On 21 January 2026, the government confirmed that private landlords in England and Wales will need to ensure their properties meet an EPC C by 1 October 2030 for all tenancies, unless they have an exemption.
However, there’s a lot more to the proposals than the headlines “it’s been delayed to 2030 and the cost cap is £10,000”.
In this blog post I break down the detail, and explain what landlords need to know about the new regime. This includes the transition arrangements, and what landlords will need to do to meet an EPC C under the new EPC metrics, once their pre-2029 EPCs expire.
EPCs are one of several big changes coming for landlords. For practical guidance on every stage of a tenancy, including the Renters’ Rights Act, there’s my bestselling book, The Good Landlord Handbook. If you have questions, you can ask me at twice-monthly webinars in The Independent Landlord Hub.
The new EPC rules at a glance
- Overview of the new MEES and EPC regime for landlords
- What are the new minimum energy efficiency proposals for landlords?
- What happens if landlords don’t meet EPC C by 1 October 2029?
- The MEES cost cap for landlords
- Other exemptions to the minimum energy efficiency standard
- How to register an EPC exemption
- Transition arrangements for EPC Cs as at 1 October 2029
- Implementation timetable for the MEES/EPC changes
- Other changes to EPCs
- Will the new EPC proposals affect HMOs?
- Enforcement and penalties
- Final thoughts
Overview of the new MEES and EPC regime for landlords
The government rolled out the new EPC regime for landlords in England and Wales in the government announcements on 21 January 2026 relating to the new policy paper, “Warm Homes Plan“, which “sets out how we will cut energy bills and upgrade homes”.
The important detail of the metrics for new EPC regime was set out a new consultation which close on 18 March: Home Energy Model:Energy Performance Certificates HEM methodology for assessing existing dwellings and producing new EPC Metrics.
Here is an overview of the new minimum energy efficiency standards (MEES) for landlords, before I go into more detail in the rest of the blog post:
- The new MEES. The MEES for private landlords in England and Wales from 1 October 2030 will be the equivalent of EPC C, unless the property benefits from a valid exemption.
- The new cost cap. One of the exemptions is the “cost cap” which is £10,000 for most properties, with a ‘Property Value Adjustment’ exemption where properties valued below £100,000 would be required to pay the equivalent of 10% of the property’s value. Expenditure from 1 October 2025 qualifies for the new cost cap.
- The new EPC metrics. The government is rolling out new EPC metrics, called the “Home Energy Model: Energy Performance Certificates” or “HEM:EPC”, which is subject to consultation. The HEM:EPC will replace the current Energy Efficiency Rating (SAP or RdSAP) methodology. The HEM was originally due to be launched later in 2026, but following the “outcome update” of 9 March, this is now due to be in “the second half of 2027”. It is due to become compulsory for new EPCs from 1 October 2029.
- Transition arrangements. If a property receives an EPC C before 1 October 2029, either using the existing EER methodology or the new HEM:EPC methodology, they will be deemed to have met the MEES until the EPC expires.
- EPC validity. EPCs will continue to be valid for 10 years.
- The new HEM:EPC methodology for EPCs. It is a two-step methodology, that is still subject to consultation:
- The first step is that a property must meet the Fabric Performance Metric, which measures the insulation, window quality etc. This will be similar to the current EPC, excluding the heating element.
- The second step, and this is where the big change is, landlords will need to either meet the Heating System Metric (which is basically a heat pump and even an efficient gas boiler would fail this metric) OR the Smart Readiness Metric (which is another word for “micro-generation”, such as solar panels).
- Therefore, when pre-1 October 2029 EPC Cs expire, landlords will need to invest in either a heat pump or solar panels, as well as having a well insulated property (although there is an exemption for wall insulation).
- Some grants will be available for landlords.
Of course, these rules may be watered down before they come into force, and grants may be available for landlords.
Further detail can be found in the government’s partial responses to the December 2024 consultation on Reforms to the Energy Performance of Buildings regime, and the February 2025 consultation Improving the energy performance of privately rented homes (82 pages).
Now I’ll dive into the detail.
What are the new minimum energy efficiency proposals for landlords?
On 21 January 2026, the government published its proposals for the minimum energy efficiency standards for the private rented sector in England and Wales.
As well as increasing the minimum energy efficiency standard for private rented properties from 1 October 2030, government is proposing to completely overhaul the way energy efficiency is assessed, by introducing new metrics.
New minimum energy efficiency standard (MEES) for landlords from 1 October 2030
The new MEES for private landlords in England and Wales will increase to the equivalent of an EPC C from 1 October 2030, unless they qualify for an exemption.
The existing way of measuring EPCs is based on the Energy Efficiency Rating (EER), which assesses the estimated cost of heating, lighting, and hot water in a property. The EER will be replaced by the new Home Energy Model (HEM), a dual metric standard, on 1 October 2029, after a transition period when both metrics will be available from the end of 2027.
What is the new Home Energy Model?
The new Home Energy Model (HEM) is the new underlying methodology that will be used for assessing the energy efficiency of homes. The HEM will replace the Standard Assessment Procedure (SAP) and Reduced data SAP (RdSAP), which use the cost based Energy Efficiency Rating (EER) model, and become compulsory to use for EPCs from 1 October 2029.
The HEM metrics have not yet been finalised. On 21 January 2026, the government launched the Home Energy Model: Energy Performance Certificates consultation on their proposals on how the new metrics should be calculated by HEM and where the band boundaries should be drawn for each metric.
It also sets out the government’s proposals for how the new headline metrics (Fabric Performance, Heating System, Smart Readiness and Energy Cost) should be calculated and “translated” into EPC scoring bands.
The HEM was due to launch in late 2026, but this has now been delayed to “the second half of 2027”. It is due to run alongside the EER until 1 October 2029, when the EER will be discontinued, and landlords will need to use the HEM.
What does the dual metric standard for EPCs mean?
