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Leasehold landlords: set up to fail under the new energy efficiency regulations?

9 April 2026

New energy regulations could force leasehold landlords to exit the market, as properties are expected to achieve a higher EPC rating of C, and those with fossil-fuel heating may face compliance issues.

If you are a leasehold landlord, the main concern is what options are available if upgrades are beyond your control. Mia Rotaru, NRLA Public Affairs Officer, explores what this means in practice. 

Upgrading might not always be possible

 Unlike freeholders, leasehold landlords lack full control over retrofit decisions. Flats, in particular, are not isolated units; they are part of a larger structure, which presents challenges that blanket approaches do not adequately cover.  

For example, while installing cavity wall insulation in a single house is fairly simple, in a block of flats, the cavity extends throughout the entire building, requiring a collective approach. This also applies to: 

  • External wall insulation 

  • New windows 

  • Heat pumps 

  • Solar PV systems 

Even if you are willing to invest in improvements, progress can be difficult to achieve. Implementing these changes requires approval from the freeholder and coordination with other leaseholders, which can complicate and slow the process.  

How can you be compliant when it feels impossible?

 Under the proposed system, there is a real risk that leasehold landlords could fall short of EPC C not because they have failed to act, but because they are unable to. 

In these situations, landlords may need to rely on a third-party consent exemption to rent the property under the new regulations. 

The Government recognises that certain energy efficiency improvements require approval from third parties before they can be carried out. Where such consent is required but cannot be obtained, landlords may be able to register an exemption. This allows the property to remain on the market while still complying with the regulations. 

The bottom line

 The real obstacle isn't landlords’ willingness to act, but a system that makes taking action much harder. 

Without a more flexible and practical approach, there is a real risk that leasehold landlords will be among those most affected by new Minimum Energy Efficiency Standards, not due to a lack of effort, but because the regulations do not fully reflect the realities of leasehold properties. 

We recognise that this is a complex issue, and we are continuing to engage with the Government to ensure both leaseholders and freeholders have the support and clarity needed to comply, while continuing to provide safe, warm homes for tenants. 

More information:

  • For more information about the proposed changes and the latest government announcements on the Warm Homes plan, the EPC, 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.      

  • NRLA partner Domna is a one stop shop, when it comes to helping you improve your properties Energy Performance Certificate (EPC) ratings. For more information click here.       

  • Part of the NRLA family, Safe2 is a one-stop-shop for all things compliance, allowing you to organise inspections and order safety certificates, including EPCs, at the click of a button. For more information click here.      

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