Summary of the proposals
The consultation proposes a shift to a new Energy Performance Certificate (EPC) metric following EPC reform. This would introduce more ambitious MEES requirements, including:
- New standards based on a fabric performance metric and either a smart readiness or heating system metric.
- A cost cap of £15,000 per property for energy efficiency improvements.
- A phased timeline requiring new tenancies to comply by 2028, and all tenancies by 2030.
- Obligations for landlords to commission new EPCs before and after works.
- Potential regulation of short-term lets and exemptions tied to affordability and property type.
Realism, support, and flexibility are vital
Propertymark strongly supports efforts to improve housing energy efficiency but warns that these goals must be realistic, properly supported, and considerate of the sector’s diverse nature. We have long advocated for a measured, practical approach to energy efficiency, calling for well-funded, targeted policy that improves housing standards without destabilising the PRS.
We will continue to engage with DESNZ and keep members informed as the proposals progress.
Reforming EPC metrics
We agree that the current EPC system is outdated and welcome a move to more accurate metrics. However, the proposed “fabric-first” approach disadvantage older, rural, and heritage properties unfairly. These homes are more costly and complex to upgrade and may require extensive works that disrupt tenants or prove unfeasible.
Cost cap concerns
We oppose the proposed £15,000 cost cap and recommend a more realistic £5,000 limit. Our survey of members shows overwhelming concern that the higher cap will price landlords out of the market or lead to rent hikes that ultimately harm tenants. A lower cap would support affordability and allow landlords to make incremental, impactful improvements.
Implementation timeline
We recommend a single compliance date of 2030 for all tenancies—new and existing. This approach avoids confusion, gives landlords sufficient time to plan and upgrade properties, and aligns with the sector’s need for more trained tradespeople. We also support incentives for early compliance and urge investment in the green skills workforce.
Grant funding and affordability
A major barrier to achieving energy targets is funding. Due to a lack of awareness, most landlords have not accessed existing schemes , eligibility barriers, or cumbersome application processes. We call for more accessible, well-publicised, and appropriately tailored funding options.
Exemptions and flexibility
We support an extended 10-year exemption period and recommend further exemptions for listed buildings, properties with recent EPC improvements, and cases where proposed upgrades increase energy costs. We also propose exemptions where tenants do not consent to disruptive works.
Impact on supply
Landlords are already leaving the sector due to rising regulatory pressures. Our members warn that these new requirements could accelerate this trend, especially in low-value areas where returns on investment are limited. This risks the availability of rental stock and undermining the very aims of the policy.