Under the new rules for 1 October 2030, landlords must meet EPC Band C against two metrics, unless they had an EPC C under the current EER methodology on 1 October 2029. The first is the Fabric Performance Metric, and the second is either the Heating System Metric or the Smart Readiness Metric. The landlord can choose between the Heating System Metric and the Smart Readiness Metric.
This is a “fabric first” approach, because the landlord must first invest towards meeting the Fabric Performance Metric, and once the property meets this, or they register a valid exemption, they must then invest towards installing measures to meet their chosen secondary metric.
This means that once the building has met the Fabric Performance Metric (or have an exemption), landlords can choose either to install a heat pump to achieve a C rating under the Heating System Metric or improve the property’s “smart readiness” by, for instance, installing solar panels and a smart meter, unless they have an exemption.
A gas boiler would not achieve a C rating under the Heating System Metric.
I explain each of the metrics below, based on the proposals in the Home Energy Model: Energy Performance Certificates Consultation.
1. Fabric Performance Metric
The Fabric Performance Metric measures a building’s thermal performance, which means its ability to maintain a different temperature to its surroundings. For instance, the level of insulation in the building, window quality, and airtightness.
The consultation proposes taking an approach that is consistent with the C/D boundary in the existing cost-based EER rating and the C/D boundary on the new Fabric Performance Metric. The consultation states that this will” support understanding of the transition and help ensure that people who have previously installed measures (such as loft and cavity wall installation) continue to see the benefits on their EPCs”.
2. Heating System Metric
The Heating System Metric assesses the technologies used to generate heat for heating, cooling, hot water and cooking.
The consultation states that “systems with high efficiency and low carbon emissions, such as electric heat pumps and low-carbon heat networks, would always score a C and above”.
A gas boiler would not achieve a C rating under the Heating System Metric, but more efficient fossil fuel systems should score better than “higher-carbon inefficient fossil fuel systems”. Hybrid heating systems that include fossil fuels, such as hybrid heat pump gas boilers, would score a D or below.
Electric heating with no (or insufficient) thermal energy storage would always score a D or below. However, “electric heating with thermal storage, where the efficiency and use of off-peak electricity results in lower annual emissions than an equivalent direct electric system will typically score a C or above”.
The band boundary for a C rating should be set such that it does not incentivise fossil fuel heating systems. We are therefore 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.
Property owners will still be able to retain their existing fossil fuel based heating system: the purpose of setting the boundary in this way is to provide clearer information to consumers about the options they have for lower carbon heating systems
3. Smart Readiness Metric
The Smart Readiness Metric aims to assess the building’s potential to generate its own energy (called “micro-generation”), usually from solar panels, and to integrate smart technologies that can optimise energy consumption.
The consultation explicitly states “micro-generation such as solar, alongside a smart meter, would be sufficient to achieve a C rating”.
The consultation refers to take account “at least” the following technologies:
- Smart meters
- Solar PV and other micro-generation
- Electric batteries: shifting demand away from peak times, maximising the use of solar panels if installed, and potentially selling electricity from the battery when the system requires.
- Thermal energy storage systems with smart functionality: including heat batteries, storage heaters, and hot water cylinders.
- Smart heating controls and other demand management systems.
- Smart EV charge points: higher scores for bidirectional charge points that enable additional flexibility by allowing vehicles to discharge energy back to the home or grid.
- Connection to the electricity network: the type of connection sets the baseline or its ability to be smart ready, as unsuitable connections may restrict households from installing smart appliances. For instance, single/three phase connection, whether the property is looped (shared service cable with neighbours).
It’s not yet entirely clear what the Smart Readiness Metric will mean in practice for the average rental property.
What happens if landlords don’t meet EPC C by 1 October 2029?
If privately rented homes that do not achieve a score of Band C or higher on their EPC (using the EER methologoy) before 1 October 2029, they will need to improve their property to meet an EPC C set against new HEM:EPC metrics before 1 October 2030, or register for a valid exemption.
Before they do this, they will need to commission a new EPC that shows the new HEM metrics to make sure the action they is informed by the recommendations in the EPCs. Once landlords they have carried out the retrofit works to reach an EPC C, or register for an exemption, they will need to commission another EPC before 1 October 2030 to show compliance.
Landlords will be able to count the cost of getting the EPCs against the cost cap.
The MEES cost cap for landlords
What is the new MEES cost cap exemption for landlords?
The government has confirmed there will be a cost cap of £10,000 per rental property. (This contrasts with £15,000 in the 2025 consultation).
The cost cap reduces to 10% of the property’s value if the property is valued at under £100,000. This is called the low-value property exemption.
If the property remains below the standard once they reach the cost cap, the landlord may register the property for a ‘cost cap’ exemption, valid for 10 years, and can continue to let the property.
Costs incurred from 1 October 2025 will count toward the cap.
Will the MEES cost cap increase with inflation?
Yes. Although the 2025 consultation proposed a cost cap of £15,000 per rental property, with no index-linking, the government response to the consultation (page 45) stated that the cost cap would be reviewed every 5 years.
The consultation states that the reason for this was to “take into consideration inflation to the cost of purchasing and installing measures, as well as other potential factors that could affect the impacts of the policy”.
There will be no inflationary increase until after 1 October 2030.
Other exemptions to the minimum energy efficiency standard
A number of exemptions will be available to landlords if they fail to reach the minimum energy efficiency standard by 1 October 2030:
- Low-value property exemption. There will be an exemption for properties worth under £100,000, ie where the spending cap where £10,000 would represent 10% or more of a property’s value. The cost cap would be set at £10,000 or 10% of the property’s value, whichever is lower.
- ‘All relevant improvements made’ exemption: No further recommendations on EPC or from an approved report showing no further improvements possible, and the property remains below the standard.
- New landlord exemption. If a property is purchased with tenants in situ, landlords would have six months to comply before enforcement begins. However, it is important that they register for an exemption, including exemptions that the previous owner had, as they do not transfer to a new owner.
