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Warm Homes Plan: What It Means for Landlords

The government's Warm Homes Plan, published 21 January 2026, confirms the EPC C requirement for rental properties. Here is what landlords need to know.

Written by EPCGuide Team
8 min read

Document Details

Published:21 January 2026
Publisher:Department for Energy Security and Net Zero
Full Title:Warm Homes Plan
Pages:Policy document

Overview

The Warm Homes Plan is the government's flagship policy document setting out how England will upgrade the energy efficiency of its housing stock. For landlords, it is the document that confirms the EPC C requirement for private rented properties by October 2030.

After years of consultation, delay, and uncertainty following previous government proposals that were ultimately withdrawn, this document provides the regulatory certainty landlords have been waiting for. The key requirements are now law, and the countdown to compliance has begun.

Key highlights from the Warm Homes Plan policy document

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Key Provisions for Landlords

The Warm Homes Plan contains several provisions that directly affect private landlords. Here are the key requirements:

EPC C Requirement by October 2030

All privately rented properties in England and Wales must achieve an EPC rating of C or above by 1 October 2030. This applies to both new and existing tenancies from that date.

Confirmed in legislation

£10,000 Cost Cap

Landlords are required to spend up to £10,000 (including VAT) on energy efficiency improvements. Those who cannot achieve EPC C after this spend can register for a cost cap exemption.

Increased from GBP 3,500

£30,000 Maximum Penalty

Non-compliant landlords face penalties of up to £30,000 per property. This represents a significant increase from the previous £5,000 maximum.

Significant increase

Single Deadline for All Tenancies

Unlike previous MEES implementation, both new and existing tenancies must comply from the same date. There is no grace period for existing tenancies.

Change from previous approach

Funding Provisions

The Warm Homes Plan includes several funding mechanisms to help achieve its energy efficiency goals. While most funding is targeted at owner-occupiers and social housing, landlords may benefit in certain circumstances.

ECO4 Scheme

The Energy Company Obligation (ECO4) provides funding for energy efficiency improvements in properties where the tenant receives certain means-tested benefits. Landlords can access this funding to improve rental properties.

  • Available for properties with EPC D, E, F, or G
  • Tenant must receive qualifying benefits
  • Can cover insulation, heating, and more

Warm Homes: Local Grant

Local authority-administered grants for home energy improvements. Eligibility varies by location and is primarily targeted at owner-occupiers, but some councils include private landlords in their schemes.

  • Administered by local councils
  • Eligibility varies by area
  • Check your local council for details

Boiler Upgrade Scheme

Grants of up to £7,500 towards heat pump installation. Available to landlords for rental properties, providing a significant contribution towards the cost of switching from gas or oil to a heat pump.

  • £7,500 for air source heat pump
  • £7,500 for ground source heat pump
  • Property must not be on gas grid (for some schemes)

Great British Insulation Scheme

Targeted support for insulation improvements in less energy-efficient homes. Includes provisions for both owner-occupiers and private rented sector properties.

  • Targets properties rated D-G
  • Cavity wall and loft insulation focus
  • Some schemes include PRS properties

What Is Confirmed

The Warm Homes Plan provides clarity on several issues that had been uncertain following previous consultations. Here is what we now know for certain:

Confirmed Provisions

  • EPC C requirement:Minimum rating of C (score 69 or above) required by 1 October 2030.
  • Cost cap of £10,000:Including VAT, for exemption eligibility.
  • Maximum penalty of £30,000:Per property for non-compliance.
  • Single deadline for all tenancies:Both new and existing tenancies must comply from 1 October 2030.
  • Exemption categories maintained:Cost cap, consent, devaluation, and wall insulation exemptions continue.
  • Five-year exemption duration:Exemptions remain valid for 5 years from registration.
  • Public exemptions register:Non-compliance and exemptions publicly recorded.

What Remains Uncertain

While the Warm Homes Plan provides significant clarity, some questions remain open or subject to further guidance. Landlords should be aware of these uncertainties:

Areas of Uncertainty

  • Enforcement approach:How actively local authorities will enforce remains to be seen. Resources and priorities vary by council.
  • Future cost cap changes:The cost cap may be reviewed in future. What applies when your exemption expires in 5 years is not guaranteed.
  • EPC methodology future changes:RdSAP 10 is current, but methodology continues to evolve. Future changes could affect ratings.
  • Specific local funding availability:Local grant schemes vary and change. What is available in your area today may differ tomorrow.
  • Interaction with other regulations:How MEES interacts with Renters' Rights reforms and other tenancy changes may create additional complexity.

Impact on Landlords

The Warm Homes Plan has significant implications for landlords across England and Wales. Understanding these impacts helps you plan effectively.

Financial Planning Required

With the cost cap set at £10,000, landlords need to budget for significant investment. For properties requiring substantial work, costs may exceed this even before achieving EPC C. Factor improvement costs into your financial planning now.

Timeline Certainty

The October 2030 deadline is now confirmed. This provides certainty for planning improvements. With approximately four years remaining, landlords can create realistic timelines for upgrading their portfolios.

Portfolio Decisions

Some landlords may need to make strategic decisions about their portfolios. Properties that cannot be economically improved to EPC C may need to be sold or converted to alternative uses. The clarity provided by this plan enables informed decision-making.

Increased Compliance Risk

The higher penalties (£30,000 maximum) and public listing of non-compliant landlords increase the risk of non-compliance. The reputational impact of public listing may affect future letting and sales.

Next Steps for Landlords

With the Warm Homes Plan now published, here is what landlords should do:

1

Review Your Portfolio

Check current EPC ratings for all properties. Identify which are below C and will need improvement. Note EPC expiry dates.

2

Estimate Improvement Costs

For each property below C, estimate what improvements will be needed and their cost. Use our calculator and property guides for guidance.

3

Explore Funding Options

Check ECO4 eligibility (tenant benefits), Boiler Upgrade Scheme, and local council schemes. Factor any available funding into your budget.

4

Create a Compliance Timeline

Plan when to make improvements for each property. Consider tenancy cycles, tax year planning, and contractor availability. Avoid leaving everything until 2029-2030.

5

Make Strategic Decisions

For properties where compliance is uneconomic, consider whether to sell, convert to alternative use, or invest in major renovation. The clarity from this plan enables informed choices.

Start Planning Your Compliance

Use our tools and guides to understand what the Warm Homes Plan means for your specific properties and create your compliance action plan.

Related Guides

Regulations8 min read

EPC C 2030 Deadline

Full details on the October 2030 deadline and what it means for your properties.

Regulations10 min read

Cost Cap and Exemptions

Detailed guide to the GBP 10,000 cost cap and exemption categories.

Sources