Renters' Rights Act EPC Transition: Did Landlords Need to Reissue on 1 May 2026?
The short answer was no. When your Assured Shorthold Tenancy automatically converted into an Assured Periodic Tenancy on 1 May 2026, you did not need to reissue your EPC, re-serve your Gas Safety Certificate, or touch your tenancy deposit. The conversion is treated as one continuous tenancy, not a new one. What you did have to do was serve the official RRA Information Sheet on your existing tenants by 31 May 2026, on pain of a penalty of up to £7,000. If you missed that, deal with it now: serving late is better than not serving.
Read on for what changed, what did not, and when your EPC next becomes relevant.
What Happened on 1 May 2026
On 1 May 2026, every Assured Shorthold Tenancy in England, whether fixed-term or already periodic, automatically converted into an Assured Periodic Tenancy (APT). This is a "big bang" switch: there is no phased transition, no grace period for fixed-term tenancies to run off, and no opt-out. Unlike the scrapped Conservative Renters Reform Bill, which proposed a phased conversion, the Renters' Rights Act applies to all existing ASTs on the same date.
One important nuance: an "existing tenancy" under Section 146 of the Renters' Rights Act is defined as one signed by both parties before 1 May 2026, even if the tenancy start date falls after that date. So if you signed an AST on 15 April 2026 with a move-in date of 10 May 2026, that tenancy is still an existing tenancy, it converts to an APT on 1 May, before your tenant even moves in.
What You Do NOT Need to Do
This is the relief section. For existing tenancies, the conversion is treated as one continuous tenancy, not as the start of a new tenancy. As a result, compliance documents served during the AST remain valid under the APT.
As The Independent Landlord confirmed in March 2026: "The AST and the APT will be treated as one continuous tenancy, and there will be no need to re-serve the compliance documents (such as the Gas Safety Certificate, EICR or EPC), or to re-register the tenancy deposit."
You do not need to:
- ❌ Re-issue your Energy Performance Certificate
- ❌ Re-issue your Electrical Installation Condition Report (EICR)
- ❌ Re-issue your Gas Safety Certificate
- ❌ Re-register the tenancy deposit
- ❌ Issue a new tenancy agreement
None of these documents need to be re-served simply because the tenancy type changes. The compliance record from the original AST carries forward.
The One Thing You Had to Do by 31 May 2026
While the conversion itself did not trigger new document obligations, one mandatory action applied to all existing tenancies: serving the official RRA Information Sheet on every existing tenant by 31 May 2026.
The Information Sheet is a government-published document explaining tenants' new rights under the Renters' Rights Act. That deadline has passed. If you never served it, the obligation has not gone away, and serving it now limits the exposure.
⚠️ The penalty for failing to serve the Information Sheet is up to £7,000 per breach. Non-compliance can also result in the loss of your right to use Ground 1A (selling) and Ground 1 (occupation) under Section 8. This is not an optional courtesy, it is a legal obligation.
For full details on the deadline, what the sheet must contain, and how to serve it correctly (including the attachment vs link rule for electronic service), see our complete guide to the RRA Information Sheet for landlords.
When Does the Conversion NOT Apply? The Section 21 Exception
There was one notable exception: where a landlord served a valid Section 21 notice before 1 May 2026 and that notice had not yet expired, the affected tenancy did not automatically convert on 1 May 2026.
Those tenancies continue under the old AST framework until the Section 21 process concludes, whether the tenant vacates voluntarily or court proceedings are completed. With Section 21 abolished, no new notices can be served, so this exception applies only to a shrinking group of cases already in train. Only once the tenancy ends and a new one begins will the new APT regime apply.
If you have a Section 21 notice still working through the courts and are weighing the EPC implications, see our detailed guide on Section 21 abolition and your EPC exit strategy.
When Will You Next Need Your EPC?
Under the APT framework, your EPC next becomes relevant when you re-let the property to a new tenant after a void period. There is no new tenancy "start date" within a continuing APT, the tenancy rolls on month-to-month indefinitely.
This means:
- If your EPC expires mid-tenancy (EPCs have a 10-year validity), you do not need to renew it immediately. Renewal is only required when marketing the property to a new tenant. This is consistent with current rules and does not change under the Renters' Rights Act, see our guide on EPC expiry during a tenancy for full detail.
- MEES compliance continues throughout. The minimum EPC band E standard, in force since 1 April 2020, applies for the duration of any tenancy. The conversion does not reset or suspend your MEES obligations.
- The band C proposal is unaffected either way. Government has said it intends to require EPC band C across the private rented sector in England and Wales from 1 October 2030. That is confirmed policy and not yet law: it still needs an Act of Parliament and a statutory instrument amending the 2015 Regulations. Nothing in the Renters' Rights Act sets an EPC standard, and your tenancy continuing as an APT changes nothing on either front.
Use the Conversion as an EPC Health Check
You were never legally required to review your EPC rating on conversion day. But with the proposed 2030 date roughly four years out, it is a reasonable planning prompt. If your property sits at EPC D, E, F or G, you have a window to plan upgrades while the market for installers, grants, and funding is still accessible. Band D and E remain perfectly legal to let in the meantime.
For a structured approach, see our EPC action plan for landlords and our full guide to the proposed 2030 EPC C standard.
FAQ
Did the AST-to-APT conversion count as a new tenancy for EPC purposes?
No. The Renters' Rights Act treats the AST and the APT as one continuous tenancy. No compliance documents, including the EPC, had to be re-served on conversion. The only mandatory action was the Information Sheet by 31 May 2026.
I signed an AST in April 2026 but the tenant moved in on 10 May. Was that an "existing tenancy"?
Yes. Under Section 146 of the Renters' Rights Act, an "existing tenancy" is one signed by both parties before 1 May 2026, regardless of start date. That tenancy converted on 1 May even though the tenant had not yet moved in.
My EPC expires in 2027. Do I need to renew it now?
No. EPC renewal is only required when you re-let to a new tenant after a void period. An EPC expiring during a continuing tenancy does not need to be renewed mid-tenancy. You will need a valid EPC when the current tenancy ends and you market the property again.
I use a letting agent. Did they handle the Information Sheet obligation?
The obligation falls on the landlord, even if an agent manages the property. Some agents served it on their landlords' behalf, but you remain responsible if it was not served. Confirm with your agent in writing, and see our guide to letting agent EPC compliance responsibilities.