Frequently Asked Questions
Answers on EPC requirements, costs and exemptions for landlords in England and Wales. What the law requires today, and what is only proposed for 2030.
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General Requirements
Understanding the basic EPC requirements for rental properties
Band E, a score of 39 or above. That has been the legal minimum in England and Wales since 1 April 2020 and it has not changed. Band D is legal to let. Only F and G are barred, and then only where no exemption is registered.
The government has proposed raising the minimum to band C (a score of 69 or above) from 1 October 2030. That is a proposal, not law. It needs an Act of Parliament to take the powers and then a statutory instrument amending the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015. Neither has happened.
So if your property is D or E you are compliant today and under no obligation to spend anything. It is still worth knowing what reaching C would cost, because the proposal may well be legislated.
No. On 21 January 2026 the government published its response alongside the Warm Homes Plan, setting out an intention to require band C from 1 October 2030 for all tenancies, new and existing. An announcement is not a rule.
To bind anyone, government has to take new powers through an Act of Parliament and then lay a statutory instrument amending the 2015 Regulations. It has said it is targeting that being in force during 2027. Nothing has been laid yet.
This has happened before. A near-identical band C proposal from the previous parliament was dropped in September 2023, and no repeal was needed because it had never become law.
Dates that are real: - June 2025: RdSAP 10, the current EPC assessment methodology, launched - 1 April 2020: the band E minimum took effect for all tenancies, and still applies
MEES applies to domestic private rented properties in England and Wales that are required to have an EPC. This includes houses, flats and HMOs let on assured shorthold tenancies. It does not apply in Scotland or Northern Ireland, which run their own rules, and neither the cost cap nor the PRS Exemptions Register exists there.
Some properties do not need an EPC at all: - Listed buildings where compliance would unacceptably alter their character - Properties let for less than 4 months per year and not let at other times - Buildings that will be demolished - Some holiday lets and temporary structures
If your property needs an EPC to be let, it needs band E or a registered exemption today. If the band C proposal becomes law, the same scope would apply at the higher band.
A local authority can issue a civil penalty of up to £5,000 in total per property for breaching MEES. That is a ceiling on the total for one property, not a figure per breach, and it is made up of fixed tiers: £2,000 for letting a non-compliant property for less than 3 months, £4,000 for 3 months or more, £1,000 for providing false or misleading information, and £2,000 for failing to comply with a compliance notice.
This applies to letting below band E without a registered exemption. There is no penalty attached to band C, because band C is not a requirement.
The government has proposed raising the maximum to £30,000 per property alongside the band C standard. It has not published a revised tier breakdown, and the change is not law.
Details of a penalty can also be published on the PRS Exemptions Register for at least 12 months.
Not unless it is below band E. The band E minimum applies to existing tenancies as well as new ones, so an F or G property with a sitting tenant is already in breach and needs fixing now. A D or E property needs nothing.
If the band C proposal is legislated as announced, it would use a single date for all tenancies rather than the phasing used in 2018 and 2020, so a sitting tenant would not buy you extra time then either.
Reasons to look at the work early anyway, none of them legal ones: - Improvements are cheapest to fit between tenancies - Grant funding exists now and may not later - Costs can be spread across tax years - Your tenant's bills drop from the day the work is done
Thirty points on the EPC scale, which is a large gap. A property at the bottom of band E scores 39. Band C starts at 69.
That gap is why the proposal pairs the higher band with a higher cost cap: £10,000 proposed against the £3,500 in force. Neither figure obliges you to spend towards band C today.
The EPC rating bands are: - A: 92-100 (most efficient) - B: 81-91 - C: 69-80 (the proposed minimum) - D: 55-68 (legal to let) - E: 39-54 (the minimum in force) - F: 21-38 (cannot be let without a registered exemption) - G: 1-20 (cannot be let without a registered exemption)
Costs and Funding
Information about upgrade costs, grants, and financial support
These are typical ranges for getting a property to band C, which is the proposed standard rather than a current duty. If your property is already D or E it is compliant, so treat these as planning numbers.