- Third-Party consent exemption including freeholders. This is an existing exemption – see the government guidance. Here are the key points:
- The third-party consent exemption applies where 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”.
- The exemption lasts 5 years, but where it concerns a lack of tenant consent, it will last until the tenancy ends or is assigned to a new tenant, and then the landlord would need to carry out the work
- ‘Solid wall insulation’ exemption: A 10 year exemption where a landlord could choose not to install solid wall insulation, if this is the only remaining measure available to bring the property up to standard against the Fabric Performance Metric. The decision will need to be documented.
- ‘Negative impacts’ exemption: This 10 year exemption will combine two existing exemptions and additionally allows landlords to evidence when a measure would negatively impact their property.
How to register an EPC exemption
In order to benefit from an exemption to the minimum energy efficiency rules to have an EPC E now, and an EPC C from 1 October 2030, landlords need to register for an exemption on the PRS Exemptions Register.
You will need to be able to upload the required proof that you qualify for the exemption.
Note that if a landlord buys a property that is subject to an exemption, they will need to re-register the exemption as it lapses when a property is sold.
Transition arrangements for EPC Cs as at 1 October 2029
The government wishes to encourage landlords to make improvements to the energy efficiency of their properties in advance of the 2030 deadline.
What if a property is an EPC C on 1 October 2029?
If a property has an EPC C or above using the current Energy Efficiency Rating (EER) metric before 1 October 2029, it will be considered compliant until that EPC expires.
Depending on the date of the EPC, this may expire in 2039, as the government has announced they will keep the 10 year validity for EPCs.
What if a property is not an EPC C by 1 October 2029?
If a property doesn’t meet the EPC C standard before 1 October 2029, landlords will need to commission an EPC which measures the energy efficiency against the new HEM metrics. They will then need to obtain another EPC to show
Landlords of properties that are not an EPC C or better using the EER metric before 1 October 2029 will need to commission a new EPC using the new metrics, and then obtain another EPC to show they are they have concluded installing the relevant measures to meet the standard to demonstrate compliance. The cost of these EPCs will count towards the £10,000 cost cap.
Implementation timetable for the MEES/EPC changes
Here is the timeline for the implementation key proposed changes to the EPC rules for landlords, subject of course to further change:
- 1 October 2025. All expenditure on improving energy efficiency from 1 October 2025 will count towards the cost cap.
- Summer 2026. Confirmation of the launch date for the HEM and “shared implementation plan” with the devolved administrations.
- Late 2027: Launch of HEM, to run in parallel with EER until 30 Sept 2029.
- 30 Sept 2029: Last day to get EPC using EER.
- 1 October 2029. Any properties with an EPC C under the EER rules by this date will be deemed to comply with the new MEES requirements until their EPC expires.
- From 1 October 2030. All private rental properties will need to meet the equivalent of EPC C, either an EPC C under the old EPC methodology (EER), or under the new EPC methodology (HEM), unless they have a valid exemption. Landlords will not be able to continue letting their properties if they don’t meet the new standards or have an exemption by this date.
- After 1 October 2030. The cost cap will be reviewed to take inflation into account every 5 years, with the earliest review being “after 1 October 2030”.
Other changes to EPCs
When will landlords need an EPC?
In the government response to the 2024 Energy Performance of Buildings consultation, they confirmed they intend to change regulations so an EPC will be required at the point of marketing a property, rather than the point of rent (or sale).
The justification is to “ensure appropriate information is available to people when making purchasing decisions”.
How long will EPCs last for?
The government confirmed in its response to the 2024 consultation that they will maintain the current ten-year validity period for reformed EPCs (with the new metrics) and that existing EPCs will keep their ten-year validity.
When will landlords need to replace EPCs?
Currently, if an EPC expires while a tenant is living in the property, the landlord does not need to renew the EPC, as they are required to with gas safety certificates and Electrical Installation Condition Reports.
The government consulted on this, and the response to the 2024 Energy Performance of Buildings consultation said they “are working to refine the position on requiring a new EPC when an existing one expires for all private rented buildings”.
Will the new EPC proposals affect HMOs?
Yes. At the moment, an EPC is only needed for properties let on a joint tenancy basis, and not when rooms are let on a room only basis.
The government is proposing that landlords will need to have a valid EPC for an entire house when a single room is rented out. Paragraph 68 of the Consultation Response states: “We intend to clarify the scope of the EPC regime by requiring a valid EPC to be provided for a whole HMO when a single room is let, short-term rental properties irrespective of who pays energy bills.”
Enforcement and penalties
Tougher proposed penalties for non-compliance
In keeping with the approach in the Renters’ Rights Act, the government is proposing to significantly increase financial penalties, with a new maximum penalty of £30,000 per property and per breach. This would bring the enforcement powers in line with other housing-related fines, such as those under the Housing Act 2004.
When these rules come into force on 1 October 2030, landlords who fail to meet the new efficiency standards could face much larger fines than under the current system.
The proposed penalty structure is also per breach, meaning repeated violations or multiple non-compliant properties could lead to significant financial costs.
| Offence | Current penalties (2026) | Proposed new penalties |
|---|---|---|
| Renting out a non-compliant property for less than 3 months | Up to £2,000 | Up to £30,000 per property |
| Renting out a non-compliant property for 3 months or more | Up to £4,000 | Up to £30,000 per property |
| Providing false or misleading information on the PRS Exemptions Register | Up to £1,000 | Not specified, but likely to be included under higher fines |
| Failing to comply with a compliance notice | Up to £2,000 | Expected to increase under the new framework |
| Maximum total fine per property | £5,000 | £30,000 per property, per breach |
Stronger proposed local authority enforcement powers
The government also proposes significantly enhance local authorities’ ability to enforce Minimum Energy Efficiency Standards (MEES) in privately rented properties.
The key measures the government is proposing include:
- Expanded investigatory powers. Local authorities to have stronger legal backing to inspect and investigate properties suspected of non-compliance.
