The government has announced significant reforms to the Energy Performance Certificate (EPC) system that will fundamentally change how your rental properties are assessed and what information you’ll need to provide to tenants. If you’re a landlord in England or Wales, these changes will affect you directly, and you need to understand what’s coming.
This isn’t just tinkering around the edges. The Ministry of Housing, Communities and Local Government (MHCLG) and the Department for Energy Security and Net Zero (DESNZ) have published their partial response to consultation on EPC reforms, and the new system is scheduled to launch in October 2026. Here’s what you need to know in plain English.
The current EPC system is being completely overhauled
Right now, your domestic rental property gets a single Energy Efficiency Rating (EER) from A to G. That simple letter grade is about to be replaced with four separate headline metrics, making EPCs significantly more complex but supposedly more informative.
From October 2026, new-style domestic EPCs will show ratings for energy cost, fabric performance (how well insulated the building is), heating system, and smart readiness (how prepared the property is for smart technologies). In addition to these four headline ratings, there’ll be secondary information on energy demand and carbon emissions.
The government received over 1,600 consultation responses, including substantial input from landlords. Many landlords expressed serious concerns about the cost implications and practical challenges of meeting new standards, but the government has decided to proceed with the reforms anyway.
What the new metrics actually mean for your properties
Energy cost metric: This replaces the current single EER rating and shows tenants what they’re likely to spend on energy. It’s responsive to energy prices, which means the rating could become outdated as prices change. The government acknowledges this isn’t perfect, but they’re keeping it because tenants care about costs.
Fabric performance metric: This measures how well insulated your property is, looking at walls, roofs, floors, windows, and doors. Unlike the cost metric, this doesn’t change with external factors like energy prices. If you own older properties, this is where you might struggle. The government acknowledges that owners of period properties raised concerns that their buildings would perform poorly on this metric, but they’re implementing it anyway.
Heating system metric: This assesses your heating system and rewards properties with lower carbon heating like heat pumps. The catch? Heat pumps are currently more expensive to run than gas boilers, and this wasn’t lost on consultation respondents. The government heard these concerns but is pressing ahead regardless, as part of their net zero commitments.
Smart readiness metric: This evaluates whether your property has smart technologies installed. There were mixed views on this in the consultation, with some landlords pointing out that smart technologies aren’t viable in rural areas with poor internet connectivity. Again, the government is proceeding with this metric.
Energy demand and carbon metrics: These will be shown as secondary information. Energy demand shows predicted energy usage (not including appliances), whilst the carbon metric shows modelled emissions from the property.
The ten-year validity period is staying (for now)
There’s some good news. The government consulted on reducing the EPC validity period from ten years to five years, which would have meant more frequent assessments and higher costs for landlords. The majority of landlords strongly opposed this, citing increased costs and administrative burden.
The government has listened and will maintain the current ten-year validity period for reformed EPCs. Existing EPCs will also retain their ten-year validity. However, you can still commission a new EPC voluntarily if you’ve made improvements and want to demonstrate this to tenants or prospective buyers.
You’ll need an EPC before marketing, not after
This is a significant practical change. Currently, you have 28 days after marketing a property to obtain an EPC. Under the new regulations, you’ll need a valid EPC before you can market the property at all.
The majority of consultation respondents agreed with this change, recognising that prospective tenants should have energy performance information when making decisions. However, landlords, particularly in the short-term let sector, opposed it on the grounds that it would create additional burdens and potentially slow down the marketing process.
The government is proceeding with this requirement, arguing it will make compliance clearer and ensure buyers and renters have the information they need upfront.
Houses in Multiple Occupation: the exemption is ending
If you rent out individual rooms in a House in Multiple Occupation (HMO), you’ve previously been exempt from EPC requirements under current guidance. That’s changing.
Under the new regulations, you’ll need a valid EPC for the entire HMO when a single room is rented out. The EPC will be for the whole property, not individual rooms. The government recognises this will add costs for HMO landlords but argues that tenants in HMOs deserve the same information as other renters.
