The Renters' Rights Act 2025 does not rewrite EPC law, but it rewires the enforcement system around it. Since 1 May 2026, Section 21 has been abolished, all tenancies are periodic, and a national landlord database will make EPC non-compliance visible to tenants, councils, and lenders. The separate proposal to raise the minimum EPC to band C by 2030 sits in different legislation and is not yet law, but the Act has already removed most of the workarounds landlords previously used to manage non-compliant properties. According to EPCGuide's analysis of 27.6 million EPC certificates covering 19.7 million homes, 49.6% of homes in England and Wales currently fall below band C. For landlords in the private rented sector, the regulatory net just tightened from both sides at once.
This guide explains exactly how the Renters' Rights Act 2025 changes EPC requirements, what has already taken effect, and what landlords should be doing right now.
What does the Renters' Rights Act 2025 actually change for EPC?
The Renters' Rights Act 2025 (RRA) received Royal Assent in 2025. Phase 1 took effect on 1 May 2026. It is tenancy reform legislation, not energy efficiency legislation, and it sets no EPC standard at all. The minimum EPC standard comes from the MEES Regulations, which require band E today. A band C standard for 2030 was proposed in the government's response of 21 January 2026, and remains a proposal until an Act of Parliament and a statutory instrument amending the 2015 Regulations are in place.
But the Act changes the context in which EPC rules operate. Here is the distinction:
| What the RRA changes | What remains unchanged |
|---|---|
| Section 21 abolished (no more no-fault evictions) | The proposed EPC C standard for 1 October 2030, which is not RRA law and not yet law at all |
| All ASTs convert to periodic tenancies | MEES minimum rating (band E in force; band C proposed) |
| New Private Rented Sector Database (EPC is a required field) | EPC must be provided at marketing and letting |
| Decent Homes Standard extended to PRS | Exemption system (cost cap, consent, etc.) |
| Awaab's Law extended to private landlords | 10-year EPC validity |
| Tenant can apply to tribunal over EPC failures | Local authority enforcement powers |
The two regimes are separate instruments with separate enforcement. But for landlords managing rental properties, they converge on the same practical question: is your EPC compliant, and can you prove it?
How does Section 21 abolition affect EPC compliance?
Section 21 was abolished on 1 May 2026. From that date, no landlord in England can serve a no-fault eviction notice. All possession must be sought through Section 8 grounds.
This matters for EPC because Section 21 quietly served three functions beyond tenancy termination:
1. Exit route for non-compliant properties. Landlords with F or G-rated properties could serve Section 21 to end the tenancy, then either sell or upgrade during the void period. That route is closed.
2. Vacant possession for major works. Some EPC improvements, particularly external wall insulation, whole-house retrofit, or scaffold-intensive loft conversions, are impractical with a sitting tenant. Section 21 was how landlords obtained the empty property they needed. From 1 May, there is no general-purpose possession ground for EPC improvement works.
3. Backstop for the tenant consent exemption. Under MEES Regulation 31(1), if a tenant refuses access for EPC improvement works, the landlord can register a consent exemption. Previously, Section 21 was the eventual escape: wait for the tenancy to end, upgrade in the void. That backstop no longer exists. The consent exemption becomes indefinite for as long as the refusing tenant remains.
The practical impact is significant. For a full analysis of how Section 21 abolition interacts with EPC strategy, see our Section 21 abolition and EPC guide.
Is there a Section 8 ground for EPC works?
No. The Renters' Rights Act updated and expanded Section 8 possession grounds, but created no ground specifically for EPC compliance works.
Ground 6 (substantial works or reconstruction) covers major structural projects, not routine EPC improvements. Fitting loft insulation, upgrading a boiler, or installing cavity wall fill does not constitute "substantial reconstruction." Courts can award compensation to tenants where possession grounds are wrongly relied upon.
Ground 1A (landlord intends to sell) is a new mandatory ground, but it requires a genuine intention to sell. Using it to obtain vacant possession for upgrade works would be an abuse of the ground and exposes landlords to civil penalties.
The NRLA raised this gap during the Bill's passage through Parliament. It was not addressed in the final legislation.
What is the Private Rented Sector Database and why does EPC matter?
The Renters' Rights Act creates a new Private Rented Sector (PRS) Database, expected to launch in late 2026 as part of Phase 2 implementation. Once live, every landlord in England must register themselves and each rental property before they can legally let it.
