties that are similar. I too wish they’d publish the details as soon as possible so we can all plan.
Points to consider re insulation
Many commonly used insulation materials are *hygroscopic*. They absorb moisure from air humidity – worse near salt-water. Over time, such “insulation” acts like a “heat bridge”, conducting warmth out, cold in, dampness in, eventually with the reverse effect of insulation.
Many reports of damp and mould are due in part to this. effect. In older properties it can be feasible to insulate inside (losing a few inches of room size) using styrofoam-style boards between the outer wall and the inner plasterboard or similar, not forgetting ventilation. A similar approach can be used with a suspended floor : wedge styrofoam-style insulation boards between the joists. An experienced builder will know the best way to do this in a given property. Styrofoam-style boards offer reasonable cost-effectiveness.
Upshot :undertake thorough scientific research of longterm properties of insulation materials (hygroscopic properties). Some installers will not know
– and/or have their own priorities. Replacing loft insulation rolls is usually feasible. Replacing cavity-wall insulation is almost impossible.
Micha
Styrofoam is highly flammable…. not a good idea!!!!
Great article! What I am having a problem finding is any information about leasehold flats that are rented out particularly where the freeholder prohibits in the head lease from carrying out any such work as installing new windows and wall insulation. My freeholder is a housing association that only carries out any such work (if they deem necessary) once in a decade. Do you know if any exemptions are proposed for this kind of situation?
Many thanks.
Such an exemption already exists as the ‘Consent’ exemption and is proposed to continue under MEES from 2030 as well. You’d be expected to implement any other ‘relevant energy improvement measures’ (can’t quite remember the exact vocabulary off the top of my head), possibly to the value of the cost cap and still be below the required rating level before being deemed to qualify.
“80% of landlords want stricter energy efficiency rules on their properties”, apparently.
https://www.smf.co.uk/80-of-landlords-want-stricter-energy-efficiency-rules-on-their-properties/
Just a few words of caution; with the Green Homes Grant I had immense difficulties and looking back wish I’d done without. They couldn’t find my properties on their database and were only able to use Land Registry rather than Council Tax records. Then having overcome that for anti avoidance they had an audit function for applications. So you would make an application; it would be recommended by the department; it would the be sent to audit where it would be bounced into the ether and you’d only find out about this by chasing. It then went back to the approving authority only to be bounced again and this cycle continued multiple times. They knew the system was rubbish and had friendly intelligent people at the end of a phone whose job as far as I could make out was to calm people down.
If I had calculated my time cost there would have been the opposite of a saving. One of the 3 great lies holds true “I’m here from the Government and am here to help you!”
We can add a couple more. “Good landlords have nothing to fear from the rent reforms” and ” We are not introducing rent controls”
Thank you so much for this Suzanne – it’s super helpful to have it all laid out like this! Can I just double check – the household means the tenants? The only pathway my flat would fit under is the “household income” one – but I rent to students. Does this mean I am not eligible?
Hi. Yes it means the tenants and any adult permitted occupiers, so far as i’m aware. I can’t see why you won’t be eligible, but let’s see when the scheme comes out.
Greetings from a very sunny Kenya Suzanne,
I stumbled upon your website this very day, congratulations on building a terrific site!
I too used to be a lawyer for a leading Russell Group University, before jacking it all in at 52 and initially hoofing off to Spain.
I have been letting out property “oop North” since 2011, where I bought-up a bunch of ex-local authority 3 bed semis which have proven to be a terrific investment. Like you I manage all my own property, dealing directly with my tenants that I find works really well.
All my properties without exception, whilst well-built, currently rate at EPC Band D. So my strategy to get up to Band C and be knocking on the door of Band B is the installation of solar PV. A ten panel 4.35kW array can now be had fitted for as little as £4,450 which is around 15 points on the EPC scorecard. However, as you will appreciate, this cost cannot currently be offset against ones tax bill. So I continue to adopt a wait and see approach as to whether Miliband and Reeves decide to incentivise the PRS. (I think they might – or rather they may have to if they wish to see any meaningful progress).
I should add that I am deeply sceptical that this government will be successful in implementing their EPC proposals by the 2030 deadline. The prospect of thousands of tenants being put on the streets by non-compliant landlords is the stuff of nightmare.
In any event the Labour Party has to stand for re-election again no later than mid-2029 and on present form they may struggle to get returned to government.
Further, industry is now pushing-back against the speed of the “green revolution”. In particular German car manufacturers (BMW, Volkswagen and today Bentley – owned by Volkswagen) are now demanding the European Union allows them to continue to manufacture ICE vehicles beyond the imposed 2030 deadline until at least 2035 as demand for EV´s has fallen off a cliff.
(NB. Solar PV is currently VAT zero rated until 31st March 2027).
Toodle pip!
Thank you for your really interesting comments. I suspect you are right about 2030. You can currently set off the cost of solar panels against capital gains, but I agree it would be sensible to allow them to allow this to be set off against income.
