Two of the biggest changes to hit the private rented sector in decades are arriving together. The Renters' Rights Act 2025 took effect on 1 May 2026, abolishing fixed-term tenancies. Separately, the government has proposed raising the minimum EPC in the private rented sector to band C from 1 October 2030. If you're a landlord wondering how these two reforms interact, and whether one affects the other, this guide gives you a straight answer.
What Is the Renters' Rights Act 2025?
The Renters' Rights Act 2025 received Royal Assent and is now law. Phase 1 of the Act took effect on 1 May 2026, introducing the following key changes:
- Section 21 'no fault' evictions are abolished, landlords can no longer reclaim possession without a valid ground.
- All existing Assured Shorthold Tenancies (ASTs) automatically convert to periodic (open-ended) tenancies on 1 May 2026.
- No new fixed-term ASTs can be created after that date. All tenancies going forward are periodic from the start.
- New landlord possession grounds under Section 8 are updated to reflect the end of Section 21.
The change is fundamental. Since 2 May 2026, every residential tenancy in the private rented sector has been periodic. That's the starting point for understanding how EPC rules apply.
Does the Renters' Rights Act Change EPC Rules?
No. The Act sets no EPC standard at all. Minimum energy efficiency comes from the MEES Regulations, which require band E to let in England and Wales. The Renters' Rights Act does not amend or accelerate that.
The band C standard for 1 October 2030 was proposed in the government's response to the EPB Regulations consultation of 21 January 2026, alongside the Warm Homes Plan. It is a proposal. Government must take powers through an Act of Parliament, then lay a statutory instrument amending the 2015 Regulations, which is targeted to be in force during 2027. No such instrument has been laid, and an identical EPC C proposal was scrapped in September 2023 without any repeal, because it had never become law.
If it does become law, the proposal is for one date across new and existing tenancies alike.
Will My AST Converting to Periodic on 1 May 2026 Trigger a New EPC Requirement?
This is the question most landlords are asking, and the answer is no.
Under current MEES regulations, an EPC requirement is triggered when a property is let to a new tenant or a new tenancy agreement is created. The statutory conversion happening on 1 May 2026 is not a new letting or a new tenancy agreement, it is a legislative change to the type of your existing tenancy.
Your existing tenancy continues. Your existing tenant remains. The EPC requirement does not reset.
You do not need to arrange a new EPC or upgrade your property to EPC C simply because your AST becomes a periodic tenancy on 1 May 2026.
What Does Count as a "New Letting" Under MEES?
A new MEES obligation is triggered when:
- You let a property to a new tenant for the first time
- An existing tenancy ends and a new tenancy agreement is signed with the same or a different tenant
Rolling from an AST into a statutory periodic tenancy on 1 May 2026 does not meet either of these conditions.
What Is the Proposed EPC Deadline, and Would It Cover My Existing Tenancies?
The proposal covers all privately rented properties in England and Wales, regardless of when the tenancy started. EPCGuide's analysis of 27.6 million EPC certificates covering 19.7 million homes shows that 49.6% of all homes in England and Wales currently fall below the C threshold, and 53.3% of privately rented homes, so a substantial share of rented stock would need upgrade work.
On the government's proposals, this would mean:
| Tenancy situation | Proposed EPC C date |
|---|---|
| New tenancy starting now | 1 October 2030 (proposed) |
| Existing AST that converted to periodic on 1 May 2026 | 1 October 2030 (proposed) |
| Long-running tenancy in place since 2015 | 1 October 2030 (proposed) |
| HMO whole-house certificate | 1 October 2030 (proposed, with a 24-month HMO transitional period) |
There is no proposed "grandfathering" for older tenancies. Until the legislation exists, though, band E remains the standard you have to meet.
How Do the Act's Changes Affect HMO Landlords?
HMO landlords face a double change. Under the Renters' Rights Act, the same conversion to periodic tenancies applies to HMOs. But there's an additional EPC change on the horizon.
The government's EPB consultation response of January 2026 proposed that HMOs should hold a whole-house EPC when any single room is let. Many HMO landlords have operated without a whole-house certificate, relying on room-level assessments or assuming EPC requirements didn't apply. The change needs regulations that have not been made.
