One widely quoted estimate puts the average cost of upgrading a rental property to EPC C at £7,633, and the bill across 3.38 million non-compliant properties at £26 billion. Government's own estimate is considerably lower.
But averages obscure everything that matters. A landlord in Kensington can absorb the same upgrade cost that would bankrupt a landlord in Powys, because London rents are four times higher. The real story isn't what upgrades cost. It's what they cost relative to what you earn.
Here's the full regional picture.
The National Picture: Which Average You Use Matters
There is no single agreed national figure, and the published estimates differ by more than £2,000 per property. Three are worth knowing:
- £5,387 per property. The MHCLG impact assessment published alongside the January 2026 government response, under the government's preferred policy option. This is the official figure, and it is the lowest of the three.
- £6,864 per property. The English Housing Survey 2023-24 estimate of the average cost of bringing a rented home up to band C. This rises to £10,788 for homes built before 1919 and to roughly £17,000 for those currently rated F or G. These are modelled figures produced using the government's Standard Assessment Procedure, not records of what landlords actually spent.
- £7,633 per property. Analysis published in March 2026 by Just Landlords, a landlord insurance provider, and reported by Landlord Today and The Energyst. It covers non-compliant private rental properties in England and Wales, and it is the source of the regional breakdown in the rest of this article. Note that Just Landlords is a commercial insurance brand rather than an independent research body, so treat the headline as one estimate among several.
The same Just Landlords analysis puts the number of non-compliant properties at 3.38 million and the total sector bill at more than £26 billion. The government's impact assessment works from a smaller base, around 1.75 million properties receiving measures by 2030, and a total of £9.87 billion.
That gap is worth sitting with. It largely reflects different assumptions about how many properties need work and how deep that work goes. What has received far less attention than any of the headline totals is how unevenly the cost falls by area, which is where the Just Landlords data is genuinely useful.
The Repair-to-Rent Ratio: A Better Way to Measure the Pain
Just Landlords introduced the concept of the repair-to-rent ratio, the average upgrade cost expressed as a percentage of average annual rental income in each area. This is a far more useful metric than raw cost because it captures the actual financial burden on landlords.
A London landlord with a 20% repair-to-rent ratio is spending the equivalent of 10 weeks' rent on upgrades. A rural Welsh landlord with a 148% ratio is spending the equivalent of 18 months' rent.
Worst Repair-to-Rent Ratios: Where Landlords Are Most Squeezed
| Local Authority | Repair-to-Rent Ratio |
|---|---|
| Powys | 148% |
| Hartlepool | 138% |
| Isle of Anglesey | 135% |
| Gwynedd | 131% |
| Northumberland | 129% |
In Powys, rural mid-Wales, the average upgrade cost exceeds the annual rental income: £10,759 to reach band C against average annual rents of £7,248, with 83% of properties in the county currently below band C. A landlord there would need to redirect every pound of rent for roughly 18 months just to cover the work, before a penny of maintenance, mortgage, or income.
Just Landlords published the ratio for each authority but not the underlying cost and rent figures for every one, so only the Powys breakdown is shown here.
Best Repair-to-Rent Ratios: How London Is Insulated
| Local Authority | Repair-to-Rent Ratio | Notes |
|---|---|---|
| Kensington & Chelsea | 20% | High rents absorb the same upgrade cost |
| Westminster | 22% | |
| Islington | 25% | |
| Hammersmith & Fulham | 25% | |
| Camden | 26% |
London's top boroughs face the same retrofit costs as anywhere else in the country. What's different is that rents of £2,500–£4,000/month make those costs a much smaller proportion of income. A 20% repair-to-rent ratio means a landlord recovers the upgrade cost in under three months of extra margin, if they can raise rents post-upgrade.
EPC Compliance Levels by Region
The repair-to-rent data tells you where costs are most painful. Compliance data tells you how much work is left to do.
