Overview
Two things are true at once in the private rented sector in England and Wales, and most coverage blurs them. The law today sets a minimum of EPC band E. Separately, the government's Warm Homes Plan of 21 January 2026 set out an intention to raise that minimum to band C from 1 October 2030.
The band C standard is stated policy, not law. Government has to take new powers through an Act of Parliament and then lay a statutory instrument amending the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015. The target is for that to be in force during 2027. Nothing has been laid yet. The near-identical band C proposal from the previous parliament was scrapped in September 2023 without needing a repeal, because it had never become law.
The scale of the job is not in doubt either way. The English Housing Survey puts roughly 61% of private rented homes in England below band C. Applying that share to the size of the sector gives somewhere between 2.6 and 2.9 million properties, which is our arithmetic rather than a published government count.
What is an EPC?
An Energy Performance Certificate (EPC) rates a property's energy efficiency on a scale from A (most efficient) to G (least efficient). The certificate includes a numerical score from 1 to 100, with higher scores indicating better efficiency. Each letter band corresponds to a score range:
EPCs are produced by qualified Domestic Energy Assessors and are valid for 10 years. The assessment considers factors including wall construction, insulation levels, heating system efficiency, glazing, and renewable energy installations.
Key Dates and Deadlines
The regulatory timeline has evolved significantly since MEES regulations were first introduced. Here are the dates that matter for landlords:
1 April 2018
MEES regulations came into force for new tenancies. Properties rated F or G could no longer be let.
1 April 2020
MEES extended to all existing tenancies. All private rentals must be E-rated or above.
June 2025
RdSAP 10 launched, changing how EPCs are calculated. Existing EPCs remain valid.
1 October 2030 (proposed)
The date the government has said it wants a band C minimum to start. It needs primary legislation and then a statutory instrument before it binds anyone.
MEES Regulations Explained
MEES stands for Minimum Energy Efficiency Standards. These regulations, set out in The Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, establish the minimum EPC rating required for privately rented properties.
The regulations apply to properties let under an assured tenancy, a regulated tenancy, or a domestic agricultural tenancy. This covers the vast majority of private rented sector tenancies including Assured Shorthold Tenancies (ASTs), which are the most common form of rental agreement.
In force today vs what is proposed
| Requirement | In force today | Proposed, not yet law |
|---|---|---|
| Minimum EPC rating | E | C |
| Minimum score | 39 | 69 |
| Cost cap for exemption | £3,500 | £10,000 |
| Maximum penalty | £5,000 | £30,000 |
| Exemption duration | 5 years, or 6 months for a new landlord | 10 years on three grounds, otherwise 5 |
Which Properties Are Affected?
The regulations apply to most privately rented residential properties in England and Wales. Understanding whether your property falls within scope is essential for compliance planning.
In Scope
- Properties let under Assured Shorthold Tenancies (ASTs)
- Properties let under regulated tenancies
- Domestic agricultural tenancies
- Houses in Multiple Occupation (HMOs)
- Properties that have an EPC (required by law to have one)
Out of Scope
- Listed buildings where improvements would alter character
- Properties not legally required to have an EPC
- Social housing (separate regulations apply)
- Holiday lets under 4 months per year
- Temporary buildings planned for under 2 years use
The £3,500 Cost Cap
The cost cap in force today is £3,500 including VAT. That is the maximum a landlord is required to spend on energy efficiency improvements before becoming eligible for a cost cap exemption against the band E minimum.
This is not a spending limit. It is the threshold for exemption eligibility. Landlords must first make improvements up to this value before they can claim an exemption if the property still does not reach the minimum.
Government has proposed raising the cap to £10,000 per property alongside the band C standard, with qualifying spend counted from 1 October 2025. Government must first take new powers through an Act of Parliament, then lay a statutory instrument amending the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015. The target is for the new rules to be in force during 2027. Until that happens the figure that binds you is £3,500.
Exemptions Overview
A landlord who cannot get a property to the band E minimum may be eligible for an exemption. All exemptions must be registered on the PRS Exemptions Register, a public database maintained by local authorities. There are several exemption categories:
Cost Cap Exemption
Available when spending up to £3,500 on qualifying improvements would not achieve the band E minimum. You must have spent up to the cap or demonstrate that the cheapest pathway exceeds it.
Third Party Consent Exemption
Applies when a required third party (such as a freeholder, superior landlord, or planning authority) refuses consent for necessary improvements. Written evidence of refusal is required.
Devaluation Exemption
Available if a qualified surveyor provides written opinion that the improvements would devalue the property by more than 5%. An independent valuation is required.
Wall Insulation Exemption
Specific exemption for properties where wall insulation would have a negative impact on the structure or fabric, based on expert assessment.
New Landlord Exemption
Temporary exemption of 6 months for new landlords who acquire a non-compliant property, allowing time to make improvements.
Penalties for Non-Compliance
Local authorities enforce MEES. These are the maximum penalties in force under the 2015 Regulations, and the only ones anyone can be fined under today.
| Breach Type | Maximum Penalty |
|---|---|
| letting a non-compliant property for less than 3 months | £2,000 |
| letting a non-compliant property for 3 months or more | £4,000 |
| providing false or misleading information | £1,000 |
| failing to comply with a compliance notice | £2,000 |
| Maximum total per property | £5,000 |
£5,000 is the ceiling for a single property, not a per-breach figure. The government has proposed raising it to £30,000 alongside the band C standard, and has not published a revised tier breakdown. That change is not law.
RdSAP 10 Changes
The Reduced Data Standard Assessment Procedure (RdSAP) is the methodology used to calculate EPC ratings for existing dwellings. RdSAP 10 launched in June 2025 and introduces significant changes to how properties are assessed.
Key changes include updated carbon emission factors reflecting the UK's decarbonised electricity grid, revised assumptions for heating system efficiency, and new calculations for improvement recommendations. Some properties may see their ratings change under the new methodology.
What You Should Do Now
Two jobs, in order. Make sure you are compliant with the band E minimum that binds you today, then find out what band C would cost you so the proposal holds no surprises. Nothing here requires you to spend money against a rule that does not exist yet.
Check Your Current EPC Rating
Find your current EPC on the government's EPC register. If your certificate is more than 5 years old or you have made improvements, consider getting a new assessment.
Estimate Your Upgrade Costs
Use our Upgrade Cost Calculator to get a realistic estimate of what improvements will cost for your property type.
Explore Funding Options
Check eligibility for ECO4, Warm Homes: Local Grant, and other funding sources. Some improvements may be fully funded if your tenants receive certain benefits.
Plan and Budget Improvements
Create a timeline for improvements across your portfolio. Prioritise properties closer to the C threshold or those with tenancy renewals due.
Consider Exemption Eligibility
If improvements are likely to exceed the cost cap without achieving EPC C, understand the exemption pathway and document your spending carefully.
Further Reading
Explore our detailed guides on specific aspects of EPC compliance:
EPC C 2030 Deadline Explained
Where the proposed October 2030 date stands, and what it would mean for your tenancies.
MEES Regulations Complete Guide
Comprehensive guide to Minimum Energy Efficiency Standards and their application.
Cost Cap and Exemptions
The £3,500 cap in force, the £10,000 proposed, and when you might qualify for an exemption.
RdSAP 10 Changes Explained
How the new EPC methodology affects ratings and whether you should wait to get assessed.
Warm Homes Plan Summary
Key takeaways from the January 2026 government announcement for landlords.