I have two detached bungalow properties which both have cavity wall insulation, new 94% efficient condensing combi boilers, double glazing in plastic windows throughout, and loft insulation below boarded lofts. Both only make EPC D because seemingly the loft insulation isn’t 270mm thick due to the boarding (surely the board itself has some insulation value but I’m told it doesn’t count!). I could put more insulation in the lofts getting rid of storage space which one tenant uses a great deal, and I could have insulation below the flooring in suspended netting (in some properties there won’t be room to do this) but I am at a bit of a loss as to what further I could do.This everybody must make EPC C or above will cause many of us private landlords to sell up. What will the government do then? I think a rethink is required from the present draconian and in many cases impractical ruling.
Best to get advice from an EPC assessor to go through the options.
Suzanne, am I missing something here?
Your EPC’s advised improvements only take you to a D(63), and they included internal or external wall insulation, which you haven’t done.
You already had partial double glazing and changing the rest has only added 3 points. You said that the previous owner had already installed a new boiler, so you didn’t need to change it. (But it’s on the list, and only adds 3 points anyway)
So, exactly how did you achieve a score of C(77)?
I didn’t change the boiler – that would have been daft. I said it had been changed since the last EPC was done, and as it was previously an old fashioned immersion tank style boiler, that made a big difference. The assessor told me that a better boiler made a big difference to the score.
I changed the windows primarily because the windows were drafty and rotten, being the original Victorian windows. These were the big windows, and made a difference – the 4 for the bay window in the front room shown in the photos, two in the main bedroom, one in the second bedroom, one in the cellar and another in the bathroom. The existing UPVC windows were only in the downstairs loo and the kitchen. It was therefore mostly single glazing before.
I increased the loft insulation to 300mm, and the previous EPC had it assumed as 0mm (in fact there was 100mm there). I added 150mm insulation to the cellar ceiling, and re-plastered it. I provided proof of this to the EPC assessor.
The previous EPC was wrong as it missed the insulation in the loft. The advice in that earlier EPC doesn’t seem right as I have similar properties in the area and they are all rated C, done by different assessors over a 5 year period. It’s not the only house in this street to have a C, by another assessor.
This assessor took a lot of time, actually went into the roof, needed proof of the insulation in the cellar.
As I say in the blog post, the EPC system isn’t fit for purpose, and it’s really important to make sure the assessor does a proper job and doesn’t just “assume” there’s no insulation in the loft
Suzanne, some good POV here.
As a landlord of 25 years I have been preparing my portfolio over the last few years with EPC upgrades. I was frustrated that the proposed dates have been altered and feel that landlords who have started to work on EPC upgrades have been forgotten about in all the equations. I am concerned that goal posts will be moved on how to grade the energy efficiency, properties that I have upgraded to a C will then be subject to more additional spending to meet even higher levels. to be honest, I can’t see where the buck will stop. Worse still, proposed changes are dragged out, I feel in limbo, EPC assessors don’t know what’s coming – who does? Landlords are an easy target here for the government. I mean the change from a E to a C baffled me, the letter D would have made sense for a number of years and then introduced a higher level at a later date. All this uncertainty has led to good landlords selling up, which is a winner for the government, but the PRS is being squeezed. I agree that badly insulated homes need to be upgraded. I wonder if and when the private home ownership sector will come under fire for EPC upgrades? It is a bleak outlook.
I totally understand your perspective. I’m one of those who has been upgrading the energy efficiency, and I’m just relieved to have all now as EPC C. We don’t know all the detail or the exceptions and I hope pragmatism will prevail, and that landlords will take up the grants. It’s certainly an incentive to select tenants on benefits!
If I spend up to £15K on getting property from D to C but it still does not achieve a C then I assume I can go the exemption register for the 5 years BUT after this exemption time limit expires am I expected to pay up to another £15K to try again to get my D to C again before I can apply for another 5 year exemption?
Good question. I’m not entirely sure, but I think that any money spent after 2026 will count.
What about flats? Mine has an energy rating of E and the EPC recommends installing flat or sloping roof insulation to bring it up to D. Am I really expected to foot the bill for improvements to the roof, given that there are three other flats on the top floor?That’s assuming I can get permission from the freeholder…
Hello. You might come under this exception, which I go through in https://theindependentlandlord.com/new-epc-rules/
“Third-Party consent exemption including freeholders. If the improvements needed require consent from the freeholder, planning authorities, mortgage company or the tenant, and they deny the consent, the landlord can register for an exemption if “despite best efforts that consent cannot be obtained or is given subject to conditions which cannot be reasonably complied with”. Where it is a lack of tenant consent, the exemption will last until the tenancy ends, and then the landlord would need to carry out the work.”
If the loft is boarded, what rules apply?
I have one property that definitely has loft insulation but the tenant decided to board it.