Most Compliant Areas
| Local Authority | Properties at EPC C+ |
|---|---|
| Tower Hamlets | 66% |
| West Northamptonshire | 55% |
| Southwark | 53% |
| Bracknell Forest | 51% |
| Islington | 51% |
Urban areas with newer housing stock and higher-density flat conversions tend to perform best. Many purpose-built urban flats already meet EPC C through double glazing and communal heating systems.
Least Compliant Areas
| Local Authority | Non-Compliant Properties |
|---|---|
| Isles of Scilly | 90% |
| Ryedale (North Yorkshire) | 88% |
| Isle of Anglesey | 87% |
| Burnley | 85% |
| Pendle | 85% |
The pattern is consistent: rural, coastal, and northern areas with older housing stock cluster at the bottom. Nine in ten properties in the Isles of Scilly sit below band C. Ryedale and Pendle face similarly daunting numbers. All of these are lawful to let today provided they are band E or above; the figures matter because of what would be required if the proposed band C standard becomes law.
Deep Retrofit Zones
Some areas face a particularly expensive challenge: more than half their non-compliant properties sit in bands E, F, or G, meaning simple measures won't be enough.
| Area | Properties in Band E/F/G |
|---|---|
| Isles of Scilly | 70% |
| Isle of Anglesey | 60% |
| Ryedale | 57% |
| Eden (Cumbria) | 56% |
| Powys | 52% |
Properties in this category typically require solid wall insulation (£2,000–£8,000) and potentially a heat pump, the most expensive and disruptive upgrades. Many are pre-1919 stone or brick construction with no cavity walls to fill.
Why the North–South and Rural–Urban Divide Exists
The regional cost gap isn't random. Four structural factors explain why rural and northern landlords face a significantly harder path to compliance.
Property age. Rural areas contain a disproportionate share of pre-1919 buildings. These properties use solid-wall construction, no cavity to fill with blown mineral fibre. Solid wall insulation (internal or external) costs four to eight times more than cavity wall insulation and involves significant disruption.
Property type. Detached and semi-detached houses have more exposed surfaces than terraced rows or flats. More surface area means more heat loss and a bigger uplift required from insulation measures.
The rent gap. Average annual rents in rural areas run £6,000–£9,000. In prime London they run £36,000–£48,000. The upgrade costs are broadly similar, but what that cost represents as a proportion of income is completely different.
Heat pump suitability. Older rural housing stock is frequently the least suited for heat pump installation, the combination of poor insulation, large floor areas, and older radiator systems means heat pumps underperform. Under the incoming Home Energy Model metrics (from 2027), heat pumps and solar panels will be required for many properties to achieve a C rating, further disadvantaging rural stock.
What This Means for Landlords in Worst-Hit Areas
If your property is in one of the high-ratio areas above, the situation is difficult, but it's not unmanageable. Three steps before you panic.
Check Your Individual Property First
Regional averages can be misleading for individual properties. A pre-1919 terraced house in Burnley might cost £4,000 to upgrade (loft insulation + modern boiler controls + LED lighting). A detached Victorian farmhouse in Powys might genuinely cost £14,000. Your EPC report's recommended measures section shows exactly which interventions apply to your property and what they cost.
Use the EPCGuide property cost estimator for a ballpark figure based on your property type and current EPC band.
Available Grants Can Significantly Reduce the Bill
Two major schemes can cut costs substantially:
- ECO4: For properties below EPC D with tenants on qualifying benefits. Can fund insulation and heating upgrades at no cost to the landlord. Check grant eligibility
- Warm Homes Local Grant: Area-dependent. Greater Manchester landlords in the Good Landlord Charter can access up to £30,000. Other combined authorities are running similar programmes. See if your area is covered
The Cost Cap Exemption, At The Figure Actually In Force
The cost cap in force today is £3,500 including VAT, and it is measured against band E, not band C. If £3,500 of qualifying work will not lift an F or G rated property to band E, you can register a high-cost exemption on the PRS Exemptions Register, valid for five years. That is the exemption that exists right now.
