On 21 January 2026, the government published its long-awaited partial response to the Energy Performance of Buildings (EPB) regime reform consultation. The full document runs to dozens of pages. Most landlords haven't read it.
This is the plain-English summary, the seven decisions that directly affect you, what each means in practice, and where to find the deeper guidance for each one.
Important caveat: this is a partial response, and it is a statement of policy intent, not law. Several questions, including whether a valid EPC must be maintained throughout a tenancy (not just at the start), when expired EPCs must be renewed, and detailed EPC data management rules, were explicitly left for a final full response later in 2026. Everything below is proposed. To take effect, government must first take powers through an Act of Parliament, then lay a statutory instrument amending the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, targeted to come into force during 2027. No such instrument has been laid. Until then the minimum EPC to let in England and Wales stays at band E, the cost cap stays at £3,500 including VAT, and the maximum civil penalty stays at £5,000 in total per property.
Background: What Was the January 2026 Consultation Response?
In December 2024 the government ran a formal consultation on reforming the entire Energy Performance of Buildings (EPB) regime, covering how EPCs are produced, what they measure, when they're required, and how they interact with Minimum Energy Efficiency Standards (MEES).
The January 21 2026 partial response represented the government's first formal set of policy decisions on that consultation. It is the most important EPC policy document since the 2015 MEES regulations, but it does not change the law by itself.
Here are the seven decisions landlords need to understand.
Change 1, A Single October 2030 Deadline for All Tenancies
What the response proposed: All private rented properties in England and Wales would have to meet EPC C (or register an exemption) by October 1, 2030. This would apply to both new tenancy agreements and existing tenancies with sitting tenants. It is not law yet.
Why this matters: Previous proposals had a tiered timeline, new tenancies first (2028), existing tenancies later. The consultation response collapsed that into a single 2030 deadline for everyone. The NRLA confirmed this is a "concession to the sector" that gives landlords more time.
What it means for you: If you have long-term sitting tenants and were planning to deal with compliance when they leave, that strategy still works, and October 2030 is the date to plan against if the proposal becomes law.
Change 2, A Proposed £10,000 Cost Cap
What the response proposed: The maximum landlords would spend on qualifying energy improvements before becoming eligible for the high-cost exemption is £10,000 per property, up from the £3,500 including VAT in force under the 2015 Regulations. Spend that would count includes assessments, improvement works, and associated installation costs, tracked from 1 October 2025. Grant funding does not count towards the cost cap: GOV.UK states that where third-party funding covers the full cost of reaching the minimum, the cap does not apply.
Why this matters: Earlier proposals had the cap set higher. The reduction to £10,000 was a government concession following consultation responses that highlighted unaffordable upgrade costs, particularly in regions where solid wall properties dominate.
What it means for you: If the proposal becomes law and your upgrade costs genuinely exceed £10,000 while the property still can't reach EPC C, you would register a cost cap exemption and continue letting legally. Today the equivalent route is a high-cost exemption against band E after £3,500 of qualifying spend. Understanding what counts toward the proposed £10,000 cost cap is worth doing early, as the rules are more detailed than most landlords realise.
Change 3, The Home Energy Model (HEM) as the New Assessment Tool
What the response proposed: The Home Energy Model (HEM) will replace the existing SAP/RdSAP methodology for producing domestic EPCs. The government launched a separate consultation on HEM metrics on the same day, 21 January 2026.
Why this matters: HEM changes how an EPC rating is calculated, not just the threshold. Properties that currently hold an EPC C under RdSAP may not automatically achieve C under HEM, particularly those relying on a gas boiler for heating. HEM gives greater weight to decarbonised heating (heat pumps, solar).
What it means for you: The Home Energy Model delay to H2 2027 (announced March 2026) means you have more time, but the underlying methodological shift is still coming. Properties with gas heating will likely need to take action before 2030.
Change 4, HMOs: Whole-House EPC Now Required
What the response proposed: When a single room in a House in Multiple Occupation (HMO) is let, the landlord would have to obtain a whole-property EPC, not just a room-level assessment. A 24-month transitional period will apply.
Why this matters: Many HMO landlords currently believe they don't need an EPC. This change removes that ambiguity and brings HMOs fully into the MEES framework on the same basis as single-let properties.
