On 21 January 2026 the government published their partial response to the December 2024 Energy Performance of Buildings (EPB) regime consultation. This response is part of the wider consultation on reforming the EPB regime to tackle the climate crisis, meet the government’s decarbonisation strategy, and support its aspirations of achieving net zero by 2050. The reforms set out in the response support proposals in the Warm Homes Plan (also published on 21st January 2026), which seeks to lower energy bills and provide greater clarity for households.
The partial response addresses two of the consultation topics, Energy Performance Certificate (EPC) metrics and when certificates are required. The response to the remaining consultation topics is expected this year and will cover Display Energy Certificates (DEC), EPC and DEC data, managing EPC quality, and air conditioning inspection reports.
Key changes set out in the response:
1. New EPC metrics
- For domestic EPCs, the existing single cost metric will be replaced with four new headline metrics: energy cost, fabric performance, heating system, and smart readiness. This new domestic EPC model is being explored in the Department for Energy Security and Net Zero’s (DESNZ) consultation ‘The Home Energy Model: Energy Performance Certificates’.
- For non-domestic EPCs the single carbon-based Environmental Impact Rating will be maintained.
2. Changes to when an EPC will be required
- Currently, an EPC is required at the point of sale or rent, or must have been commissioned prior to marketing. Where the relevant person commissions an EPC before marketing they should secure that it is obtained within seven days of marketing, and failing that, secure that it is obtained within a further 21 days. The consultation response proposes a key change to this – that a valid EPC must be obtained prior to marketing (rather than only commissioned).
- Currently, an EPC is valid for ten years, and this period is ‘intended’ to be maintained. However, there is an anomaly that a new EPC is not needed when an existing one expires during a tenancy. To ensure that the policy has its “intended effect,” the DESNZ and the Ministry of Housing, Communities and Local Government are considering whether a valid EPC will be required throughout all private rented tenancies.
- Currently, a valid EPC is not required for an entire HMO when a single room is rented out. Moving forward, a valid EPC will be required for the whole HMO when a single room is let, thereby providing greater consistency across the private rented sector.
- The exemption allowing landlords to avoid obtaining an EPC for heritage buildings will be removed. This will bring many new buildings into the EPC remit. Where the Minimum Energy Efficiency Standards (MEES) apply, exemptions will remain to ensure that owners are not directed to make unsuitable retrofit recommendations. In the Improving the energy performance of privately rented homes: government response the government said it will update existing exemptions and include a new negative impacts exemption where a landlord can demonstrate that installing a suggested recommendation would negatively impact the building.
New regulations were expected later this year to address the proposals ahead of the implementation of the new domestic EPCs, however following engagement with industry on the delivery timeline the launch of the reforms has been pushed back to the second half of 2027.
The delay and continued uncertainty will be frustrating to both landlords and their tenants.
A reminder of the current MEES
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MEES |
Proposals for change |
| Domestic Private rented sector |
- Current minimum EPC is an E.
- Properties that are an For a G cannot be legally rented unless there is a valid and registered exemption.
- One of the exemptions is that the MEES do not apply if the cost of making cheapest recommended improvement would exceed £3,500.
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In the Improving the energy performance of privately rented homes: government response the following was announced:
- Costs cap will be increased from £3,500 to £10,000 per property.
- Landlords need to ensure properties are at least an EPC C by 1 October 2030.
The change to an EPC C in 2030 is becoming increasingly ambitious given the delay to the domestic EPC reforms set out above. |
| Non-domestic private rented sector |
- Current minimum EPC is an E.
- Properties that are an F or a G cannot be legally rented unless there is a valid and registered exemption.
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There is a lack of clarity as to the future for non-domestic MEES. However, the direction of the government and legislation is clear, and landlords should prepare for higher standards. |
Conclusion
While some aspects of the EPB consultation remain to be addressed, change is on its way. And whilst we await clarification of how existing EPCs will be treated within new regulatory requirements, early preparation for landlords will be key.
For rural estates, the cost of complying with any changes is likely to be particularly high, as many rental properties will need significant improvements. Landlords should plan early to determine how the cost of any remedial works can be shared with tenants.
