EPC C – what HMO landlords need to know

Higher Minimum Energy Efficiency Standards (MEES), tighter enforcement and new rules for heat networks will impact landlords of Houses in Multiple Occupation (HMO) in unique ways. Public Affairs officer Mia Rotaru explains more. 

Understanding how changes to energy efficiency rules will apply to House in Multiple Occupation (HMO) over the coming years is the first step towards getting ahead of the curve. 

Generally, an EPC is required when a property is let, unless a valid exemption applies. 

At present you only need an EPC if properties are let on a joint tenancy basis, that is, if the entire house is rented out. If you let the home on a room only basis you don’t need one. 

However, the Government is planning to extend the rules from 2030, so that, even if you rent on a room-by-room basis,  will need one for the house. 

This doesn't mean that you will need an EPC for each room, just one for the entire property. 

Understanding this distinction is critical, as it determines both compliance obligations and how improvements should be planned.  

EPC Band C by 1 October 2030:

Under the Government’s Warm Homes Plan, all privately rented homes in England and Wales will need to reach EPC Band C (or equivalent) by 1 October 2030.  

At the same time, the current EPC framework is due to be replaced by the Home Energy Model (HEM).   

Rather than a single headline rating, this system will assess properties across multiple metrics, including fabric performance, heating systems, and smart readiness.   

However, the thresholds defining “Band C” under this new approach have not yet been confirmed, leaving landlords without a precise target.

New heat network regulation:

Alongside changes to minimum energy efficiency standards, a separate regulatory framework is being introduced for properties with ‘communal or district heating systems’.

So, what exactly is a heat network?

A heat network distributes heating, hot water or cooling from a central source and typically takes one of two forms: 

• Communal systems, serving multiple units within a single building (for example, a block of flats).  

• District systems, supplying two or more buildings from a central source.  

While most standard HMOs will not be affected, there are some important exceptions. 

• Section 257 HMOs – buildings converted into self-contained flats that do not comply with post-1991 building regulations.   

For landlords managing properties within larger converted or leasehold buildings, this will add an additional compliance aspect alongside EPC obligations.   

What's the challenge for HMO landlords?

For HMO landlords, the challenge is not just technical but practical.  

Changes under the Renters’ Rights Act will limit the ability to rely on void periods to carry out major works, making it harder to time upgrades as many landlords have historically done.   

At the same time, uncertainty around the future EPC methodology makes it difficult to plan with confidence, particularly for those operating in cyclical markets such as student housing, where upgrade windows are already tight.  

What should I do now?

Despite these uncertainties, the case for early planning is compelling. 

• MEES and EPC changes: Landlords should review their EPC status, particularly for HMOs assessed as whole properties. Improvements after October 2025 count towards the £10,000 cap. 

• Heat networks: If you supply heat or hot water through a heat network, prepare for the introduction of a formal regulatory framework overseen by Ofgem. This will require registration and compliance with authorisation conditions by 27 January 2027. 

Enforcement

The Government has confirmed it will be taking a stronger approach to enforcement, with the upcoming changes to minimum energy efficiency standards, coming with a maximum fine of £30,000 per property.   

If you operate a heat network, engage proactively with Ofgem and address any issues early. While the regulator encourages self-reporting, more serious compliance or enforcement action may be taken in cases of non-cooperation or where there is demonstrable harm to customers.   

More information

• For more information about the proposed changes and the latest government announcements on the Warm Homes plan, EPCs, and MEES, click here.        

• The NRLA’s award-winning Training Academy runs an energy efficiency course giving you all you need to know on energy efficiency and how to access funding. Click here for more information and to book.        

• To help heat networks prepare for registration, Ofgem haas added more accessible guidance on how the registration process will work. For more information click here.