An Energy Performance Certificate lasts 10 years. But what happens if yours expires while a tenant is still living in your property? Do you need to rush out and commission a new assessment? And with several EPC rule changes either confirmed or pending, it's no wonder landlords are confused.
This guide answers the three questions that are genuinely open right now: what the current rule says, what proposals are still unresolved, and what the Home Energy Model (HEM) transition means for landlords whose EPCs will expire after 2027.
The Short Answer: No, You Don't Need to Renew Mid-Tenancy (Right Now)
Under current law, an EPC expiring during an ongoing tenancy is not a compliance breach. You are not required to commission a new Energy Performance Certificate simply because your existing one has expired while a tenant remains in place.
EPCs are triggered by a letting event — that is, when you market a property for rent or grant a new tenancy. As long as no new tenancy is being created and no marketing is taking place, your obligation to hold a valid EPC does not apply.
You do need a valid EPC in these situations:
- Before marketing the property to any new tenant — even if your current tenant has been in place for years and you are simply finding a replacement
- When granting a new fixed-term or periodic tenancy, including to the same tenant
- If you formally vary the tenancy terms in a way that creates a new agreement — some solicitors and advisors treat this as a new letting event
If your EPC expires mid-tenancy and you plan to continue renting to the same tenant on a rolling basis without any new tenancy agreement, you are not currently required to renew.
Note: Some sources incorrectly state that you must renew an EPC whenever it expires during a tenancy. This is not the current legal position under The Energy Performance of Buildings (England and Wales) Regulations 2012.
How Long Is an EPC Valid For? (Confirmed: Still 10 Years)
An EPC is valid for 10 years from the date of assessment. This is the law as it stands — and, critically, it will remain the law going forward.
The government consulted on reducing EPC validity from 10 years to 5 years, to ensure certificates more accurately reflected improvement works. That proposal was rejected in the January 2026 partial government response. The reason? The majority of landlords opposed the change because of the increased cost and administrative burden.
| Proposal | Government decision (Jan 2026) |
|---|---|
| Reduce EPC validity to 5 years | ❌ Rejected — 10-year period retained |
| Four new headline metrics on EPCs | ✅ Confirmed |
| HEM as new assessment methodology | ✅ Confirmed (delayed to H2 2027) |
| Remove heritage building EPC exemption | ✅ Confirmed |
If you were worried about having to get a new EPC every 5 years, you can stop worrying. The 10-year validity stays.
The Unresolved Question: Will EPCs Need to Stay Valid "At All Times"?
This is where the picture becomes less clear.
The December 2024 consultation proposed that rental properties should need a valid EPC throughout the tenancy — not just at the point of letting. If this rule were confirmed, a landlord whose EPC expired mid-tenancy would need to commission a reassessment immediately, even if no new tenancy was being created.
⚠️ Important: This rule has not been confirmed. The government acknowledged in January 2026 that the question of continuous EPC validity is still being considered "alongside upcoming changes to MEES, to ensure the two regimes work together effectively without placing unnecessary burdens on landlords." Further engagement with landlord groups is planned before any final position is set. A decision is expected later in 2026.
What this means in practice: do not renew your EPC early based on this proposal alone. Monitor the government's response when it arrives — if continuous validity is confirmed, there will be a transition period before it takes effect.
The HEM Reassessment Risk: What Happens When Your Old EPC Expires?
Here is a risk that no other article is explaining clearly: when your current EPC eventually expires and you need a new one, the assessment methodology may have changed — and your property's rating could change with it.
The Home Energy Model (HEM) is the government's new EPC methodology, due to launch in H2 2027 (delayed from the originally planned late 2026). From 1 October 2029, all new EPCs must use HEM.
HEM is fundamentally different from the current system:
- Current (RdSAP 10): Based primarily on estimated energy costs. Gas boilers score well because gas is cheap. A property can achieve EPC C on relatively low insulation standards if it has an efficient gas boiler.
- HEM: Uses four headline metrics — fabric performance, heating system efficiency, smart readiness, and energy cost. A property will need good insulation AND an efficient low-carbon heating system to score well.
| Your EPC expiry date | What happens when it expires |
|---|---|
| Before H2 2027 | Reassessed under current RdSAP 10 — same methodology |
| Between H2 2027 and Oct 2029 | You can choose RdSAP or HEM during transition period |
| After Oct 2029 | Must use HEM — your rating could change |
⚠️ Key risk: If you currently have an EPC C under RdSAP 10 and your certificate expires after October 2029, your property may not achieve a C under HEM — particularly if it has gas heating. Properties heavily reliant on gas boilers without good fabric insulation are most exposed.
The "grandfathering" protection: An EPC C obtained under RdSAP 10 before October 2029 will count as compliant with the 2030 MEES requirement for the duration of its 10-year validity. You will not be required to get a new HEM assessment just because HEM launches — only upon natural expiry.
For a deeper look at the HEM transition and what it means for your property, see our guides: Will My EPC Still Count After the Home Energy Model? and Should I Upgrade My EPC Now or Wait for the New Metrics?
What Should Landlords Do Right Now?
Given the three developments above, here is a practical checklist:
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Check your EPC expiry date — go to epcregister.com and search by postcode or address. Your EPC's expiry date is printed on the certificate.
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If your EPC expires before H2 2027 — no urgency. Current rules apply. You don't need to act unless you're re-letting.
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If your EPC expires between H2 2027 and October 2029 — consider whether you want to renew under RdSAP 10 before HEM becomes mandatory, to "lock in" your current rating for another 10 years. This is particularly worth considering if your property has gas heating.
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Do not renew mid-tenancy purely because of the "always valid" proposal — this remains unconfirmed. Wait for the government's final position.
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If your EPC has expired and you're re-letting — you must commission a new EPC before marketing the property. This is a legal requirement, and failure to provide a valid EPC is a compliance breach that affects your ability to serve a valid Section 8 notice.
For guidance on registering a formal exemption if your property cannot reach EPC C, see: EPC Exemption Register: How to Apply
Frequently Asked Questions
My EPC expires this year while my tenant is still in place. Am I in breach?
No — under current rules, EPC expiry during an ongoing tenancy is not a compliance breach. You are only required to hold a valid EPC when letting or marketing the property. If your tenancy is continuing unchanged, no immediate action is required. Watch for the government's decision on the "always valid" proposal later in 2026.
Do I need a new EPC if I sign a new tenancy agreement with the same tenant?
Yes. A new tenancy — even with the same tenant — is a new letting event. You must provide a valid EPC before the new tenancy begins. If your current EPC has expired, you'll need to commission a fresh assessment first.
Will my EPC C rating still count for MEES compliance after 2030?
An EPC C obtained under RdSAP 10 before October 2029 will be treated as compliant for the duration of its 10-year validity. When it eventually expires after 2030, you'll need a new HEM EPC — and you'll need to demonstrate compliance under the new metrics at that point.
Where do I find my EPC expiry date?
Search at epcregister.com by postcode or full address. Your certificate will show the assessment date; add 10 years to get the expiry date. Your original certificate (which you should have provided to your tenant) also states the validity period. See also: The Home Energy Model Delay — What Landlords Need to Know
Last updated: March 2026. EPC rules are subject to ongoing reform — check gov.uk for the latest position on the "always valid" proposal and HEM implementation dates.