Earlier this month the Labour Government released a consultation on changes to the Energy Performance Certificate (EPC) rating system. This comes after it committed to upgrading the minimum EPC rating for private rented property to C by 2030.

The Government wants to alter EPCs to incorporate a range of new metrics including:

• Carbon emissions
• Fabric performance
• Heating system

It is proposing that EPCs are completed more frequently, with greater detail and that rented properties have an up-to-date EPC for the duration of the tenancy.

Due to the greater complexity of the new EPC’s, they will probably cost more and take longer for assessors to complete. The Government wants landlords to invest in low carbon heating technologies such as heat pumps as landlords see future EPCs downgraded for properties fitted with gas boilers. 

Multiple metrics for EPCs

The current EPC calculates a rating metric, the Energy Efficiency Rating (EER), which combines a numeric rating (1-100) and a band rating (A-G).

The Government states the EER does not serve the diverse needs of users and it doesn’t give sufficient information about a building’s energy performance. The consultation proposes that EPCs should contain more metrics which measure:

• Fabric performance
• Heating system
• Smart readiness  

It is not known whether higher metric scores will be required to meet the updated Minimum Energy Efficiency Standards (MEES) or the future Decent Homes Standard.

New heating systems ratings

For many landlords the most challenging element of the proposals will be the new heating system metric. 

To encourage the adoption of low-carbon heating solutions, fossil fuel heating systems will score poorly and heat pumps will achieve a higher score.

This could lead to higher heating costs for tenants as efficient gas boilers can be cheaper to run than some heat pumps, reducing energy costs for tenants.

More regular EPC assessments

EPCs are currently valid for 10 years, but the Government proposes reducing this term to improve the accuracy of the ratings due to ongoing changes in metric assessment. The Government proposes different validity periods including as short as two years between assessments.

This raises the issue of how to deal with valid EPCs assessed under the current 10 year system and how long they should remain valid for. The Government states 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, there are other options in the consultation such as invalidating all existing 10-year EPCs or providing a transition window before invalidating them. 

The Government is also proposing that privately rented properties must always have a valid EPC rather than only at the point of marketing and entering a new tenancy. Currently, it is not a requirement to replace an EPC if the same tenancy continues after the expiration of the EPC.

Expanded HMO EPC requirements

The consultation includes plans to expand EPC requirements to cover all houses in multiple occupation (HMOs), holiday lets, and listed buildings. Currently, an EPC is only required for HMOs where the property is let on a joint tenancy. For HMO landlords to comply with these new requirements a 24-month transition period is proposed for HMO landlords

EPC standards and enforcement

The Government wishes to address the standards of EPC assessment, make assessments ratings more reliable and address enforcement. 

They have committed to a range of measures including:

• Replacing the Standard Assessment Procedure (SAP) with the Home Energy Model (HEM). It is stated this will make assessments more transparent and increase accuracy.
• Improving assessor training and introduce sanctions for poor quality assessments. 
• Work with local authorities to improve enforcement and increase financial penalties for non-compliance (fines of up to £800).

Introduction timetable 

The EPC consultation is open for input until 26 February 2025. For further information use the link below:

New EPC changes are expected to be introduced in the second half of 2026, with a transition period to follow.

The Government is also developing a Home Energy Model for domestic buildings, which will be incorporated into EPC assessment and for which there will be a further consultation in 2025.

The Government is to release a further consultation on changing the requirements for MEES. However, it has already confirmed that rented properties will require an EPC C rating for rented properties by 2030.