The proposed transitional period for HMO landlords to obtain a whole-house EPC is 24 months from commencement. That would give HMO operators more time than standard BTL landlords, but the direction of travel is clear.
The Private Rented Sector Database: How It Affects EPC Compliance
The Renters' Rights Act includes a new Private Rented Sector Database that all landlords must register with. While this isn't live yet, it's worth understanding what it means for EPC compliance.
The database is designed to give tenants, councils, and government visibility over rental properties and their compliance status. EPC ratings are a core piece of that data. Once the database is operational:
- Your EPC rating will be visible alongside your property registration
- Local councils will have easier tools to identify non-compliant F/G rated properties
- MEES civil penalties, capped at £5,000 in total per property, will become easier to enforce
This doesn't change your obligations, but it does make them harder to ignore.
Is There Any Update on "EPC Required Throughout the Tenancy"?
Currently, landlords must have a valid EPC when marketing a property or starting a new tenancy, but there's no requirement to maintain a valid EPC throughout an existing tenancy.
The government has been consulting on whether this should change. The January 2026 partial response said an updated position on whether EPCs should remain valid throughout a tenancy would follow in a separate MHCLG consultation response.
For now: the requirement is at letting/marketing stage. Watch this space, a change here would affect all landlords with long-running tenancies.
What Should Landlords Do Now? Checklist
Given both reforms, here is what you should be doing now:
EPC compliance:
- Check your current EPC rating, use our postcode EPC lookup tool to find it quickly
- If you're rated D, E, F or G, estimate your upgrade costs now, before costs rise
- Check which grants you qualify for to reduce upgrade costs
- If your EPC is more than 10 years old, book a reassessment, an old EPC may not reflect recent works
- If you have an HMO without a whole-house EPC, consider starting that process now (a 24-month window is proposed from commencement)
Renters' Rights Act:
- Familiarise yourself with the updated Section 8 possession grounds (Section 21 went on 1 May 2026)
- Review your tenancy agreements, fixed terms became periodic on 1 May 2026 with no action required from you
- Register for the PRS Database when it opens (details to be announced by MHCLG)
Both:
- Don't confuse the two reforms. The Renters' Rights Act sets no EPC standard. Band E is the requirement in force, and 2030 band C is a proposal to plan against.
Frequently Asked Questions
Do I need a new EPC when my AST becomes a periodic tenancy on 1 May 2026?
No. The statutory conversion of ASTs to periodic tenancies is not treated as a new letting for MEES purposes. Your existing EPC (if valid) remains in force.
Does the Renters' Rights Act bring forward an EPC C requirement?
No. The Act contains no EPC standard. A band C standard for 1 October 2030 is proposed under the MEES regime and would need its own legislation.
Will I be fined if my property is EPC D or E in 2026?
Not for being D or E. The MEES minimum is EPC E, and letting a property rated F or G without a registered exemption carries civil penalties of up to £5,000 in total per property. Properties rated D or E are compliant, though they would need to reach C if the proposed 2030 standard becomes law. See our full EPC upgrade costs breakdown to plan ahead.
How do the Renters' Rights Act and the Warm Homes Plan work together?
The Warm Homes Plan (which includes the proposed EPC C by 2030 target and a proposed £10,000 cost cap, up from £3,500 today) is the government's energy efficiency policy, and those parts still need legislation. The Renters' Rights Act is tenancy law reform, already in force. They run in parallel, with the same landlords affected by both, but they are separate instruments with separate enforcement mechanisms.
What happens to my EPC if I start a brand new tenancy now?
You'll need a valid EPC of band E or above (band C is proposed for 2030, not required yet) before marketing the property. Exactly as before. The Act doesn't change this trigger, new tenant = new EPC requirement check.
Understanding where the Renters' Rights Act ends and the EPC rules begin is key to planning your compliance without unnecessary stress or cost. The short version: 1 May 2026 changed your tenancy structure. Band E is your EPC requirement today, with band C proposed for 1 October 2030. The two regimes don't conflict.
Want to know where your properties stand today? Check your current EPC rating with our free postcode lookup or estimate what it'll cost to reach EPC C.