- Stronger financial penalties. The fine for non-compliance would increase from a maximum of £5,000 per property to £30,000 per property, per breach (see above table)
- More proactive enforcement. Councils would be expected to actively monitor compliance and take action against landlords who fail to meet the standards.
- Public disclosure of non-compliance. The government is considering giving local authorities powers to publicly disclose landlords in breach of MEES regulations, but this is still under consultation.
Final thoughts
Assuming the everything goes ahead as per the current proposals, which is a big assumption, landlords now have to obtain an EPC C under the existing, easier EPC metrics, and benefit from the transition arrangements which “grandfather” those EPC Cs.
Landlords who achieve EPC Cs before 1 October 2029 under the old EPC metrics will be able to defer the decision on further investment for a while, depending on when their EPC expires.
If landlords try and fail to reach EPC C, they will either need to register for an exemption, or achieve an EPC C rating under the new HEM:EPC metrics, in order to be able to continue renting properties. Unless the rules are changed, this means a heat pump or solar panels (or other smart readiness kit) by 1 October 2030.
I have Victorian/early Edwardian terraced houses that now all achieved EPC Cs, without wall insulation. I took the decision to upgrade my properties early, as I figured the closer we got to the deadline (which was originally due to raise the standard to EPC C for new tenancies on 31 December 2025), the various trades and materials would be in short supply.
The deadline has moved to 2029, but I don’t regret raising my properties to EPC Cs, as I will benefit from the transition arrangements for 10 years (I’ll be renewing the EPCs in early 2029). But I will then need to decide whether to install a heat pump or solar panel, or see whether something else is suitable for the houses for when the EPCs expire, once we know what “smart readiness” means.
A lot can happen between now and then, technology may improve, the cost may come down or the dates and rules may change. Let’s see.
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Really thought provoking article (as usual)….excellent again at breaking the new EPC assessment details down.
As usual it leaves me with more questions than answers as obviously a lot of the stuff is “proposals” at present.
My main thought is if the new EPC assessments will mean it’s easier or harder to achieve an “C” rating than the existing system.
I have 3 properties on a C70 rating(just in!) and hope this will be still the case when reassessment time comes around after 2026.
Thank you. So much depends on what these new metrics mean, and what impact they have. We’re in the dark on this at the moment.
I’m going to get my EPC C-rated properties re=assessed later this year so I have the full 10 years without having to worry about it. In each I’ve improved the properties since the last EPC (eg new boiler, new UPVC front doors), so the ones that are a bit marginal, will hopefully be bumped up.
Good afternoon Suzanne,
Unless I am much mistaken I think if a property is newly tenanted the 10 year epc rule does not apply? So if I am correct you would need the same tenant(s) for the entire 10 years. But please do correct me if I am wrong.
You don’t need a new EPC each time you have a new tenant. It lasts for 10 years at the moment.
That’s a good idea Suzanne……..i may well do a similar thing…..that takes us to 2035/36….it’ll be totally different ball game by then and at 67 at that time quite possibly exit time😉
Hi Suzanne
This (together with the renters rights bill) has meant I am actively reducing my portfolio. I hopefully will only have 1 property left by 2026 and it has an EPC C rating carried out in 2023.
Do I read your comments correctly that I will be “Safe” until 2033 regardless of tenant changes?
The property is an insulated cavity wall, fully double glazed property with modern gas combi boiler.
I will be 70 by 2033 and will be looking to retire completely from being a landlord by then.
We are currently trying to live our best life by travelling extensively, after my wife was diagnosed with cancer (now in remission). The properties are managed for us by a very good agent, however, like many others I meet, we have had enough of our investments being not fully under our control.
We have lovely tenants in the last property, when they leave we will sell. I would hate to have to ask them to leave so we can sell…… I dont think the government realise this might be an outcome of their changes….. its completely opposite to what they say they want.
As the proposals currently stand, your 2023 EPC C should be fine until 2033. Sounds like you’ve done everything possible in any event, with insulated cavity walls.
Yes, enjoy your best life x
Hi Suzanne, great article appreciating that you got your Victorian houses to a EPC C I’d find it really helpful to understand how you accomplished this and how much the works cost per house. Kind regards Chris
The loft insulation was inexpensive, but the windows were very expensive. However, they needed replacing anyway. It was more than £10k and I got it to 77 without wall insulation or anything special other than insulating the cellar ceiling.
Similar to mine, a C69, only just made it ! My opinion is it will not make a C with the new metrics because it is gas central heating and not smart controlled. By 2030 I will be virtually retired and certainly won’t be looking to spend a small fortune to satisfy the governments whims. If this was being applied across all residential properties I may have a different viewpoint but this is blatant landlord bashing. If my tenant leaves beforehand I will be selling up if not the chances are another perfectly good home will go the market for sale in 2030 anyway. Labour will keep twisting the knife until we are eliminated.
Well you will have two hoops to jump through under the new MEES requirements. Each will require specific types of improvement measures if you fall short. Under the existing system it doesn’t matter how you get to a C as everything recorded during an EPC assessment gets input into the modelling and affects the result so how you improve your rating doesn’t matter. Under the new system I think this will force people to install either solar PV or heat pumps (unless they qualify for an exemption) where previously these things were mostly not required to get a C under the current system.
Given the modifications required and works to install either PV or heat pumps I am not sure either would be achievable on standalone units within the £10k cap. Anyone with experience of installing either with an steer on possible costs for this work in the South East?
All the stuff about enforcement and council intervention etc are surely just a lot of padding, the already announced ( but not detailed) landlord/property database does this very easily, not going to be hard for councils to keep an eye on things.
As for the new metrics affecting the EPC achieved , risks becoming a nonsense if a home heated by electric has the same rating as one heated by gas , but tenants could well be paying very different bills.
Likewise the notion that a tenant in a property that’s had the “average” £6k spent on it is going to save an average of £240 a year, the majority of landlords are going to want to recoup that £6k ( more if the capital is assumed to have been borrowed), even if over 10 years the tenant is likely to be worse off.
