Energy Performance Certificates Consultation: what it means, and what's next

The UK Government published the first of two long-awaited consultations on energy efficiency this week. It outlines proposed changes to how Energy Performance Certificates (EPCs) will be calculated – including prioritising low-carbon heating. Mia Rotaru and Finlay Duncan from our public affairs and policy teams explore what these proposed changes could mean for you, and the wider sector.

On 4 December, the Government announced its consultation on proposed changes to the Energy Performance Certificate (EPC) rating system.  

The Government wants to reform the assessment method for EPCs to consider a range of new metrics that includes carbon emissions, fabric performance and heating system. It also wants to make the existing regulation stronger, requiring more frequent assessments and ensuring that all rented properties have an up-to-date EPC for the duration of the tenancy.  

All these changes mean that landlords will be required to acquire new, more in-depth EPC assessments more frequently. These will likely cost more and will take longer to assess. The Government hopes that the proposals will encourage landlords to invest in low carbon heating technologies such as heat pumps and may see their EPC downgraded for having gas boilers.  

The Government is consulting with stakeholders with the aim of strengthening these regulations and to ensure effective implementation. This comes after it recommitted to upgrading the minimum EPC grade to C by 2030 for rented properties. 

Multiple metrics on EPCs 

The Government states that the current EPC is problematic because a single headline metric, like the current Energy Efficiency Rating (EER), doesn’t meet the diverse needs of users and it doesn’t provide complete representation of building energy performance. 

Instead of using one headline measure, the Government is proposing that EPCs are turned into a collection of different metrics covering the different elements of energy efficiency: 

• Fabric performance 
• Heating system 
• Smart readiness 
• Energy cost 

It is not clear from the consultation whether higher scores on all of these will be required to meet the updated Minimum Energy Efficiency Standards (MEES) or the future Decent Homes Standard.  

Heating system rankings 

Perhaps the most challenging element of the proposals will be the new heating system metric.  

Aiming to encourage the adoption of low-carbon heating solutions, the Government proposes ranking different heating systems with fossil fuel heating systems at the bottom of the ranking, and heat pumps at the top.  

This could potentially lead to higher costs for tenants. More efficient gas boilers can be cheaper to run than some heat pumps, reducing fuel costs for tenants. In our consultation response, we will be making the case for these types of boilers to be ranked as an effective way to reduce energy consumption. 

Reducing EPC validity periods 

Currently, EPCs are valid for 10 years but the consultation proposes reducing this to improve the accuracy and timeliness of energy performance information for properties.  

The Government is consulting on a range of different validity periods including as little as two years between assessments. 

This raises the question of what happens to existing EPCs and how long they will remain valid for. The Government has stated that its “preference is to allow all existing EPCs to remain valid until the end of their existing validity period and apply any new validity period to new EPCs”. However, it is also consulting on other options such as invalidating all existing 10-year EPCs or providing a transition window before invalidating them.  

Making an EPC a continuous requirement 

The Government has also proposed mandating that private rented properties must always have a valid EPC rather than only at the point of marketing and entering a new tenancy. Currently, a landlord is not required to replace an EPC if the same tenancy continues after the EPC expires. 

EPC requirements for HMOs 

The consultation also includes plans to expand EPC requirements to cover all houses in multiple occupation (HMOs), holiday lets, and listed buildings. Currently, Government guidance states that an EPC is only required for HMOs where the property is let on a joint tenancy. 

A 24-month transition period is proposed for HMO landlords to comply with these new requirements. 

EPC standards and enforcement 

The Government has also proposed a range of measures to reform the standards of assessment, accreditation and enforcement, improving the overall reliability of the process.  

They have committed to a range of measures including: 

Replacing the Standard Assessment Procedure (SAP) with the Home Energy Model (HEM). This will make the assessment procedure more transparent and provide more accurate rating of properties’ carbon efficiency.  

Strengthening assessor training, identifying common errors and reviewing possible sanctions for poor assessment practices.  

Working with local authorities to strengthen enforcement, including harsher financial penalties for non-compliance (fines of up to £800).  

Next steps  

The changes to EPC metrics are expected to be introduced in the second half of 2026, with a transition period to follow. The Government is also working on the development of a Home Energy Model for domestic buildings, which will inform the new EPC methodology and will be consulted on in 2025. 

While this will change the EPC calculations, we still await the consultation on changing the requirements for MEES . The Government has, however, confirmed that rented properties will require an EPC C rating for rented properties by 2030.  

The EPC consultation is open for input until 26 February 2025. The NRLA will submit a response, making the case for changes that are fair, practical, and workable for landlords. 

If you would like further details, or to respond to the consultation yourself, more information can be found here.