1970s-1990s houses (cavity walls, some improvements already): £2,000-£5,000 - Usually need loft top-up, heating controls, draught proofing
1930s-1960s houses (mixed construction): £5,000-£15,000 - May need cavity wall insulation, new boiler, glazing improvements
Victorian/Edwardian terraces (solid walls): £15,000-£30,000+ - Solid wall insulation is the expensive part - Most of these are already compliant at D or E, so this is planning money, not compliance money
Purpose-built flats: £1,500-£8,000 - Often limited scope for improvement, may need freeholder consent
These are estimates only. Use our cost calculator for a more accurate assessment based on your specific property, or get quotes from TrustMark registered installers.
It lets you register an exemption when spending up to the cost cap still will not get the property to the minimum band. The cap in force is £3,500 including VAT, measured against band E.
How it works: 1. You spend up to £3,500 on qualifying energy efficiency improvements 2. If the property still falls below band E, you register a cost cap exemption 3. The exemption lasts 5 years, after which you reassess
You cannot claim it on an estimate. You have to actually spend up to the cap, with quotes and invoices to prove it, before the exemption is accepted.
The government has proposed a £10,000 cap measured against band C, or 10% of value for properties worth under £100,000, with qualifying spend counted from 1 October 2025. That version is not law.
Properties most likely to need it are solid-wall builds: Victorian and Edwardian terraces, and some listed buildings.
Yes, several funding schemes may help reduce your costs:
ECO4 (Energy Company Obligation) Available if your tenant receives certain means-tested benefits. Can cover insulation, heating improvements, and more. Contact energy suppliers directly to check eligibility.
Boiler Upgrade Scheme (BUS) Provides £7,500 towards air source heat pumps or £5,000 towards ground source heat pumps. Available for properties in England and Wales. The property must have an EPC and the installer must be MCS certified.
Warm Homes: Local Grant Contact your local council for information about local schemes. Many areas have specific funding for landlords, particularly for properties with low-income tenants.
Great British Insulation Scheme (GBIS) Closed to new applications in January 2026 and ended on 31 March 2026, so it is no longer available. It targeted homes in Council Tax bands A-D in England or A-E in Wales and Scotland, and households with income below a threshold, funding loft and cavity wall insulation.
Check eligibility for all schemes as criteria change regularly. Your local council or an energy advisor can help identify available funding.
No. Energy efficiency improvement costs cannot be passed directly to tenants or used to justify rent increases specifically for this purpose.
The Tenant Fees Act 2019 prohibits landlords from charging tenants for any costs relating to the tenancy beyond rent, deposit, and permitted payments. Energy improvements are the landlord's responsibility.
While you can increase rent in line with market rates at renewal, you cannot add a surcharge specifically for EPC improvements.
However, you may benefit indirectly: - Improved properties may command higher market rents - Lower energy bills make your property more attractive to tenants - Compliance ensures you can continue letting legally - Energy-efficient homes may have higher resale value
Split the question in two, because the answers are different.
If you are below band E: do the work now. That is a live breach with a real penalty attached, and no amount of policy uncertainty changes it.
If you are at D or E: you are compliant and nothing is forcing your hand. Get the property assessed and costed so you know the number, then fold any work into something you were doing anyway, a boiler replacement, a void period, a refurb. That is how the same job costs a third of what it costs when it is done in a panic.
Reasons to move sooner rather than later: - Contractors are cheaper and more available now than in any rush - Grant funding exists today and schemes close without much notice - Costs spread across tax years - Tenants get lower bills from the day the work is done
Reasons to hold: - The band C standard is still a proposal, and one version of it was already dropped in 2023 - RdSAP 10 changed how ratings are calculated, so a fresh EPC may move your score on its own - If you are a high D, a new assessment may be worth more than a new boiler
Quick wins that offer the best value (cost per EPC point) include:
Loft insulation top-up: £400-£600 Potential improvement: 4-8 EPC points If you have less than 270mm of loft insulation, topping up to the recommended level is one of the most cost-effective improvements.
Draught proofing: £200-£400 Potential improvement: 2-4 EPC points Sealing gaps around windows, doors, and floorboards. Often overlooked but can make a noticeable difference.
LED lighting: £100-£200 Potential improvement: 1-2 EPC points Replacing all light bulbs with LEDs is a simple improvement that assessors note.
Smart heating controls: £200-£400 Potential improvement: 2-4 EPC points Programmable thermostats and TRVs (thermostatic radiator valves) improve the heating system rating.
Hot water cylinder insulation: £20-£50 Potential improvement: 1-2 EPC points If you have a hot water tank, ensure it has a proper insulation jacket.