To me the measures are more a case of the prs being an easily manipulated and significantly sized portion of overall housing, around which an energy efficiency industry can be built with time for training and lessons to be learnt ( as to what does and doesn’t work) and for that industry to mature before attention turns to the owner occupied low performing housing.
The green deal and renewable heat incentives, were both unmitigated disasters, using landlords as guinea pigs to prevent another , could be seen as quite sensible.
Hi Suzanne,
Thanks for breaking down the 60+ pages into some digestible clarity. I have Edwardian ground floor flat so the best it can achieve is high D rating at the moment. I own share of freehold and so if I want to clad my external red brick part of my property I assume I need my fellow freeholders permission. Logically they will say no as they don’t want half of the building looking clad with insulation vs their top part of their building so is that a valid exemption (it would certainly devalue the property owners flat upstairs) as the red brick facade would look very odd? My damp surveyor says internal insulation would cause damp issue as the old buildings need to breathe through brickwork and internal lime plaster so is that a valid exemption (again fellow freeholder permission required???)? I have the original solid weathered wood 100 years old windows that are very robust but I would resent ripping them out for PVC versions but only gain 2 extra points on my EPC. I know you have been successful with your Victorian properties but I believe you own the whole house/sole freeholder so your loft insulation can make a big impact on your EPC points. I do feel per 1919 properties are massively disadvantaged with EPC ratings so could be early casualties in terms of being removed from PRS supply.
Hello Dee. We need to see the final detail on these new metrics, as they might help you.
Hi Suzanne. Does that mean they will be looking at pre 1900 houses? I’ve had various conservation architects look at my solid stone terraced house and all say the same. Clad those walls and they will run with damp. We have a solid slate floor, surely that will devalue the property if covered up as I’ve been advised to do by many warm home grant people. I’ve added new upvc doors, it’s double glazed, the loft is now insulated fully and a new electric smart boiler fitted. I feel I can’t go any further, well, should I say I shouldn’t. I know smothering the stone lime mortar solid walls with celotex will be detrimental and I know the beautiful character will be ruined if we do loose all yhe features,just to tick a green box. The house is boiling and it holds the heat 24hrs. There needs to be a more comprehensive exemption list surely…..
Hello – I answer the question about solid wall insulation in my new blog post and YouTube video: https://theindependentlandlord.com/epc-answers/
Interesting and thanks for going through 67 pages!
Does the £15,000 exemption mean you have to spend that much before you get the exemption, or that if it will cost that much you dont have to do anything?
It’s a cost cap. This means that once you’ve spent £15k, you won’t need to spend any more, even if your property hasn’t reached the minimum standard.
Is the monetary spend the only way to get an exemption in the new plans?
I set out the other exemptions mentioned in the consultation under this heading: Exemptions likely to be available to landlords
Do you know is this cost cap per property or cost cap per rental? E.g. having 2 flats in one building.
Per property let, ie per flat, as each flat has its own EPC as they will differ (eg middle floor will have insulation from above and below)
Suzanne
Excellent article, thank you.
HMOs remain Exempt, correct?
Thanks
Suzanne, does the £15,000 expenditure cap apply to the property as a whole? I have a period building that is split into 6 self contained flats each with their own Council Tax rating. I assume this does not mean that each Flat has a separate £15,000 expenditure requirement before exemption.
I believe it is for each property, ie the flats not the building. There are potential exemptions for heritage buildings: https://theindependentlandlord.com/epc-answers/
But what’s to stop landlords just asking their tenants to deny consent?
Good point. I guess the landlords would need to act in good faith and be able to show that the landlords have refused consent, despite the landlord’s best efforts.
Where are the tenants meant to live whilst in some cases extensive work is required and who picks up the cost of housing them in the meantime?
Ill thought out and totally unrealistic timescales.
If this will not become law and new metrics are not out until late 2026 and as a tenant can give notice at any time, that only give a year before the 2028 deadline.
So where are all the installers going to come from to do all the external Wall insulation work on the solid wall properties in my area?
Good video and useful blog – bookmarked. I have (had, one just sold) two G2 listed terraced houses on leasehold. The last EPC’s graded them D 63. Recommendations to improve the rating included internal/ext wall insulation, solar water heating, double-glazing and PV on the roof. Cost estimate £14.5k – £32k.
I guess I would have to rely on one of the exemptions you list as none of those are feasible even if I wanted to do it and I’m certain the freeholder would object.
But as that casts uncertainty going forward I will probably put the other property on the market in April. Government objective achieved; another private landlord out of the market. I wish tenants all the best dealing with corporate landlords!
Sorry to hear this. The net effect is that there will be one less property in the PRS and if an owner occupier buys it, they’ll be unlikely to upgrade it unless they get a government grant. The numbers wouldn’t stack up for a corporate landlord, unless the rent is really high!
Thank you for the summary!
So just to be clear… new EPC standards will be available under the new terms as of 2026, but if the property still fails under the new scheme, we have until 2028 to make it comply?
Thoughts:
Based on current HMRC treatment of energy efficiency improvements, most upgrades are considered capital expenditures, not expenses. That means:
– Not immediately deductible from rental income—instead, you can only offset them against capital gains tax when selling the property.
– If classified as repairs (rather than improvements), some elements may be tax-deductible.
*Lobbying for these costs to be fully expensible is critical, as forcing landlords to absorb them as capital costs makes compliance far less affordable. I’d actually like it to be a choice if you chose capital vs expense – but that’s not going to wash!
The Blanket Cap Figure
A blanket figure fails to account for rental income differences. On a property generating £50k per year, a £15k investment is manageable; on a £19k-per-year property, it’s crippling. It also suggests that some properties can remain inefficient, which contradicts the claim that these rules are *necessary*. If the standards are not essential, then why impose them at all—especially at such high costs to landlords.
Grant Ineligibility – many landlords do not qualify for government grants and must finance improvements entirely on their own. The cost cap should reflect what landlords can realistically afford, not just what the government wants to enforce.
