Breaking: New minimum energy efficiency standards to come in from 2028
*To fully understand the topics covered in this update, we recommend reading our piece on how the scoring and display of EPC ratings is set to change first.*
UK Government have announced their intentions to raise minimum energy efficiency standards in the private rented sector from 2028.
Launched recently, the consultation – entitled Improving the energy performance of privately rented homes in England and Wales – lays out plans to raise the minimum standards from 2028 for new tenancies and from 2030 for existing tenancies.
The consultation invites stakeholders to submit their comments before it closes on 2nd May 2025. We urge landlords to make their feelings known, which they can do via the Consultation Response page.
The new minimum standards
Nobody knows what the new minimum standards will be yet, but we do know the areas of energy performance the government want landlords to meet. They are proposing to set the new standards against four new headline metrics displayed on EPCs, which will replace the current single energy efficiency rating:
- Fabric performance
- Heating system
- Smart readiness
- Energy cost
Under the government’s preferred approach, landlords must first meet a primary minimum standard for fabric performance (e.g. loft insulation, cavity wall insulation, double glazing). After that, they can choose between meeting a secondary minimum standard for either:
- Heating system (e.g. heat pumps, improved heating controls, upgraded radiators), or
- Smart readiness (e.g. smart meters, solar panels, heat batteries, load-shifting appliances).
Notably, while ‘energy cost’ will appear on EPCs, landlords won’t be required to meet a minimum standard for it.
What EPCs might look like and the metrics properties will be targeted on:
Properties with an existing EPC when reform happens
Under the plans, properties with a valid EPC rated ‘C’ or above won’t need a new certificate when scoring and display rules change in the second half of 2026. Additionally, the property will be considered compliant with the new minimum energy efficient standards that come in from 2028, until the EPC expires.
However, properties rated below ‘C’ at the time of reform will need a new EPC that displays the new metrics. If the new certificate doesn’t meet the new minimum standards, landlords must take action to comply.
Since some landlords may need to replace EPCs that would otherwise have remained valid for several years, the government is proposing that the cost of obtaining the new certificate can be counted toward the cost cap (explained later in this update).
Timescales
According to the timeline in the government’s consultation, the new minimum standards won’t be confirmed until the second half of 2026, which is when the change in the scoring and display of EPCs comes into effect.
If this timeline holds, landlords will have a relatively short window – from Q3/Q4 2026 to 2028 – to ensure compliance.
However, as this is still at the consultation stage, the final details may change before becoming law.
Cost cap
The cost cap to meet the current minimum ‘E’ standard is set at £3,500 including VAT per property. If they reach this cap – or there are no other energy efficiency improvements they can do without spending an amount that will take them over the £3,500 cap – they can register an exemption.
Under new proposals, the government aims to raise the cap to £15,000 (including VAT) and, notably, any work completed before the new standards are confirmed in late 2026 won’t count towards it.
Recognising affordability concerns, an affordability exemption that reduces the required investment to £10,000 per property is being considered for landlords who qualify.
Funding
Support is currently available (subject to eligibility) for some of the least energy-efficient homes through programs like the Boiler Upgrade Scheme, the Great British Insulation Scheme, and the Warm Homes Nest scheme. Additionally, energy-saving measures such as insulation and low-carbon heating benefit from a zero VAT rate until March 2027.
The government plans to explore additional funding and grants before implementation.
Fines for non-compliance
Currently, landlords can be fined up to £5,000 per property for non-compliance. The government’s preferred approach is to increase this to £30,000.
Our thoughts
Expert insight from our Director of Operations, Nikki Lewis.
With this consultation – and the previous one on EPC scoring and display changes – there’s a lot for landlords to digest. My first piece of advice? Respond to the consultation and make your voice heard.
Given that properties rated A-C will be deemed compliant with the new minimum standards when EPC reform takes effect in the second half of 2026, landlords with those ratings might want to get a new EPC in early 2026, even if it’s not due for renewal. Doing so locks in a 10-year compliance, meaning no work would be required until 2036. Even then, your property might still meet the standards, avoiding costly upgrades altogether. One caveat: the government is considering reducing EPC validity from 10 years, but it’s unclear if this will apply to existing certificates.
For landlords just shy of a ‘C’, small upgrades now – especially for properties with gas central heating, which the new EPC system will penalise for carbon emissions – could be worthwhile for the same reasons as given above.
For landlords facing a significant spend to reach a ‘C’, my advice is to wait. Once the new EPC metrics launch, get a fresh certificate, review your new rating, and assess the recommended improvements and funding options. Crucially, any work done before the new minimum standards are confirmed in late 2026 won’t count toward the proposed £15,000 cost cap – another reason to hold off. That said, if the government’s timeline holds, landlords will only have between late 2026 and 2028 to comply for new tenancies (2030 for existing ones), so staying informed is key. As always, we’ll keep you up-to-date.
Finally, we realise there is a lot to take in on this topic, so you may find our Frequently Asked Questions page useful.
The information contained within this article was correct at the date of publishing and is not guaranteed to remain correct in the present day.