Many HMO landlords argued that tenants don’t pay for energy costs directly, so EPC information is of limited benefit. The government counters that tenants indirectly cover these costs through their rent, so the information remains relevant.
There will be a 24-month transitional period for HMO landlords to obtain an EPC and comply with Minimum Energy Efficiency Standards (MEES) regulations. Some consultation respondents wanted a longer transition period, others wanted it shorter at 12 months. The government has settled on 24 months.
Short-term and holiday lets: no more exemptions
This will be controversial. If you operate short-term or holiday lets, you’ll now need a valid EPC regardless of who pays the energy bills.
The majority of consultation respondents, particularly short-term and holiday let landlords, disagreed with this proposal. The concerns raised included the unique and often historical character of holiday properties, which makes improving energy efficiency challenging and expensive, and the fact that guests aren’t responsible for bills and therefore have less interest in energy performance.
The government acknowledges these concerns but is implementing the requirement anyway, citing the need for consistency across all rental tenures and better data on the energy performance of all buildings. They also note that some vulnerable tenants may reside in short-term lets for extended periods and deserve the same protections as other renters.
Heritage properties: the exemption is being removed
If you own or let a heritage building, you’ve previously been exempt from EPC requirements. That exemption is being removed.
This was one of the most contentious proposals. The majority of respondents, particularly landlords and owners of heritage properties, disagreed. Concerns centred on EPC recommendations often being inappropriate for heritage buildings, the significant cost of suitable retrofit measures, and the difficulty of complying with MEES in buildings with protected characteristics.
The heritage sector also raised concerns about whether energy assessors have adequate skills and competence to assess complex or unique heritage buildings appropriately.
Despite these objections, the government is removing the exemption. They argue that even with additional complexity, removing the exemption provides greater clarity and better information for landlords and consumers. They claim this will support owners with improvements where viable, without impacting the character of heritage buildings.
What about MEES regulations and compliance?
The government’s response acknowledges the elephant in the room: many landlords are concerned not just about EPCs themselves, but about the cost of works required to meet existing and proposed Minimum Energy Efficiency Standards (MEES).
The government is being somewhat cagey about exactly how the new EPC metrics will interact with MEES requirements. They’ve stated they’re “working to refine the position” on requiring a new EPC when an existing one expires for private rented buildings, and will engage with landlord groups to shape final plans.
What we do know is that MEES exemptions will remain in place to ensure owners aren’t mandated to install unsuitable measures. The government promises further detail in their response to the “Improving the energy performance of privately rented homes” consultation.
For social housing landlords, MEES arrangements will be confirmed through the response to the social rented sector consultation, expected in early 2026.
Practical concerns about recommendations and costs
Many landlords raised concerns during consultation that EPC recommendations aren’t always appropriate for their properties, particularly older buildings, heritage properties, and properties in certain sectors like holiday lets.
The government’s response to this is essentially that EPCs provide information and recommendations, but building owners should seek further expert advice before proceeding with any works to determine if measures are suitable.
In other words, the EPC will make recommendations, but you’re not automatically required to implement them all. However, if MEES regulations apply to your property type, you may face requirements to meet certain standards, with exemptions available where measures aren’t suitable.
The cost concern is very real. Installation of measures like heat pumps, extensive insulation work, or smart technologies represents significant capital expenditure. The government acknowledges these costs but maintains that the reforms are necessary to achieve net zero by 2050, alleviate fuel poverty, and enhance building standards.
The assessor workforce and capacity
Some consultation respondents raised concerns about whether there are enough energy assessors to meet demand, particularly if validity periods were reduced (which isn’t happening) and more property types are brought into scope (which is happening).
The government hasn’t directly addressed capacity concerns in their response, though they note that some accreditation schemes and assessors felt there was sufficient capacity. Other assessors highlighted potential practical challenges, such as delays when assessors have exclusive relationships with letting agents and are on leave.