What it means for you: If you operate an HMO, see our dedicated guide on the HMO EPC requirements for the full compliance timeline and what to do now.
Change 5, Short-Term Lets: EPCs Required Regardless of Who Pays Bills
What the response proposed: For short-term rental properties (Airbnb, holiday lets), an EPC would be required regardless of whether the landlord or the guest/tenant pays the energy bills, closing the route that allowed short-term lets to avoid EPC requirements by structuring the tenancy to include energy costs.
Why this matters: A significant cohort of short-term let operators had structured arrangements to avoid EPC obligations. This change makes clear the EPC requirement is triggered by the letting of the property, not the billing arrangement.
What it means for you: Short-term let landlords still benefit from a short-term let MEES exemption, they don't have to hit EPC C by 2030. But they do now need a valid EPC (currently minimum E).
Change 6, Heritage/Listed Building Exemption Removed
What the response proposed: The exemption under Regulation 5(1)(a), which applies to listed and officially protected heritage properties only where meeting minimum energy performance requirements would unacceptably alter their character or appearance, would be removed. These properties would be required to produce a valid EPC when marketed, sold, or let.
Why this matters: Countless landlords of listed buildings have operated under the (incorrect) assumption that their property was completely EPC-exempt. This change closes the grey area definitively.
What it means for you: The MEES third-party consent exemption still exists for situations where listed building consent for specific improvements cannot be obtained. Full breakdown in our listed building EPC exemption guide.
Change 7, EPC Required Before Marketing, Not Just at Transaction
What the response proposed: Landlords would have to obtain a valid EPC before a property is marketed for let or sale, not simply have one available at the point of transaction. This would close a procedural gap where some landlords were listing properties without a current EPC.
Why this matters: The practical impact is that an EPC must be in place before a Rightmove or Zoopla listing goes live. With the 2030 deadline approaching, this creates pressure to get EPC assessments done earlier in the process.
What it means for you: If you're planning a relet in 2026 or later, get the EPC sorted before your current tenant leaves, not after you've started advertising.
What This All Means for Landlords
The January 2026 response doesn't require any immediate action beyond ensuring you have a valid EPC on your current let. But it sets the framework for everything between now and 2030. Here's the practical summary:
| Change | Status | Immediate action | Proposed date |
|---|---|---|---|
| October 2030 single deadline | Proposed, not law | Start planning upgrade works | Oct 1 2030 |
| £10,000 cost cap | Proposed, not law (£3,500 in force) | Keep records of improvement spend from Oct 2025 | Oct 1 2030 |
| HEM methodology | Proposed | Note: current EPC C may not transfer under HEM | H2 2027 (HEM launch) |
| HMO EPC requirement | Proposed | Get a whole-house EPC if you don't have one | 24-month transitional |
| Short-term let EPC | Proposed | Get EPC if you don't have one (min. E) | On implementation |
| Listed building exemption | Proposed | Obtain EPC at next transaction | On marketing/letting |
| Pre-marketing EPC | Proposed | Get EPC before advertising | On implementation |
The final response, covering EPC renewal timing, valid EPC throughout tenancy, and other outstanding questions, is expected later in 2026. Check back when that lands, as it may introduce additional requirements.
FAQ
Is the October 2030 deadline legally confirmed?
No. The partial response states the government's intention. Legislation still needs to be passed: an Act of Parliament to take the powers, then a statutory instrument amending the 2015 Regulations, targeted to come into force during 2027. No instrument has been laid. This is not a hypothetical risk, an almost identical EPC C proposal was dropped in September 2023 without needing any repeal, precisely because it had never become law. Planning for October 2030 is sensible; describing it as a legal requirement today is not.
What happens if I can't reach EPC C within £10,000?
Under the proposal you would be eligible for a cost cap exemption, registered on the PRS Exemptions Register with evidence of your improvement spend. The route available today is the high-cost exemption against band E after £3,500 of qualifying spend, and it lasts five years. See MEES regulations guide for the full exemption process.
Was anything NOT confirmed in January 2026?
Yes, several questions were deferred to the final 2026 response: (1) whether a valid EPC must be maintained throughout a tenancy (not just at the start), (2) the timing for renewing expired EPCs on existing lets, and (3) EPC data management and quality standards. Watch for the final response.