A valid EPC is one of the mandatory compliance documents landlords must provide at registration. The database will display:
- Your EPC rating alongside property details
- Whether your EPC is current or expired
- Your compliance history, visible to tenants and councils
Every rental property will receive a Unique Property Reference Number (UPRN) that links all compliance records. From launch, rental adverts must display this UPRN, allowing prospective tenants and enforcement officers to cross-reference EPC status instantly.
This is the mechanism that turns EPC non-compliance from a paper risk into a visible, searchable, enforceable one. Local councils will no longer need a complaint or a dispute to identify properties with expired or sub-standard EPCs. The database does it automatically.
For the full breakdown of registration requirements and preparation steps, see our PRS Database landlord guide.
What are the EPC requirements landlords must meet now?
Three separate EPC obligations apply to private landlords in England and Wales. The Renters' Rights Act does not change these requirements, but it strengthens the enforcement machinery behind them.
1. Serve the EPC to tenants
Landlords must provide a copy of the property's EPC to tenants before a tenancy begins. This requirement sits alongside the gas safety certificate and the Electrical Installation Condition Report (EICR) as one of three mandatory safety and compliance documents.
Under the Renters' Rights Act, the new Information Sheet (which must be served to all existing tenants by 31 May 2026) directs tenants to check their landlord's compliance documents, including the EPC. Tenants are now better informed about what they should have received and what it should show.
Failure to provide a valid EPC to a tenant was previously a barrier to serving a valid Section 21 notice. With Section 21 abolished, the enforcement mechanism shifts: tenants can now apply directly to the First-tier Tribunal if EPC requirements have not been met, and councils have broader investigatory powers to audit compliance proactively.
2. Minimum EPC E (current MEES requirement)
All privately rented properties in England and Wales must hold a minimum EPC rating of band E. This has applied to all tenancies (new and existing) since 1 April 2020. Bands D and E are legal to let. Letting a property rated F or G without a registered exemption is the breach, and MEES civil penalties are capped at £5,000 in total per property across all breaches combined.
3. The proposed EPC C standard for 1 October 2030
The proposed EPC C standard would require privately rented homes to achieve band C (SAP score of 69 or above) from 1 October 2030, with the maximum penalty proposed to rise to £30,000. Neither the standard nor the higher penalty is law: the government must take powers through an Act of Parliament and then lay a statutory instrument, targeted to be in force during 2027. An identical EPC C proposal was dropped in September 2023 without any repeal being needed, because it had never become law.
How does the Decent Homes Standard affect EPC?
The Renters' Rights Act extends the Decent Homes Standard (DHS) to the private rented sector for the first time, with enforcement indicated for 2035 and the detail still to come in secondary legislation. The DHS has five criteria. Two are directly relevant to EPC.
Criterion D: Thermal comfort and energy efficiency. Properties must have a whole-home programmable heating system and meet a thermal performance standard. A property well short of band C is likely to struggle with Criterion D as well. The improvements needed to reach band C, such as insulation, heating upgrades, and draught-proofing, are the same improvements that satisfy Criterion D.
Criterion E: Damp and mould. Damp and mould are now a standalone DHS requirement. Poorly insulated properties generate condensation that leads to damp. Upgrading insulation, the primary route to better EPC ratings for solid-wall and older properties, directly addresses the root causes of condensation damp.
The practical consequence: landlords who upgrade to EPC C by 2030 will be most of the way toward DHS compliance by 2035. Landlords who delay both face overlapping remediation costs.
For the full DHS breakdown, see our Decent Homes Standard landlord guide.
What does Awaab's Law mean for landlords and EPC?
Awaab's Law, named after Awaab Ishak who died in 2020 from exposure to mould in social housing, requires landlords to investigate hazards such as damp and mould within 14 days and begin repairs within a further 7 days. Originally enacted for social landlords under the Social Housing Regulation Act 2023, it is being extended to the private rented sector under the Renters' Rights Act framework.
The EPC connection is structural. Properties with poor energy efficiency ratings, particularly those with inadequate insulation, single glazing, or insufficient heating, are far more likely to develop the condensation and damp conditions that trigger Awaab's Law obligations. EPCGuide's data shows that properties rated E, F, or G are disproportionately concentrated in older housing stock where cold bridging and moisture problems are endemic.
Landlords who improve their EPC rating address both compliance obligations simultaneously. Insulation reduces condensation. Better heating reduces cold surfaces where moisture collects. A property that reaches band C is structurally less likely to generate the damp and mould conditions that Awaab's Law targets.
