Joined-up thinking on EPCs is needed to balance with housing reality

Energy efficiency policy has major implications for the private rented sector (PRS), homebuyers and sellers, and the wider housing market. Our response to the UK Government’s consultation on reforms to Energy Performance Certificates (EPCs) and the introduction of the Home Energy Model sets out clear recommendations to ensure changes are grounded in real-world property conditions and avoid unintended consequences for supply.

Green home model house being held in hands

For letting agents, EPC reform affects compliance, portfolio management and client advice. For sales agents, changes to EPC methodology can influence marketing, buyer expectations and property values.

It is essential that:

  • Agents are given adequate notice of regulatory change
  • Updated guidance is issued well in advance of implementation
  • Training and support are available to ensure consistent interpretation

The property sector plays a central role in delivering the UK’s climate ambitions. However, policies must be workable on the ground. We will continue to engage with the Department for Energy Security and Net Zero and other stakeholders to ensure the voice of property professionals is heard as these reforms progress.

Protecting owners during transition

We recognise the limitations of the current Standard Assessment Procedure (SAP) methodology and support efforts to improve the accuracy of EPCs. However, the transition to a new Home Energy Model must be carefully managed.

Clear communication to property owners and agents about how ratings will change under the new system must be a priority, with transitional arrangements in place to prevent properties from being unfairly penalised.

EPC ratings influence mortgage lending, property values, minimum energy efficiency standards and landlord investment decisions. Sudden or poorly explained changes risk undermining confidence in the system.

EPC on a tablet
10 Dec 2024
Proposed overhaul of Energy Performance Certificates will impact the entire property sector

Aligning reform with targets and exemptions

EPC reform mustn't be viewed in isolation from the minimum standards policy because the sector needs long-term certainty on both aspects to comply effectively. 

In its recent Warm Homes Plan, the UK Government confirmed that PRS homes in England and Wales must meet EPC C by 2030. As we have set out in our wider energy efficiency policy work, this target must be supported by sustained funding and practical exemptions.

We have consistently warned that overly ambitious or poorly designed targets could reduce the supply of rented homes, particularly where older or harder-to-treat properties are concerned. Without proper support, landlords may exit the market rather than invest.

Our wider energy efficiency policy highlights the need to move away from a “one size fits all” approach and instead recognise differences in property age, type and construction. The UK Government should target funding based on property archetypes, not tenure alone.

Parents with daughter on sofa with tabet
22 Jan 2026
Warm Homes Plan sets 2030 energy efficiency deadline for the PRS

Linking EPCs to clear improvement pathways

EPCs should provide a practical roadmap for improvement rather than a simple headline rating. Property owners need a realistic sequencing of measures and certainty over which improvements will deliver regulatory compliance. Without this clarity, there is a risk of piecemeal upgrades, wasted investment and confusion for both agents and consumers.

We believe energy efficiency targets should be linked directly to EPC recommendations, so landlords and homeowners have a structured route to achieving warmer homes and lower emissions.

Energy Efficiency
22 May 2025
Path to net zero must not lead to zero homes

Funding and incentives are critical

Improving energy performance comes at a high cost, and without sustained funding and fiscal incentives, carbon reduction targets are unlikely to be met.

We continue to campaign for meaningful financial support, including reform of grant schemes to ensure they are accessible and cover a wider range of improvements, the reintroduction and expansion of the Landlord’s Energy Saving Allowance, and tax incentives to encourage investment, including VAT relief on energy efficiency works.

Read our full consultation response