Suggestions:
✅ Capping investment a percentage (say 5%) of annual gross rental income (averaged over the previous 3 year period – or in the case of a new rental based on the Estimated Market Rental Value —the average rent that a property could reasonably generate based on local market conditions)—making the requirement proportionate to what landlords can earn from the property. The government must move away from a ‘one-size-fits-all’ approach and implement a cost cap that aligns with actual rental income levels, while also ensuring that compliance costs remain financially viable through tax relief and grant availability.
✅ Expanding exemptions for older housing stock—some properties simply cannot meet these standards within reasonable financial or structural limits. Recognising and documenting exemptions for solid walls, conservation rules, and traditional construction methods that make some upgrades unsuitable (e.g., increased damp, ventilation issues, or overheating in summer). Make these features exempt upfront.
✅ Ensuring all upgrade costs are tax-deductible as expenses (not capital costs)—so landlords can actually afford the improvements without unfair financial strain.
✅Extend the time for compliance. Encourages Sensible, Gradual Upgrades – Landlords would still be incentivised to improve energy efficiency, but in a way that is financially sustainable and does not result in rent hikes or landlords leaving the market.
✅Grants for All Landlords – Financial support should be available to all landlords, not just those who meet arbitrary eligibility criteria. If the government wants to enforce stricter MEES, it must provide meaningful financial incentives (e.g., tax reliefs, direct subsidies).
Excellent comments! You should submit these to the consultation.
I would add to this, that there should be an option to measure fabric thermal efficiency via a heat loss survey. This would then address the issue of inappropriate assumptions made by the assessor, or lack of documentation in respect of insulation (for example).
I’m my case, I have a top floor ex-LA flat that is a high E, with the only available measures being internal wall and ceiling insulation, both incredibly expensive and disruptive. However, the flat retains its heat well, is comfortable year round, and inexpensive to heat. A heat loss survey would quantify this lived experience.
I assume this flat will no longer be rentable in a few years’ time as I won’t be able to change from gas central heating or add solar panels.
Incidentally I tried selling it already and nobody even came to view it. A shame as it’s a lovely flat.
How do we submit an idea to consultation?
Hello Suzanne.
1. The EPCs under the existing system will last 10 years and, as I understand it, all these rumours that they will need replacement every time there is a new tenant within that 10 year period, are false? Am I correct?
2. When the new EPC system comes into force, do we know how long those certificates will last? (Some suggestion they will need to be replaced frequently than 10 years.)
3. Assume you have a flat where, to get to the desired rating, there are certain improvements that it is within your power to do, but also other improvements outside your power to do because they would require freeholder consent which is refused. Suppose the stuff within your power costs £5000 to do and you get it done but it still doesn’t get you to the desired rating. I assume you can then get an exemption because you have done everything you LEGALLY can. You are well short of the cap, but everything else that would improve things is simply outside your power to do. In this sense, the “cap” on that property may be a lot less than £15K where some measures just can’t be legally done.
1. This is a suggestion in the Reforms to the Energy Performance of Buildings regime launched in December 2024
2. The current rule is 10 years. It is possible it may reduce to 5 years (also in the December 2024 consultation)
3. I mention the exemption for leaseholders in the blog post under “third party consent exemption”
The Consultation document states that a validity of 10 years will apply to EPCs issued under the new system, and this period is not on which comments are being sought.
I don’t understand your point. You were replying to a comment I made a year ago on the original consultation, and not the response published last week. EPCs are currently valid for 10 years, and the response to consultation says this will continue.
Do you consider that there could be a case for judicial review based upon any of the following grounds:
-Discrimination against the private sector, leaving the public rented sectors as is;
-Insufficient time by only publishing the MEES in late 2026 and patently lack of resources to fulfil thereafter
Judicial review is not an area where I have any expertise. Maybe the NRLA will know? But I do agree that the timelines are too short, esp as the metrics are changing. Ditto the RRB, although I hope they will truly give us enough time to make preparations after Royal Assent when the regulations are published.
Thanks Suzanne – useful info but quite depressing really for landlords.
1. what should landlords do? – My answer is Sell Up as I am doing; run for the hills before you get hit with a massive fine for not compliance. Just had a tenant give notice as they have just got married so their flat will soon be on the market for sale.
2. Their seems to be scant info regarding blocks of flats and how the EPC can be lifted on these buildings, and the relevance to the Leaseholder regarding works being done to their building.
Thanks
Thanks – I added a little bit about 2 in the third party consents, and will look to add more.
Oh ok thanks Suzanne – must have missed that. As I’m a director of a right to manage on a 46 unit block of fats at Worksop, we need to stay mindful of what our duties could be with the MEES
Thanks again Suzanne!
I have 3 flats which are basically concrete shells! I have these EPCs:
77 (c) expires Aug 2032
69 (c) expires Aug 2032
71 (C) expires Jan 2028
– Am I safe until Aug 2032 for the first two?
– If I re-certified before 2026 for the thrid one, would I be safe for another 10 years? (presumably not!!)
Many thanks
Everything is still out to consultation. Under the transition rules, you’d be ok until 2032 for the first too. You might consider getting the 77 one redone early next year with the same assessor. It would be a bit risky with the 69, unless you’ve made some improvements since then. Maybe speak to the same assessor. With the 71, you could get it redone next year and have it for another 10 years. As with the 69, have the chat with the assessor. A bit caveat is that the government is considering changing the length of the validity, but I imagine there would be transition arrangements. The usual disclaimer – just my best guess. I’m not an EPC assessor!
If the private landlord is to achieve EPC C rating why are social properties not required to? Surely this would be considered to be discriminating and we should insist All rental properties are treated in the same manner. Councils will not want to comply with EPC C yet they have more complaints about poor standards than anyone.