As a landlord, this could mean booking assessments well in advance, particularly around the October 2026 launch date when demand is likely to spike.
The legacy EER rating will remain temporarily
To support the transition to new-style EPCs, the government will retain the legacy Energy Efficiency Rating (EER) metric alongside the new metrics. This will enable comparison with current EPCs and support ongoing compliance with existing regulatory measures until it’s no longer required.
This means your new EPC will show both the old A-G rating and the four new headline metrics, at least initially. Eventually, the old rating will be phased out once everyone has transitioned to the new system.
What happens to your existing EPC?
If you have a current EPC that’s still valid, it will retain its ten-year validity period. You won’t be forced to get a new-style EPC until your current one expires.
However, if you’re marketing a property and your EPC expires, or if you’re bringing a property type newly into scope (like an HMO room, short-term let, or heritage property), you’ll need to obtain a new-style EPC under the reformed system.
Timeline and implementation
The government is aiming to launch new-style domestic EPCs from October 2026. They acknowledge this timeline is ambitious and want to work with industry to build a shared implementation plan.
A full government response to the remaining consultation questions (covering Display Energy Certificates, EPC data, managing EPC quality, air conditioning inspection reports, and additional questions) will be published later in 2026.
The response on social rented sector MEES is expected in early 2026, following the consultation that closed in September 2025.
What you need to do now
As a landlord, here’s your action plan:
Immediate actions: Review when your current EPCs expire and plan for renewals. If you operate HMOs, short-term lets, or heritage properties currently without EPCs, budget for obtaining these before the regulations change. Ensure you understand which of your properties will be affected and when.
Before marketing properties: From the implementation date, ensure you have a valid EPC before marketing any property. Adjust your processes with letting agents accordingly. Don’t assume you’ll have 28 days after marketing to sort this out, because that grace period is ending.
Plan for the new metrics: Understand that the new EPCs will be more complex. Consider what improvements might be needed across the four metrics (cost, fabric, heating, smart readiness). Seek professional advice about which improvements are suitable and cost-effective for your property type.
Budget accordingly: The combination of more property types requiring EPCs, more frequent assessments when EPCs expire, and potential costs of improving properties to meet MEES requirements means you need to factor these expenses into your business planning.
Engage with government consultations: The government is still consulting on related matters and claims to be engaging with landlord groups. If you’re part of a landlord association or organisation, make sure your voice is heard in these processes.
Stay informed: Watch for the full government response later in 2026, the social housing MEES response in early 2026, and ongoing updates about how the new metrics will interact with MEES requirements.
The bigger picture
These EPC reforms are part of a broader government strategy to improve the energy efficiency of the UK’s building stock, reduce carbon emissions to achieve net zero by 2050, and alleviate fuel poverty.
The government clearly sees landlords as key to achieving these goals, given that the private rented sector houses millions of people. Whether you agree with the approach or not, the direction of travel is clear: expect increasing requirements, more stringent standards, and greater scrutiny of the energy performance of rental properties.
The government’s response acknowledges landlord concerns but proceeds with most of the controversial proposals anyway. The ten-year validity period remains the main concession to landlord objections, whilst requirements are being extended to more property types and made more stringent in various ways.
For landlords, particularly those with older properties, heritage buildings, or operating in the short-term let sector, these changes represent significant challenges. The government promises flexibility through MEES exemptions for unsuitable measures, but the detail of how this will work remains to be finalised.
The next 18 months will be critical. Watch for further government announcements, engage with your professional networks and landlord organisations, and start planning now for how these changes will affect your property portfolio and your business model.
One thing is certain: the days of simple A-G ratings and minimal compliance requirements for certain property types are coming to an end. The new EPC regime will be more complex, more demanding, and will require landlords to engage seriously with the energy performance of their properties whether they like it or not.