Any EPC improvement recommended by an accredited assessor counts toward the £10,000 cost cap per property, as does the EPC assessment fee itself. Works must be carried out on or after 1 October 2025. The compliance deadlines are 1 April 2028 for new tenancies and 1 April 2030 for all tenancies.
From 1 October 2025, all qualifying EPC improvement works count toward your £10,000 cost cap per property. Any money you've already spent on insulation, heating upgrades, or glazing since that date is accumulating toward the cap right now, and could reduce how much you need to spend before the April 2030 deadline.
EPCGuide's analysis of 29.2 million EPC certificate records shows that around 37% of privately rented properties currently sit below EPC C, with the bulk in bands D and E. For most of those landlords, the £10,000 cap is the central planning number: how much you must spend before you can legally stop.
Here's what qualifies, what doesn't, and how to keep records that will stand up to scrutiny.
What Is the £10,000 Cost Cap?
The £10,000 cost cap is the maximum a landlord is required to spend on EPC improvements per property to reach EPC C. It was confirmed in the government's January 2026 partial response to the EPC consultation, reduced from the earlier £15,000 proposal.
The key rule: you must make all the improvements your EPC assessor recommends, up to a maximum total spend of £10,000. If you've spent £10,000 on recommended works and still can't reach EPC C, you can register a cost cap exemption and continue letting legally.
When did the cap start counting?
1 October 2025. The NRLA confirms: "The cap includes eligible works undertaken from October 2025, as well as the cost of obtaining the EPC itself." Any qualifying spend on or after this date contributes to your £10,000.
This is the key planning insight: landlords who started improvements in late 2025 or early 2026 are already building up cap credit, even though the formal compliance deadline for all tenancies is not until April 2030.
Which Improvements Count? The Full List
The government's position is clear: all "relevant energy efficiency measures" recommended by an accredited EPC assessor qualify. In practice, this covers the following categories:
Insulation measures
| Improvement | Typical cost | Typical SAP impact |
|---|---|---|
| Loft insulation (270mm) | £300-£600 | +4-8 points |
| Cavity wall insulation | £350-£500 | +5-10 points |
| Internal wall insulation | £2,000-£8,000 | +4-12 points |
| External wall insulation | £5,000-£20,000+ | +8-15 points |
| Floor insulation | £500-£2,000 | +2-4 points |
| Hot water cylinder jacket | £20-£50 | +1-2 points |
Heating systems
- Boiler replacement (to modern A-rated condensing boiler)
- Air source heat pump (ASHP) installation
- Ground source heat pump (GSHP) installation
- Storage heater upgrades
- Communal heating connection (where available)
Heating controls
- Programmers and timers
- Room thermostats
- Thermostatic radiator valves (TRVs)
- Smart heating controls (Tado, Nest, Hive, etc.)
- Hot water cylinder thermostat
Windows and doors
- Double glazing or triple glazing replacement
- Secondary glazing
- Draught-proofing (windows and doors)
- Letterbox draught excluders
Renewable energy
- Solar PV panels (photovoltaic)
- Solar thermal hot water system
- Battery storage (where combined with solar)
Does the EPC assessment fee count?
Yes. The NRLA confirmed this explicitly: "The cap includes eligible works undertaken from October 2025, as well as the cost of obtaining the EPC itself." So your assessor's fee, typically £50-£150, counts toward your £10,000.
What Doesn't Count?
The improvements must be on your EPC assessor's recommended list or be recognised energy efficiency measures. The following do not count toward the cap:
- General home maintenance (replacing a broken radiator, repainting walls)
- Kitchen or bathroom renovations
- Garden landscaping
- New flooring or carpet
- Decorative upgrades
- Works that improve comfort but have no EPC impact (e.g. a new shower that doesn't change the hot water system type)
The test is: does the improvement appear on your EPC assessor's recommendations, or is it a recognised energy efficiency measure under the MEES regulations? If it's neither, it doesn't count.
How to Track Your Spend Toward the Cap
This is where most landlords fall short. Tracking your cap spend requires keeping a proper paper trail from day one, not reconstructing it in 2029 when you're trying to register an exemption.
Documentation checklist
Keep all of the following for every qualifying improvement:
- A copy of your current EPC certificate (with the improvement recommendations listed)
- Invoice or receipt for each piece of work, dated after 1 October 2025
- Confirmation that the works were carried out by a suitably qualified installer (TRUSTMARK-registered where relevant)
- Any updated EPC certificate commissioned after works are complete
- A running total of qualifying spend per property
Store these in a folder per property, either physical or digital. If you use property management software, keep a note against each property.
The epcadvisor.co.uk guidance confirms what you'll need if you claim a cost cap exemption: "A list of the recommended improvements and those carried out. Invoices and receipts showing costs incurred. EPC/assessment evidence that no further relevant improvements are available within the cap."
Using the Cap Strategically
The £10,000 cap reframes how landlords should think about their improvement timeline:
If your property is already at D: Most D-to-C improvements cost £1,000-£5,000. You can hit compliance well within the cap, often with money to spare. Act early: installer availability tightens every year as the April 2028 new-tenancy deadline approaches.