I don’t particularly have an issue with that except that i don’t know what the effect will be on the EPC calculation
In short, if the assessor doesn’t have reasonable access to determine the level of insulation present in the loft due to the scenario you describe, the insulation status will be recorded as ‘Unknown’. This will firstly suppress any recommendation from appearing on the EPC to increase the level of loft insulation, and the methodology also assumes a certain level is present depending on the construction dateband of the building (or extension, etc). This assumed level used to be zero mm for older datebands up to 1966 iirc, then gradually increasing for newer datebands up to present day depending on the mins required by building regs. With the update to RdSAP 10 on 15 June 2025 the methodology now assumes a minimum of 100mm mineral wool right up to 1982 iirc, then increasing from there. That first 100mm however actually gives the biggest proportion of gain in EPC rating from loft insulation, as I describe on my webpage. Hope that helps understand how it works in this situation.
Hi Suzannah
Thank you for writing a good post about how to improve your EPC, the first step for a landlord is to arrange for an assessor to carry out a draft not lodged up to date EPC to see where the property is at today, the next step is for them in conjunction with an energy efficiency advisor to carry out different simulations on what are the lowest cost measures need to be done to reach C, different types of properties will require different measures and get different EPC points ie if the property is detached or mid terraced. Many properties have an EPC D and in reality on the dozens of properties I have advised on how to increase from D to C, the actual cost is often less than £1.5k For Any works actually carried out you should keep the invoices and take photos to prove it. If landlords want to help tenants there are various measures landlords can do which cost nothing. I have been a portfolio landlord and developer in London for almost 2 decades and I can see it through a landlords eyes as I am one myself, my advice is for landlords to get their property to EPC and register it for the next 10 years now, as it will become more expensive in the future when the rules change.
Quite a good article. I’d like to make the following observations to help even further:
1) EER is the current metric, and SAP (&RDSAP) is the current methodology. We need to take care about interchanging the use of these two terms.
2) The Building fabric metric is NOT roughly similar to the current EER. The EER is a cost-based metric, and it is affected by all aspects of a property, not just building fabric elements.
3) “A landlord must obtain an EPC before they market a property to let” – that’s not currently true – the marketing of a property to let privately is the trigger to requiring an EPC, but the landlord has 7 days plus 21 (28 in total) to get one in place.
4) “…and its potential for improvement to a 72. It’s not always accurate” – The list of available Recommendations is fixed in the methodology, and their presentation on the certificate is very prescriptive. For example with your loft insulation, if access was not available to the loft at the time of assessment (I don’t think you were there yourself, were you?), because it was not safe to get into the loft, then the methodology in the past assumed zero loft insulation was present in a Victorian property (it depends on construction age). This will explain the difference – because with ‘assumed’ loft insulation for a standard pitched roof, the recommendation for increasing the depth of loft insulation is suppressed on the certificate, and that’s done for good reason. By the way, since the methodology was updated to RDSAP 10 on the 15th June 2025, it now assumes a minimum of 100mm loft insulation is present.
5) “Although I didn’t do it myself, it might be worth obtaining advice from an EPC expert, who can model what changes might move the needle for you.” – This is absolutely critical but you need to find a decent one.
6) “an EPC in broad terms measures the building’s ability to retain heat” – in reality, the current EER metric MODELS the running costs of the property, related to floor area. Sure, improving the building fabric improve the rating, but so too does improving any other aspect of the property.
7) “Heating systems are the foundation of a property’s EPC rating.” – This is not very meaningful. As previously mentioned, all aspects of a property contribute to the EPC rating, but heating systems are indeed a very important factor.
8) “Thermostatic radiator valves should be added to at least 75% of the radiators” – The trigger is actually 50%.
9) “Surprisingly, no extra points are currently given for a smart thermostat.” – This has changed since the introduction of RDSAP 10.0.1 very recently. However, load and weather compensators listed in the PCDB have been recordable in assessments for a very long time, and I’ve written about these and many other aspects of EPC assessment on my website.
10) “…mention if they need to bring a ladder for the loft.” – Energy assessors are required to put their head and shoulders into the loft of a pitched roof as past of the assessment. Any assessor not bringing a telescopic ladder with them is not doing the job properly.
I’m qualified as a DEA. If you need to check anything about assessment methodology just let me know.
Thank you for your useful comments which I’ve incorporated.
Interesting article. Improving a property’s EPC rating is becoming an important consideration for many landlords. Alongside insulation and efficient heating systems, renewable energy solutions can also play a significant role in improving overall energy performance. We’ve also found that keeping solar panels properly maintained helps ensure they continue operating efficiently over the long term.
Do you think more landlords will start investing in solar energy as EPC requirements become stricter?
Very informative article! It clearly explains EPC requirements for landlords and the importance of improving energy efficiency. The practical guidance and updates make it a valuable resource for property owners preparing for future regulations.