These improvements typically cost under £1,500 combined and can gain 10-20 EPC points for the right property. However, effectiveness depends on your current situation.
Absolutely. Prices vary significantly between contractors, and getting multiple quotes helps you:
1. Understand the fair market price for the work 2. Identify any quotes that seem unusually high or low 3. Compare what is included in each quote 4. Assess the contractor's knowledge and professionalism 5. Check availability and timeline
We recommend getting at least 3 quotes for any significant work. For each quote, check: - Is the contractor TrustMark registered? - What exactly is included? - What guarantees are provided? - What is the payment schedule? - Can they provide references?
TrustMark registration is particularly important as work by registered installers may be required for some grant schemes and provides consumer protection.
Be wary of quotes that are significantly lower than others - this may indicate corners being cut or hidden costs.
Property Specific
Guidance for different property types and situations
Solid wall properties (typically pre-1930 construction) are the most challenging to improve. The main options are:
Internal wall insulation (IWI): £8,000-£14,000 - Insulation boards fitted to the inside of external walls - Reduces room sizes slightly (typically 50-100mm per wall) - Can cause condensation issues if not properly installed - May affect internal features like cornices and skirting boards - No planning permission usually needed
External wall insulation (EWI): £10,000-£20,000 - Insulation fitted to the outside of the building - Better thermal performance - Preserves internal room sizes and features - Changes the external appearance of the property - May need planning permission, especially in conservation areas - Not suitable for all properties (terraces, flats)
Solid wall properties are the most common candidates for a cost cap exemption, but that only becomes relevant if the property falls below band E, and you have to actually spend up to the £3,500 cap first. Most solid wall terraces sit at D or E and are already compliant.
Alternative strategies for solid wall properties: - Focus on other improvements first (heating, glazing, loft) - Consider hybrid approaches - Explore available grants specifically for solid wall insulation
Making changes to a flat depends on several factors:
Leasehold vs freehold: If you own the leasehold, you will likely need freeholder consent for any works that affect the structure or common areas. This includes: - Window replacements - External wall insulation - Changes to heating systems that affect communal supplies - Any works to the exterior
Common challenges: - Freeholder may refuse permission - Works may require consent from other leaseholders - Building insurance implications - Access to common areas for installation
What you can usually do without consent: - Internal improvements like insulation behind plasterboard - Upgrading heating controls within your flat - Installing LED lighting - Draught proofing internal doors and windows - Adding secondary glazing (usually does not require consent)
If the freeholder refuses consent: You may qualify for a third-party consent exemption. This requires evidence that you have requested consent and it has been unreasonably refused.
For flats in blocks, consider approaching the freeholder or management company with other leaseholders to discuss building-wide improvements.
Listed buildings and properties in conservation areas have additional restrictions, but improvements are often still possible:
Listed buildings: - Any works that affect the character of a listed building require Listed Building Consent - This includes many energy efficiency improvements - Internal works may also need consent if they affect historic features - Contact your local planning authority before starting any work
Conservation areas: - External changes visible from a public place often need planning permission - Internal works usually have fewer restrictions - Permitted development rights may be limited
Improvements that may be possible: - Secondary glazing (usually acceptable for listed buildings) - Internal wall insulation (subject to consent) - Loft insulation (if accessible without affecting structure) - Heating system improvements - Draught proofing - LED lighting
If you cannot make necessary improvements due to listed status or conservation restrictions, you may qualify for an exemption. However, you must: 1. Demonstrate that you explored all possible options 2. Show that the restrictions genuinely prevent compliance 3. Provide evidence from the planning authority
Work with a conservation architect or specialist surveyor who understands both EPC requirements and heritage restrictions.
Houses in Multiple Occupation (HMOs) are treated as single properties for MEES purposes. Key points:
One EPC for the whole property: - An HMO requires a single EPC for the entire building, not individual rooms - The minimum band applies to the property as a whole - Room-by-room EPC requirements do not exist
Practical considerations: - Improvements benefit all residents and improve the whole property rating - You may need to coordinate works around multiple tenants - Common areas (hallways, kitchens, bathrooms) are included in the assessment
HMO licensing: - HMO licensing is separate from EPC requirements - You must meet both licensing conditions and EPC standards - Local authorities may check EPC compliance as part of HMO inspections
Improvement priorities for HMOs: - Heating systems often have the biggest impact (communal heating) - Draught proofing is particularly important with multiple doors - Common area lighting and insulation - Consider how improvements affect fire safety requirements
If your HMO is in a converted building, you may face similar challenges to flats, particularly if there are shared structural elements.