The £10,000 cap measured against band C is part of the government's January 2026 proposal. It is not law, and no statutory instrument amending the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 has been laid. There is currently no cost cap exemption to register against band C, because there is no band C requirement to be exempt from. See the full rules at cost cap exemptions.
Keep every invoice regardless. If the proposal is legislated, documented spend is what an exemption application will rest on.
How Does This Compare to Your Local Area?
The national and regional data gives you context. For the specifics of your city, local grant schemes, council enforcement priorities, and property-type patterns, we've published detailed local guides:
- London EPC Landlord Guide
- Manchester EPC Landlord Guide
- Birmingham EPC Landlord Guide
- Leeds EPC Landlord Guide
- Newcastle EPC Landlord Guide
- Sheffield EPC Landlord Guide
- Bristol EPC Landlord Guide
If your city isn't listed, the property cost estimator and grant checker tools work for any UK address.
Frequently Asked Questions
What's the average EPC upgrade cost in the UK?
It depends which estimate you use, and they differ by more than £2,000. The MHCLG impact assessment of January 2026 puts the average landlord cost at £5,387 per property under the government's preferred option. The English Housing Survey 2023-24 puts the average cost of bringing a rented home to band C at £6,864. Just Landlords' March 2026 analysis puts it at £7,633 per non-compliant property. The range around any of these is wide: a D-rated property with good insulation may cost only £1,000–£3,000 to push into C, while an E or F-rated rural property requiring solid wall insulation and heating upgrades can cost £12,000–£15,000.
Which UK regions have the highest EPC upgrade costs relative to income?
Rural mid-Wales (Powys, Gwynedd), the Isle of Anglesey, and parts of the north-east (Hartlepool, Northumberland) have the worst repair-to-rent ratios, in some cases upgrade costs exceed one full year's rental income. This is driven by a combination of older property stock, lower rents, and the need for expensive solid wall insulation.
Why are EPC upgrade costs more manageable in London?
The upgrade costs themselves are broadly similar to the rest of the country. What's different is that London's high rental yields, often 2–4 times higher than rural equivalents, mean the same upgrade represents a far smaller share of annual income. A landlord in Kensington & Chelsea has a repair-to-rent ratio of just 20%.
Are there grants available for landlords in high-cost regions?
Yes. The ECO4 scheme (for properties below EPC D with lower-income tenants) can fund insulation and heating upgrades at no landlord cost. The Warm Homes Local Grant covers up to £30,000 in some areas. The Boiler Upgrade Scheme offers up to £7,500 toward a heat pump installation, available to all landlords regardless of tenant income. Availability depends on your local authority and tenant eligibility. Use the grant checker tool to find what applies to your property.
What is a "deep retrofit zone" for EPC purposes?
Areas where more than 50% of non-compliant properties are in bands E, F, or G, meaning they're likely to need solid wall insulation and potentially heat pumps, the most expensive and disruptive upgrade route. Isles of Scilly, Isle of Anglesey, Ryedale, Eden, and Powys are the hardest-hit.
Data: regional repair-to-rent ratios, compliance percentages and band E/F/G shares are from the Just Landlords regional analysis (March 2026), as reported by Landlord Today and The Energyst. Just Landlords is a landlord insurance provider, not an independent research body. National average costs: MHCLG impact assessment, "Improving the energy performance of privately rented homes" (January 2026), and the English Housing Survey 2023-24. All figures are averages, individual properties will vary.
Regulatory position at the time of writing: the minimum EPC band to let in England and Wales is E, in force since 1 April 2020, with a £3,500 including VAT cost cap and a maximum civil penalty of £5,000 in total per property. Band C by 1 October 2030, a £10,000 cap and a £30,000 maximum penalty are government proposals from the January 2026 response and the Warm Homes Plan. They require an Act of Parliament and a statutory instrument amending the 2015 Regulations. Neither has been laid.