EPC shake up – answer the consultation now, before it’s too late

It’s just over two weeks until the Government consultation on changes to EPC ratings closes. NRLA chief product office and Safe2 founder James Kent explains what’s set to change, and why it is vital you have your say.  

Energy efficiency has never been far from the headlines in recent months and, hot on the heels of the announcement on plans to introduce a minimum EPC of C for all rented homes by 2030, comes a new consultation that would overhaul the whole system.  

What is the Government planning ?

Proposals revealed last month outline plans to completely overhaul the way your EPC is calculated.  

At present, your EPC, full title, Energy Performance Certificate is calculated based on the energy costs for your home, with a qualified assessor taking into account factors such as the age of the home, insulation, glazing and lighting as well as the heating system, giving you a rating from A-G.  

The Government wants to replace this methodology with its new Home Energy Model, which would come up with a rating based in three metrics.  

These are:  

• Fabric performance   

• Heating systems   

• Smart readiness    

What does this mean in practice?

If implemented, you would need to make sure you make any ‘fabric improvements’ to the property first to improve its energy efficiency.  Fabric performance relates to how well the property retains heat, so if you have decent insulation and double glazing you will probably hit a C.   

If not, these are things you could improve to make the grade. You will also need to ensure the property is properly ventilated.  

You would then need to pick one of the remaining two metrics, heating systems and smart readiness to meet before you could be considered compliant.   

These are potentially more problematic.  

Heating systems

The big news when it comes to the heating systems metric is that, under the Government proposals no house with a gas boiler would be able to reach a C.  

And with the Government’s own figures showing 79% of PRS homes are heated primarily using gas, this could bring with it huge problems.   

The Government is bringing in this rule to promote cleaner heating systems such as heat pumps – with grant funding of £7,500 available under the Boiler Upgrade Scheme (BUS) to cover around half of the cost.   

However, taking out fully functioning and efficient heating systems to replace them will mean additional cost and massive disruption to your tenant.  

Smart readiness

When it comes to smart readiness, the Government wants to encourage landlords to generate and store their own energy – and is proposing the introduction of solar panels to this end.  

Both of these metrics would require significant investment, and we do have some serious concerns about the plans.  

What does the NRLA want?

In our response to the Home Energy Model consultation, we will be asking the Government to:  

• Recognise that efficient gas boilers have a role and can still provide cheap and efficient heating.   

• Ensure continuity with the old ratings. The new ratings should broadly line up with existing EPC bands to make the system easier to understand.  

• Make ventilation a priority, while recognising no landlord should be forced to install where this will cause increased damp and mould.  

• Recognise the limitations of certain properties. Homes that are unable to make certain improvements should be able to meet the standard in more reasonable ways.   

Could I get an exemption?

There are plans to include exemptions, not least the cost-cap coming in as part of the MEES regulations which cap your spend at £10,000 a property. That means that when you have hit this figure, you can apply for an exemption.   

This cap is reduced to 10% of the property value for homes valued under £100,000.   

The cost cap covers work carried out from October 2025 (that was recommended by the EPC or an expert), as well as the cost of obtaining the EPC.   

Other exemptions will include:   

A solid wall insulation exemption (SWI): This will also be available for those of you who choose not to install it  if there are concerns about damp and mould.   

A third party exemption: This would be available where a tenant or freeholder refuses consent for work .​   

All relevant improvements made exemption: This could be granted where no further recommendations on EPC are available and the house has not hit C.​  

A negative impacts exemption: This is available where the measures would devalue the property or negatively impact it. ​   

A new landlord exemption: This is a six-month exemption to give new landlords time to get work done. ​  

What can I do about it?

You currently have until 18th March to reply to the consultation.  

Once the Government has come to a decision and the Home Energy Model is in place, it will run alongside the existing mechanism for calculating EPCs until October 2029.   

If you purchase an EPC before the end of September 2029 and your EER rating is A, B or C, then your EPC will remain valid for 10 years – something worth thinking about.  

However, if by October 2029 you do not have an EPC rated A, B or C, under the old system, then you will need to commission a new-style EPC, which will be calculated using the Home Energy Model.    

You have various options, depending on your existing rating, something you can find out more about here.   

If you feel you can reach a C under existing rules then it may be worth getting an up-to-date EPC now, giving you time to factor in – and save for – any improvements that will be needed further down the line.   

However, you are already planning energy efficiency improvements to your home, particularly major works such as solar panels, you might opt for the new system.  

More information

• To respond to the consultation click here.  

• Our award-winning Training Academy offers an Energy Efficiency & MEES Compliance eClassroom course. To find out more and book click here.   

• NRLA compliance arm Safe2 provides of all forms of property safety certification, offering landlords a single service to ensure gas, electrical safety and energy performance certificates are up to date. For more information click here.  

• For more information on the outcome of the consultation and the NRLA response keep an eye on our news site and social media channels.