Big EPC reforms set to affect landlords
A recent UK Government consultation laid out intentions to overhaul how a property’s energy performance is displayed on Energy Performance Certificates (EPCs).
The Reforms to the Energy Performance of Buildings Regime consultation invited stakeholder input before it closed last week. As well as how energy performance is displayed, it also sought feedback on considerations to reduce the validity period of EPCs, and revising the circumstances in which an EPC is required to include all short-term/holiday lets.
How EPCs currently display energy performance
Energy Performance Certificates (EPCs) provide various metrics on a building’s energy efficiency, but the key measure is the Energy Efficiency Rating (EER) – a single grade from A to F. This rating is based on modelled energy costs per square metre, calculated using standardised assumptions about heating patterns, temperatures, and energy prices. The data comes from either a physical inspection (for existing buildings) or drawings and specifications (for new builds).
However, the Government recognises flaws in this system. Since the EER is tied to assumed energy costs, which can fluctuate, it can produce misleading results. For example, installing a heat pump – a highly efficient, low-carbon heating solution – can sometimes lower a property's EER simply because electricity costs more than gas. This means the rating isn’t always a fair reflection of a building’s true energy efficiency and can be affected by factors beyond the property owner’s control.
Multiple headline metrics
Recognising the limitations of the current single Energy Efficiency Rating (EER), the government is proposing a broader approach of four headline metrics to provide a more complete picture of a building’s energy performance. These new headline metrics are:
- Fabric performance: measures the thermal efficiency of a building’s structure, promoting the importance of insulation for comfort and energy savings.
- Heating system: assesses the efficiency and environmental impact of the heating source, encouraging the adoption of cleaner technologies.
- Smart readiness: evaluates a building’s ability to integrate smart technologies that optimise energy use and take advantage of cheaper smart tariffs.
- Energy cost: helps individuals understand the financial implications of a property’s energy efficiency and make informed decisions about potential improvements.
Other metrics, such as an estimate of the carbon emissions arising from the energy used in the building, an insight into overall energy consumption and identification of areas for energy efficiency improvements, will be provided as secondary information.
What might the new EPC look like?
Moving from a single headline rating to multiple metrics represents a major shift. As the government acknowledges, ensuring the new EPC remains clear and user-friendly will be a key consideration in its final design.
Below is CPS Homes' mock-up of how the proposed four headline metrics might appear if the government retains an A-F rating for each category. However, an alternative approach could be a numerical score from 0 to 100.
How EPCs currently look
How EPCs might look from Q3 2026 onwards
Expert view
Now the consultation period is over, the government must consider stakeholders’ submissions, then make decisions. I don’t imagine we’ll see any changes to the information displayed on EPCs until the second half of 2026 at the earliest. This is partly because the Government are intending to consult on the methodologies that combine to create a property’s overall Energy Efficiency Rating during 2025. Their revised methodologies will create the scores for the proposed fabric performance, heating system, smart readiness and energy cost headline metrics, if that’s the route they decide to go down.
The current 10-year validity period of EPCs
Currently, EPCs are valid for 10 years. However, in many cases, they don’t need to be renewed when they expire, as a valid EPC is only required at the point of build, sale, or when granting a lease to different tenants in the rental sector.
As part of the consultation, the government is considering reducing the validity period. They argue that more frequent updates would better reflect building improvements – such as insulation upgrades – and provide prospective buyers and tenants with more accurate, up-to-date information that could directly impact their cost of living.
If changes are introduced, the government have stated their preference is to allow existing EPCs to remain valid until their expiry date, with any new validity period applying only to newly-issued EPCs.
Requiring a valid EPC throughout the tenancy period
Under current rules, a new EPC is only required when a property is re-let – not when an existing tenant renews or extends their lease. This means a property could be rented for years with an expired EPC.
The government is proposing a change that would require landlords to obtain a new EPC when the current EPC expires, regardless of whether the tenant remains in place. This would create a system similar to gas safety certificates, which must be renewed upon expiry.
If introduced, this change would ensure that EPC ratings remain accurate and up-to-date, providing tenants with current energy efficiency information throughout their tenancy.
Marketing a property for sale or rent
At the moment, an EPC must be commissioned before a property is marketed for sale or rent, but sellers and landlords have up to 28 days to display the certificate.
The government is proposing to tighten this requirement, stating that a property should not be marketed at all without a valid EPC. They argue this change would ensure buyers and renters have access to key energy efficiency information from the outset, allowing them to make more informed decisions. It would also simplify enforcement, making the rules clearer for landlords, agents, and regulatory bodies.
Short-term / holiday lets
There is no current legislation requiring an EPC to be produced for short-term or holiday lets. There is guidance that says one is required for properties rented out as a furnished holiday let (as defined by HMRC) where the building is occupied for the purposes of a holiday as a result of a short term letting arrangement of less than 31 days to each tenant, and is rented out for a combined total of four months or more in any 12 month period, and if the occupier is responsible for meeting the energy costs for the property.
The government don’t want to see landlords move from the private rented sector to the short-term/holiday let sector, so they are proposing to legislate for all short-term/holiday let properties to have a valid EPC at the point of being let, irrespective of whether the occupier is responsible for meeting the energy costs.
Expert view
This is the government getting their ducks in a row. It’s common knowledge that they want to legislate for increased minimum energy efficiency standards, but if they did that before changing the way EPCs look, they’d have to redraft the wording of the legislation so that it covered the revised scores and display. So this is the precursor for new minimum energy efficiency standards, which they have actually just released a consultation on.
Within the article, we mention a third consultation for landlords to look out for in 2025, which will alter the methodology that calculates the ratings. As the government acknowledges, the current methodology places too much emphasis on the cost of energy when calculating the energy efficiency rating. So, as electricity is costlier than gas, hot water cylinders are rated lower than gas boilers, despite the latter’s use of carbon. The new methodology will focus less on energy cost and reward properties with reduced carbon emissions, so landlords of properties with gas boilers should be prepared for them to be scored lower than in the past. Though, as we mention, the display of the score will be different if the Government go in the direction they want to, so it’ll be the ‘heating system’ metric that is affected.
I disagree with the proposal to reduce the validity length of EPCs, and also the suggestion that a new one should always be produced when the previous one expires. If a property meets the legal minimum standard, why should it be reassessed so soon? It’s unlikely to have become less energy efficient in two, five or even seven years. I accept that we learn more about climate change with each passing year, and technology continues to advance, but the current position of 10-year validity – and only requiring a new one when tenants are changing and the previous one has expired – feels adequate to me.
Read about new minimum energy efficiency standards from 2028...
UK Government have announced their intentions to raise minimum energy efficiency standards in the private rented sector from 2028. Read about these here.
The information contained within this article was correct at the date of publishing and is not guaranteed to remain correct in the present day.