The final straw, we are selling up x three, renters reform bill, sec 21 removal, local licencing, EPC’S , threats of huge fines, etc, we had a new more efficient boiler fitted on a property with a C rating and when the EPC was updated it waz dropped to a D rating! Figure that out. Our tenants are all origional tenants, always looked after by us for ten plus years, have never had a rent rise and are now going to be made homeless due to local and national government interference. We are one of many good landlords who are leaving the PRS. legislation is already in place to tackle bad landlords but we are being tarred with the same brush and milked for cash by those in power, our rights over our own priperties are under attack, we feel we now have no option but to sell. Three less rental properties available at a good rental price in good conditiin with decent landlords. We will invest elsewhere now. Its very sad and counterproductive.
I have 3 properties and I just do not have money to spend on upgrading the properties so I will be selling. I’m sure I won’t be the only one. I have provided homes that have been properly maintained and have dealt with any issues the tenants have had promptly. I am now being forced out of the market. I feel sorry for all of those who are going to find themselves looking for other homes that will be in short supply and have much higher rents. The government aren’t doing anyone any favours with their ill thought out plans.
Hi Suzanne. What if we can not afford the improvements and not one of the exemptions. We have lovely tenants and done improvements but only get to a D.
On EPC says to put cavity wall insulation in it would need digging up the whole area around the house as the outside area is higher than DPC . Plus those who have had cavity wall.insulation in same street have had loads of trouble with mould and condensation after doing it, which we don’t have at the moment
Please where do we stand with all this. It looks like we have to sell up but will do what we can not to do this but only in what we can afford to do. .
I think it would be best to wait and see what the new metrics will say – this does sound like something that would need to be taken into account.
Hi Suzanna,
really informative article i have 2 properties currently rented 1 a C and the other a D rated . The accesor told me the only way to uplift from a D to a C would be to put solar panels on the roof evidently cavity wall insulation is not possible because of the age of the house .I should point out that the property missed a C by 2 points however this could drop lower when the rules change . Could i get an exemption or should i go back to the E P C issuer to see if there is another improvement way forward before the2026 deadline? My tenents are really happy effectively the government by enforcing unrealistic measures on landlords will mean that i have to aell up.
It might be worth asking another assessor to give some advice, as 2 points is so close. Or go back to the assessor to see if there are any measures you can do to improve it, eg more loft insulation. When the new rules come in, if you can show the solar panels upgrades would be more than £15k, you wouldn’t need to do it. Also worth checking out whether you can get a grant for the solar panels under the new Warm Homes: Local Grant when it comes into effect in April. I write about it in this blog post: https://theindependentlandlord.com/epc-landlords/
Hi Suzanne do you think MEES applies to “let” properties include outside Housing Act or rather a mirror of the RRB (assured tenancies) please?
Very good question. The definition for the current MEES rules is in s42 of the Energy Act 2011, ie an assured tenancy for the purposes of the Housing Act 1988, and a tenancy which is a regulated tenancy for the purposes of the Rent Act 1977. It would appear that this doesn’t include (say) high rent tenancies (over £100k pa) as they aren’t assured tenancies or Rent Act tenancies. I haven’t spotted anything in the consultation documents that suggests the application will change (and the RRB isn’t increasing the £100pa rent limit for assured tenancies).
Hi Suzanne,
I just got a new EPC for one of my properties that was about to expire. It seems it has now been downgraded 2 points to 67 from 69. This is despite all the lighting is epc friendly now also. I could install thermostastic valves to get to 68 no problem. Having many years ago done cavity wall insulation and double glazing in every window, loft insulation of 250. The frustrating thing is the only other improvements to get to C are floor insulation/Solar panels and Solar water with only 1 point to go. The assessor (same as the one from ten years ago) says the change is because cavity wall gradings were changed a few years ago and probably because the large external wall area. So I guess in the coming years this would be seen as awfully cold property and so un lettable when this year the tenants have behaved like the property is to warm if anything!! Do you have any suggestions/thoughts? Thanks.
Sorry to hear this. Have you checked to see if there are any errors or assumptions. You could instal thermostatic radiator valves (something you should do anyway), and try another assessor. It’s comparatively little money to do that (we’ve done it at our own home recently). I got a substantially higher rating when I did some of the things in the list for my previously EPC E rental. You could also get a PAS2035 assessment done to see what scope there is.
Hi Suzanne, Firstly thank you for all the info such a help to a fellow landlord.
I have a small detached 1910 property of solid brick wall construction currently with a EPC rating D 60 points carried out in June 2022.
I upgraded the property with new double glazing, low energy lighting, programmer room thermostat and TVR, kept the original condensing gas boiler,loft insulation to the pitched 100 mm as boarded for storage and laminated flooring throughout.
I spoke with the assessor and my understanding raising the loft to 300 wouldn’t make much of a difference and any upgrades either to the gas boiler.
I understand that EPC needs to be upgraded in sequence as recommended with the appropriate steps to gain the maximum points unfortunately next step is insulation to walls.
Which I wouldn’t dream of adding as it would significantly impact the size of the property internally externally.
Plus the cost implications and to the detriment of the integrity of the building that currently hasn’t any issues.
My extensive research and reading articles from professionals this will cause damp and condensation.
We only have to consider the government well thought-out plan of spraying insulation into the loft and the problems this has caused and the major expense to the poor individuals following there recommendations.
if I decide not to install insulation to either interior or external in the future certified by a respected professional would this exclude the property for not reaching the recommended EPC C and further alterations not needed?
It sounds as if you have similar properties and I am wondering what alterations have you made that might help me move forward to gaining the C it would be greatly appreciated if you could share this?
Would it be possible that the sequencing of the improvements suggested on the current EPC couldn’t be discarded? The cheaper option consider IE floor insulation would not greatly improve my point situation with a new EPC/assessor if this was in place at the time of assessment?.
As I have heard it’s based on how they input information which is key to results.
Suggestions and thoughts would be most welcome.
Ask your assessor what your rating would become if you qualified for TTZC. This can be achieved under the current methodology by installing the right type of ‘smart TRVs’ and should get you back in the C band. Another approach is to upgrade the heating controls on your boiler to include weather and/or load compensation. These won’t cost too much compared to other measures and are the type of thing that are not covered by any recommendation in the current methodology. Also check
You don’t have any electric secondary heating if your main heating is a gas/oil boiler. Hope that helps.
