Member representation: Consultation responses and position papers

Propertymark’s response to the Ministry for Housing, Communities and Local Government (MHCLG) consultation on reforms to the Energy Performance of Buildings (EPB) regime addresses the wide-ranging proposals, covering changes to Energy Performance Certificates (EPCs), Display Energy Certificates (DECs), and Air Conditioning Inspection Reports (ACIRs). We welcome many of the proposed reforms but have also raised concerns, especially around commercial and heritage buildings and HMOs, and made recommendations to ensure the final policy is fair, practical, and effective.

The UK Government’s proposed disability and health-related benefits system reforms could significantly reshape support for vulnerable people. Propertymark responded to the Work and Pensions Committee’s inquiry on these plans and welcomed many proposals. We made it clear, however, that housing must be central to any efforts to ‘Get Britain Working’.

A major consultation for a new Land Use Framework aims to balance the need for 1.5 million new homes, expansion of energy infrastructure, and the creation of new towns, alongside the protection of the environment and the transition to a low-carbon economy. Propertymark supports a balanced approach to changes in land use, however, we believe the UK Government has significantly underestimated the land required for residential development.

Plans are afoot to strengthen HMRC (HM Revenue and Customs) to act quickly and robustly against professional tax advisers who help clients avoid paying the correct tax. Propertymark welcomes this because it aligns with our calls to the Treasury, and we support HMRC’s ambition to ensure the financial sector upholds the highest standards and integrity of the tax system.

Propertymark urges the UK Government to make access to housing a central part of its welfare system reform. Without suitable affordable housing options, it will be much harder to address other barriers to work, such as improving physical and mental health or engagement with education and training. Proposals in the Pathways to Work Green Paper will overhaul the existing system and introduce new initiatives, including unemployment insurance, to create sustainable health and disability benefits and employment support.

The UK Government has published proposals to reform planning committees in England as part of its broader planning reform agenda, setting out significant changes that could affect how planning decisions are made locally. Propertymark supports reform to improve the consistency and speed of decisions but warns that the current proposals may miss the mark, especially around delegation and local flexibility.

Propertymark has submitted a response to the House of Commons Public Bill Committee's call for evidence on the Bill, focusing on key areas that affect the property sector, particularly anti-social behaviour (ASB) and the protection of vulnerable tenants from exploitation such as cuckooing and county lines activity. Our key message is clear: no matter how strong the tools , they will only work if landlords and property agents are informed and engaged in the implementation.

The Digital Markets, Competition and Consumers Act (DMCC), which passed into law on 24 May 2024, contains provisions to prohibit unfair commercial practices, replacing and updating the Consumer Protection from Unfair Trading Regulations 2008 (the 2008 regulations). The legislation hands direct enforcement powers to the Competition and Markets Authority (CMA), giving them the authority to act on breaches of consumer protection rules, including requirements for providing material information.

The Scottish Government has launched a technical consultation on proposed changes to lodgement fees and penalty charges as part of its ongoing reform of Energy Performance Certificates (EPCs). This follows the publication of the Scottish Government’s response to a 2023 consultation on EPC reform and outlines plans to introduce new EPC regulations in 2025, with enforcement scheduled for 2026.

The Ministry of Housing, Communities and Local Government (MCLHG) and the Welsh Government have proposed new regulations overhauling how insurance costs are charged to leaseholders in multi-occupancy buildings, to increase transparency and prevent leaseholders from being overcharged through commissions and hidden fees. While Propertymark supports efforts to ensure fairness for leaseholders, we have warned Ministers that these reforms alone will not bring down insurance premiums; a focus on building safety and insurer confidence is needed to achieve real change.

The Scottish Government is consulting on the process for a Mental Health Moratorium designed to give people with severe mental health conditions respite from debt recovery action, including rent arrears. Propertymark supports the proposals with recommendations to ensure the scheme works effectively in practice and recognises the rights of landlords.

The Northern Ireland Executive has published a draft Fuel Poverty Strategy with proposals for improving energy efficiency in homes, protecting consumers, and fostering collaboration across sectors. Propertymark supports the key principles but has highlighted critical areas that need further consideration, including achievable timescales, sensible exemptions, and cost caps that reflect property values.