EPC Requirements for Landlords: What's Changing, What It Costs, and How to Plan

Current EPC requirements

Under the Minimum Energy Efficiency Standards (MEES) regulations, it is currently unlawful to grant a new tenancy — or renew an existing one — for a privately rented property in England and Wales with an Energy Performance Certificate rating below E. This has been in force since April 2018 for new tenancies and April 2020 for all tenancies.

An EPC is valid for ten years from the date of assessment. Properties with an EPC rating of E or above are currently compliant for letting purposes, regardless of the underlying energy efficiency of the property.

What is changing and when

The government has proposed raising the minimum EPC standard for private rented properties in England and Wales from E to C. Under proposals consulted on most recently in 2023, the requirement would apply to new tenancies from 2028 and to all tenancies from 2030, with a cost cap of £15,000 per property beyond which landlords would not be required to spend.

It is important to note that these changes are proposals, not yet enacted legislation. The timeline has already shifted multiple times since the original 2025 target date. However, the direction of travel is clear, and landlords with properties below a C rating who intend to continue letting will need to plan and fund improvements regardless of the precise implementation timeline.

Exemptions available

Several exemptions are available where a property cannot be economically improved to the required standard. The cost cap exemption applies where the recommended improvements would cost more than the cap — currently £3,500 for the E standard, and proposed at £15,000 for the C standard — and the property still cannot reach the required rating. A third-party consent exemption applies where the landlord has been unable to obtain necessary consent from a freeholder, lender, or local authority. A wall insulation exemption applies where cavity or solid wall insulation has been assessed as inappropriate or too risky for the specific property type. All exemptions must be registered on the PRS Exemptions Register.

Typical improvement costs

The cost of improving an EPC rating varies significantly by property type, current rating, and the measures required. Loft insulation — the most cost-effective measure for properties with accessible lofts — costs £300-£800 installed and typically delivers a 3-5 rating point improvement. Cavity wall insulation costs £500-£1,500 and delivers a similar improvement. Double glazing, where not already present, costs £5,000-£15,000 for a whole property and delivers significant rating improvements but with long payback periods. Air source heat pumps — likely required for many properties to reach C — cost £8,000-£15,000 installed, often partially funded through the Boiler Upgrade Scheme grant of £7,500.

Properties built before 1919 with solid walls present the greatest challenge — solid wall insulation (internal or external) costs £8,000-£25,000 and is disruptive to install. These properties are most likely to rely on the cost cap exemption if the proposed C standard is enacted.

How to plan for a portfolio

For landlords with multiple properties, the planning process should begin with an audit of current EPC ratings across the portfolio, identifying which properties are already at C or above, which are at D or E requiring improvement, and which are at F or G and currently unlettable without exemption registration. Properties at D with a current valid EPC should be assessed for the gap to C and the likely cost of bridging it. Where the gap is bridgeable within the likely cost cap, planning and funding for improvements should begin well ahead of any deadline — both to spread the capital requirement and to avoid contractor capacity constraints as deadlines approach.