How does the HMO whole-house EPC rule change things?
The January 2026 consultation response proposed that HMOs should require a whole-house EPC when any single room is let. HMO landlords letting individual rooms have historically had no EPC obligation and no MEES requirement, and the government proposes to close that gap. It requires new regulations, which have not been made.
Under the Renters' Rights Act, every individual tenancy within an HMO is subject to the new periodic tenancy regime. Combined with the proposed whole-house EPC rule, HMO landlords are looking at:
- A whole-house EPC obligation, with a proposed 24-month transitional period from commencement
- The proposed band C standard applying to the entire building, not individual rooms
- No Section 21 to manage tenant turnover for improvement works
- The PRS Database registration requirement for each tenancy
A transitional period would give HMO landlords more time than standard BTL landlords to obtain their first EPC, but the proposed 2030 date would not move with it. A landlord who waits until the last moment to get their EPC may find they have very little time to plan and fund the upgrades needed to reach band C.
For detailed HMO guidance, see our HMO EPC requirements guide and Renters' Rights Act HMO guide.
What does EPCGuide's data show about rental property compliance?
EPCGuide maintains the UK's largest independent analysis of the domestic EPC register: 27.6 million certificates covering 19.7 million assessed homes in England and Wales. The data reveals the scale of the challenge facing landlords under the combined RRA and MEES framework.
National picture
- 49.6% of all assessed homes are rated below band C
- That translates to approximately 9.8 million homes needing improvement
- The average SAP score across all properties is 63, six points below the band C threshold of 69
- Band D is the most common rating, at 37.8% of all assessed properties
Property type breakdown
| Property type | Average SAP score | % below band C |
|---|---|---|
| Purpose-built flat | 70 | 39.1% |
| Converted flat | 60 | 62.4% |
| Mid-terrace house | 63 | 54.7% |
| Semi-detached house | 61 | 59.2% |
| End-terrace house | 60 | 61.8% |
| Detached house | 56 | 71.3% |
Landlords with detached houses and converted flats face the steepest climb. Purpose-built flats often already sit at or near band C.
Regional variation
EPCGuide's interactive local authority map shows stark differences. In some local authority areas, over 70% of properties fall below band C. Former industrial towns, coastal areas, and regions with older housing stock are worst affected. The landlords most exposed to the combined RRA and MEES pressure are concentrated in exactly these areas.
For a personalised estimate based on your property type and current rating, use the EPCGuide cost calculator.
Timeline: what has changed and what is coming
| Date | What happened or happens |
|---|---|
| Late 2025 | New local authority investigatory powers active (RRA early provisions) |
| 21 January 2026 | Government proposes EPC C by 2030, a £10,000 cost cap and a £30,000 maximum penalty in its consultation response. None of it is law |
| 1 May 2026 | Section 21 abolished. All ASTs convert to periodic tenancies. New Section 8 grounds in force. |
| 31 May 2026 | Deadline to serve RRA Information Sheet to all existing tenants (£7,000 fine per property for non-compliance) |
| 31 July 2026 | Pre-1 May S21 notices not yet in court proceedings become invalid |
| Late 2026 | PRS Database launches (Phase 2). Landlord registration required with valid EPC. |
| 2027 | Decent Homes Standard secondary legislation expected. Legislation for the proposed EPC C standard targeted for this year. HMO whole-house EPC rule expected. |
| 2029 | Home Energy Model proposed to replace RdSAP for EPC assessments |
| 1 October 2030 | Proposed start of the EPC C standard, with penalties proposed at up to £30,000. Requires legislation first. |
| 2035 | Decent Homes Standard enforcement for private landlords (indicated) |
What should landlords do now? A practical checklist
The regulatory picture is clear. Here is what to do, in priority order.
1. Check your current EPC rating and expiry date
Look up every rental property on the government's EPC register or use the EPCGuide EPC predictor tool. If your EPC is more than 10 years old, it has expired and you are currently in breach if you are letting the property.
2. Confirm you have served mandatory documents
From 1 May 2026, you must have provided every tenant with:
- A valid EPC
- A gas safety certificate
- An Electrical Installation Condition Report (EICR)
- The official MHCLG Information Sheet (by 31 May 2026)
Missing any one of these creates enforcement risk under the new regime.
