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. 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. The seven changes below are what was confirmed.
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). Over 5,000 responses were received.
The January 21 2026 partial response represented the government's first formal set of confirmed policy decisions. It is the most important EPC policy document since the 2015 MEES regulations.
Here are the seven decisions landlords need to understand.
Change 1 — A Single October 2030 Deadline for All Tenancies
What was confirmed: All private rented properties in England and Wales must meet EPC C (or register an exemption) by October 1, 2030. This applies to both new tenancy agreements and existing tenancies with sitting tenants.
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, but the clock is now fixed at October 2030.
Change 2 — The £10,000 Cost Cap Confirmed
What was confirmed: The maximum landlords must spend on qualifying energy improvements before becoming eligible for the high-cost exemption is £10,000 per property. Spend that counts includes assessments, improvement works, and associated installation costs — tracked from 1 October 2025.
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 your upgrade costs genuinely exceed £10,000 and the property still can't reach EPC C, you can register a cost cap exemption and continue letting legally. Understanding what counts toward the £10,000 cost cap is critical — the rules are more detailed than most landlords realise.
Change 3 — The Home Energy Model (HEM) as the New Assessment Tool
What was confirmed: 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 was confirmed: When a single room in a House in Multiple Occupation (HMO) is let, the landlord must 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 whole-house requirement for the full compliance timeline and what to do now.
Change 5 — Short-Term Lets: EPCs Required Regardless of Who Pays Bills
What was confirmed: For short-term rental properties (Airbnb, holiday lets), an EPC will be required regardless of whether the landlord or the guest/tenant pays the energy bills. The current exemption that allowed short-term lets to avoid EPC requirements by structuring the tenancy to include energy costs was closed.
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 was confirmed: The current exemption under Regulation 5(1)(a) that allows listed buildings and officially protected heritage properties to avoid EPC requirements is being removed. These properties will 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 was confirmed: Landlords must obtain a valid EPC before a property is marketed for let or sale — not simply have one available at the point of transaction. This closes 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 | Immediate action | Deadline | |--------|-----------------|----------| | October 2030 single deadline | Start planning upgrade works | Oct 1 2030 | | £10,000 cost cap | Track improvement spend from Oct 2025 | Oct 1 2030 | | HEM methodology | Note: current EPC C may not transfer under HEM | H2 2027 (HEM launch) | | HMO EPC requirement | Get a whole-house EPC if you don't have one | 24-month transitional | | Short-term let EPC | Get EPC if you don't have one (min. E) | Immediate | | Listed building exemption | Obtain EPC at next transaction | On marketing/letting | | Pre-marketing EPC | Get EPC before advertising | Immediate |
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?
The partial response confirms the government's intention. Legislation still needs to be passed. However, given the strength of the policy signal — confirmed by the NRLA and backed by the consultation response — landlords should treat October 2030 as the working deadline. Waiting for final legislation before starting work would be a significant risk.
What happens if I can't reach EPC C within £10,000?
You may be eligible for the cost cap exemption — register on the PRS Exemptions Register with evidence of your improvement spend. 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.