If your property is at E: Works typically cost £3,000-£10,000 depending on the upgrade path. You're likely to use most or all of the cap. Prioritise the improvements your assessor flags first, as these deliver the highest SAP points per pound spent. See our guide to the cheapest EPC improvements.
If your property is at F or G: You will almost certainly exceed the £10,000 cap before reaching C. In this case, your goal is to spend up to £10,000 on the recommended improvements, then register the cost cap exemption. The exemption lasts 10 years, covering you past the initial 2030 deadline.
The spread-cost opportunity: The NRLA and independent advisers are clear that the October 2025 start date exists specifically to allow landlords to spread costs over roughly 4-5 years rather than face a large bill in 2029-2030. Landlords who phase improvements over 2025-2028 will face better availability, better prices, and less financial strain than those who leave it until the final year before April 2030.
Combining Grants With Your Cap Spend
Grant schemes can reduce your out-of-pocket cost significantly below £10,000 if your property or tenants qualify.
ECO4: Available where your tenants meet low-income or benefit eligibility criteria. Covers up to £14,000 per property for insulation and heating upgrades. ECO4 closes 31 December 2026, so landlords with eligible tenants need to act now. The Warm Homes Plan takes over from 2027. See our full ECO4 landlord guide.
Boiler Upgrade Scheme (BUS): Offers £7,500 toward a qualifying air or ground source heat pump. Landlords are eligible and the scheme is not means-tested. The BUS is open now and runs alongside the MEES cost cap. Read the Boiler Upgrade Scheme application guide for eligibility criteria and the full application process.
Note: the question of whether grant amounts reduce your cap contribution has not been formally resolved by the government. The conservative planning assumption is that the full project cost counts toward your £10,000 regardless of how much a grant covered.
What Happens When You Hit £10,000 and Still Can't Reach C?
If you've spent £10,000 on your EPC assessor's recommended improvements and the property still can't reach EPC C, you register a cost cap exemption on the PRS Exemptions Register.
You'll need to provide:
- Evidence of the improvements made (invoices, receipts)
- The total qualifying spend (must be at or above £10,000)
- A current EPC confirming the property is still below C despite the works
- Evidence that no further works remain within the recommended improvements list
Once registered, the cost cap exemption lasts 10 years. After that, you must try to achieve C again, or register a new exemption if still unable.
Read our full guide to exemption types and how to register.
Frequently Asked Questions
Does grant funding count toward my £10,000?
The broadly accepted position is that the cap reflects the total project cost, not your net spend after grants. If a £5,000 heat pump is half-funded by a grant, your cap contribution is likely the full £5,000, not the £2,500 you paid out of pocket. This has not been formally confirmed for the post-2028 MEES framework. Seek written confirmation from your local authority or scheme installer before planning around a different figure.
Does the cap reset between properties?
No. Each property has its own separate £10,000 cap. If you own five properties, each has its own £10,000 limit and each tracks improvement costs independently.
What if I spent money before October 2025?
Spending before 1 October 2025 does not count toward the cap. The October 2025 start date is the confirmed cut-off in the January 2026 government response. Pre-2025 improvement costs cannot be backdated.
My property is under £100,000 in value, does that change things?
Yes. The NRLA confirms that for properties valued at under £100,000, landlords may be eligible for a property value exemption if the cost of compliance exceeds 10% of the property's market value. This is separate from the standard cost cap and designed to protect landlords of very low-value properties from disproportionate compliance costs.
Do I need to spend £10,000 before claiming the exemption?
Yes, the cost cap exemption requires evidence that you've spent up to £10,000 on recommended improvements. It is not an upfront opt-out. You must attempt compliance first and reach the cap before registering.
Does the Boiler Upgrade Scheme grant count toward my £10,000?
The Boiler Upgrade Scheme gives landlords £7,500 toward a qualifying heat pump, and landlords are eligible without a means test. The planning assumption is that the full heat pump installation cost counts toward your cap (the grant reduces your out-of-pocket spend, not your cap tally). A typical air source heat pump runs £10,000-£15,000, so the BUS grant can bring your net cost well below the cap even when the total project cost exceeds it. Confirm the cap treatment in writing with your installer or a TRUSTMARK adviser.
What will happen to the £10,000 cap under the Warm Homes Plan?
The Warm Homes Plan launches in 2027 as the successor to ECO4 and is expected to focus on low-income households. The £10,000 MEES cost cap is tied to the 2028 and 2030 compliance deadlines, not to any specific grant scheme, so it remains in place regardless of how the Warm Homes Plan is structured. EPCGuide will update this page if the plan introduces new landlord-specific funding or cap changes.
What to Do Next
If you've made any EPC improvement works since October 2025, locate the invoices and receipts today and start a tracking file. You're already building cap credit: document it.
If you haven't started yet, use our property cost estimator to see what typical improvement costs look like for your property type and current EPC band. For D-rated properties in particular, the cost to reach C is often significantly less than the £10,000 cap, and the window to act at good prices is now.