3. Assess your path to EPC C
If your property is currently rated D, E, F, or G, you need a plan. Use the EPCGuide cost calculator to estimate upgrade costs based on your property type and current rating. Common improvements that shift ratings toward band C include loft insulation top-up, cavity wall insulation, boiler upgrades, and smart heating controls. Our complete guide to EPC improvement costs breaks down every measure by price, and our cheapest ways to improve your EPC rating ranks them by cost per SAP point.
4. Claim available grants before they close
The ECO4 scheme ends 31 December 2026 with no confirmed replacement. If your tenants are on qualifying benefits, you could get insulation and heating upgrades at no cost. The Boiler Upgrade Scheme offers £7,500 toward heat pump installation. These funding windows are finite. For the full picture on every available scheme, see our complete guide to EPC grants for landlords.
5. Resolve tenant consent issues now
If your tenant is likely to refuse access for improvement works, address it while you still have options. The tenant consent exemption under MEES still applies, but without Section 21, it becomes a long-term position rather than a temporary bridge. Negotiate access and scheduling with your tenant. Document everything. If consent is genuinely refused, register the exemption on the PRS Exemptions Register.
6. Prepare for the PRS Database
When the database launches in late 2026, you will need to register every rental property with a valid EPC. Properties with expired or missing EPCs will not be registrable. Start getting your documentation in order now.
7. Budget for the combined regulatory cost
The proposed 2030 band C standard, the Decent Homes Standard, and the MEES requirements already in force all point toward the same investment: insulation, heating, and building fabric. The cost cap today is £3,500 including VAT. The government has proposed a £10,000 cap counting qualifying expenditure from 1 October 2025, so keep receipts from that date in case it is enacted. Note too that third-party funding such as grants does not count towards the cap: GOV.UK is explicit that if you secure funding covering the full cost of reaching the standard, the cap does not apply.
Frequently asked questions
Does the Renters' Rights Act set an EPC C requirement?
No. The Act is tenancy legislation and sets no EPC standard. The minimum standard comes from the MEES Regulations, currently band E. The band C standard for 1 October 2030 was proposed in the government's response of 21 January 2026 and still needs legislation, so it is not yet a legal deadline.
Did the AST-to-periodic conversion on 1 May 2026 trigger a new EPC requirement?
No. The statutory conversion of Assured Shorthold Tenancies to periodic tenancies was not treated as a new letting for MEES purposes. Your existing EPC (if valid) remained in force. No new EPC assessment was required on that date.
Can I still use Section 21 to gain vacant possession for EPC works?
No. Section 21 was abolished on 1 May 2026. There is no Section 8 ground specifically for EPC improvement works. Ground 6 (substantial works) covers major structural projects, not routine EPC improvements. Ground 1A (intention to sell) requires a genuine sale intention.
What happens if my tenant refuses access for EPC improvement works?
You can register a tenant consent exemption under MEES Regulation 31(1). This exemption protects you from enforcement while it is valid. However, it expires automatically when that tenant leaves, and without Section 21, you cannot use eviction to resolve the impasse. The exemption is now a long-term holding position, not a temporary bridge.
Would HMO landlords need a whole-house EPC under the proposed rules?
That is the government's proposal. The January 2026 consultation response proposed that HMOs need a whole-house EPC when any room is let, with a 24-month transitional period from commencement. It requires regulations that have not been made, so there is no whole-house EPC duty for room-only lettings today.
Will my EPC rating be visible on the PRS Database?
Yes. The PRS Database, launching in late 2026, will include your EPC rating as a mandatory field. Prospective tenants, local councils, and enforcement officers will be able to see your EPC status by searching your property's Unique Property Reference Number (UPRN).
How does Awaab's Law affect EPC compliance?
Awaab's Law requires landlords to investigate damp and mould within 14 days and begin repairs within a further 7 days. Properties with poor energy efficiency are more likely to generate the condensation conditions that trigger these obligations. Improving your EPC rating, particularly through better insulation and heating, reduces the underlying risk.
What fines do I face for EPC non-compliance?
MEES civil penalties are capped at £5,000 in total per property, across all breaches combined, for letting an F or G rated property without a registered exemption. The government has proposed raising the maximum to £30,000 alongside the band C standard, but that is not law and no landlord faces a £30,000 MEES penalty today. The PRS Database and new council investigatory powers do make detection significantly more likely than under the old system.
This article was last updated on 19 August 2026. EPCGuide's analysis covers the full domestic EPC register for England and Wales, 27.6 million certificates covering 19.7 million homes. For methodology and interactive data, visit the EPCGuide Research Hub.
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