What about property management companies? Are they under any obligation to install whole-building energy efficiency measures? Will they be?
Hi Suzanne,
My problem with all of this is time. I have 12 properties. I will have to refinance to the raise money to do the work. If I wait until late 26 to get more clarity on the best way forward, I’ve then got an almighty race to get work done to avoid enforcement. I think I need about 5-10 years to get this done.
I hope the government understands that these types of improvements can’t happen overnight. It took me 5 years to get my EPC E to an EPC C. I did it out of income, a little each year. But I only had one property to upgrade, so I can only imagine what it might be like for you with 12. Do check out the Warm Homes: Local Grant that I link to.
Great summary as always. I too have Victorian ground floor flats so unable to install solar and do not think a heat pump will cut it. I am loathed to put in internal insulation on walls only to cause problems in 5 /10 years time from not allowing the building to ‘breath’ as older properties are meant too. I also can’t see my fellow freeholder who owns upstairs allowing me to change the look of the outside (whether that’s replacing the existing single glaze windows which have secondary glazing now or apply external wall insulation to my red brick) so I assume that I would be likely to qualify for an exemption for 10 years?
I agree with your take on internal insulation in Victorian buildings Dee. I too severely doubt that a heat pump will provide a warm and economical period home which cannot have walls insulated for good reason.
The problem of damp being harboured in single skin walls when insulation is added is now more understood. One only has to look at the poor record of wall insulation installations through government schemes to see that it creates more problems because either it’s not suitable or installers do not know how to install correctly:
*98% of homes that had external wall insulation installed under the schemes have problems that will lead to damp and mould if left unaddressed.
*Nearly a third, or 29%, of the homes that were given internal insulation also need fixing.
Hi Suzanne,
I can foresee a housing shortage at this rate. There’s no way my wife and I can afford or invest the amount of money for the upgrades required.
We have a single property built circa 1830s, three bed room terrace house and at current values worth £180k to £200k. Rated EPC band D until July 2034 but with a many Government energy improvements recommendations which as far as I can tell will be access of £15,000.
Floor insulation £2000 – £5000
Heating controls £350 – £450 (Current controller is only 5 years old!)
Solar panels £5000 – £8000 (This will be probably higher as the roof will need strengthening)
Solid wall insulation £9500 – £14000
With all this mind, we’re now seriously thinking of selling up, leaving my tenants looking for somewhere else to live or find a very large loan which I will never see a return on.
I take it from what I understand, I have start some of these improvements this year 2026?
M.
Remember that you get an exemption once you spend £10k
suzanne the 10k spend i choose how to spend it ?
Yes, but I understand it needs to be spent addressing issues highlighted in the EPC
Hi Suzanne
Thanks for reporting on this update. Is there any detail on what spending will ‘count’ and what might not.
Or do you think there may be more in the pipeline?
For example, if solar panels require roof strengthening first will this ‘count’ for the cap. And will these works be tax deductable?
Would it be best to wait for more info from the Govt before cracking on?
I would imagine that work needed to put in solar panels will count. You can start with fabric enhancements now (eg insulation, new windows), but I personally am going to wait a bit before I do solar panels etc. All my properties are already EPC C. If you can get to EPC C under the existing rules, that will mean you’ll get a 10 year reprieve before investing in solar panels or heat pumps etc
Thank you for you reply Suzanne.
Very good point re what costs count. So for example, if, in order to install internal wall insulation, you have to rip out your kitchen, bathroom fittings, skirtings, central heating pipework and rads, electrical sockets and switches, window sills and door frames, would the cost of replacing/reinstalling these be included in the £10k limit? Or only installing the insulation itself? The cost estimates on the EPC seem absolute pie in the sky, especially in London. And that’s not to mention putting the existing tenants in temporary accommodation. In London.
Thank you so useful! There is a current exemption on small stand alone rental propertys under 50m2 – do we know if that exemption will still apply in the new rules ? ThZnk you. Susiev
I’ve not seen it mentioned, which makes me think it won’t be changed.
An assessor a few days ago recounted being approached by a landlord upgrading her property and keen to get a date for an assessment in the diary to avoid delay, She was removing a gas boiler and had bought a heat pump (still in its crate outside) ready for installation. The (lady) assessor suggested she run the info through her system first as she feared the consequence of the heat pump installation. And, it seems, rightly so as the heat pump was going to move the assessment down a letter (from D to E I believe) because of the required electricity consumption, rather than up as the owner expected. Does this ring true to anyone else? If so, will the new assessment methods alter that position?
Oh – and where are we on Listed Buildings??
Listed buildings will need EPCs, but they may come under the ‘negative impacts’ or ‘wall insulation’ exemptions
After I had an epc which was D, I asked the surveyor how to get it to a C. I gave him a specific model of a heat pump meant to be good for flats; doing that he said would put it down to an E. So I am not surprised by your comment.
Crazy world! Another reason for why no wonder uptake for Heat Pumps is bad.
When the algorithm changes it is meant to be different. How much insulation needed to go with a HP may be critical to getting a good score
fantastic info, very helpful indeed now ill buy the book!
Thank you!
So given the further delay, would you envisage the long stop date of October 2030 now being pushed out again?
It wouldn’t surprise me, but I always plan for the worst!
What happens if I am unable to upgrade to a C as I do not have the finance to do that? I do not wish to take out loans or grants at my stage in life. I am retired and the rent is part of my retirement income.
Can I give my tenant notice to leave ( if they have not already given me notice) at that time so that I can sell my property?
You’ll be able to use the new Ground 1A to sell up.
Thank you.
Also, My letting Agent will not Issue a Section 8 Notice when the new rules come in to force. He states it must be issued by a solicitor. Is that correct?
It’s better if a solicitor does it. I wouldn’t use an unqualified person to do this