Yes, very much so. The most effective improvements depend heavily on your property type:
Victorian terraces (pre-1919): - Primary challenge: Solid walls - Focus: Heating efficiency, secondary glazing, loft insulation - Often qualify for cost cap exemption - See our Victorian terrace guide
1930s semi-detached: - Primary challenge: Often have cavity walls but may be unfilled - Focus: Cavity wall insulation if suitable, loft insulation, heating - Usually achievable within budget - See our 1930s semi guide
Purpose-built flats: - Primary challenge: Limited scope, need freeholder consent - Focus: Heating controls, glazing (if possible), internal insulation - May need to pursue exemptions if consent refused - See our purpose-built flat guide
1970s-1990s properties: - Primary challenge: Often partially improved but not to modern standards - Focus: Topping up insulation, upgrading heating, glazing - Usually most straightforward to improve
Each property type has different typical starting ratings, common issues, and priority upgrades. Using the wrong approach wastes money and may not achieve the required improvement.
EPC and Assessment
Understanding EPC assessments and ratings
EPCs are valid for 10 years from the date of issue. However, there are important considerations:
When to get a new EPC: - Your current EPC expires within the next 5 years - You have made significant improvements to the property - You want to demonstrate a higher rating to tenants - You are selling or re-letting the property and want to show improvements
After making improvements: If you have upgraded your property, the existing EPC will not reflect the changes. You need a new assessment to show your improved rating. The old EPC remains technically valid but will not demonstrate compliance.
If your EPC expires: An expired EPC is a problem now, not in 2030. You cannot demonstrate compliance without a valid one. If yours is due to run out, time the new assessment for after any improvements you were going to make anyway.
RdSAP 10 consideration: The new assessment methodology (RdSAP 10) launches in June 2025. EPCs issued after this date will use the new calculations, which may give different ratings. Some properties may benefit, others may see lower ratings.
RdSAP 10 is the methodology used to assess the energy efficiency of existing dwellings. It came into use in June 2025, replacing RdSAP 9.94.
Key changes in RdSAP 10: - Updated fuel prices and carbon factors - Better recognition of heat pumps and renewable technologies - Changes to how certain building elements are assessed - More accurate modelling of heating systems - Potential changes to how solid wall and floor insulation is valued
Who might benefit: - Properties with heat pumps - Homes with renewable energy systems - Some well-insulated properties
Who might see lower ratings: - Properties with older gas boilers - Homes heavily reliant on gas heating - Properties that benefited from previous calculation quirks
Should you wait? - RdSAP 10 is already in use, so there is nothing left to wait for - If your EPC predates June 2025 and you are a high D, a fresh assessment may move your score on its own - If you are below band E: fix that now, whatever the methodology says
Compliance is measured against the rating on your valid EPC, so an older certificate showing a higher rating is not a disadvantage while it lasts.
Yes, getting an EPC assessment before planning improvements is strongly recommended for several reasons:
Identify the most effective improvements: A proper EPC assessment identifies specifically what would improve your rating. The recommendations are tailored to your property, not generic advice.
Understand your baseline: You need to know your current rating and score to plan effectively. The score (1-100) matters more than the letter grade for understanding how much improvement is needed.
Get specific cost-effectiveness data: The EPC includes estimates of improvement costs and potential savings, helping you prioritise.
Avoid wasting money: Without an assessment, you might spend money on improvements that do not significantly affect your rating. For example, replacing windows might have less impact than you expect if your heating system is the main issue.
Establish a before picture: Having a dated assessment before improvements provides evidence of what you have done, which may be useful for exemption applications or disputes.
Choose a good assessor: Look for an accredited assessor who will take time to understand your property. A rushed assessment can miss opportunities and give inaccurate recommendations.
Yes, if you believe your EPC assessment is incorrect, you have several options:
Request a review from the assessor: Contact the assessor who conducted the assessment and ask them to review their findings. Point out any specific errors you have identified, such as: - Incorrect measurements - Unrecorded improvements (e.g., insulation they did not note) - Wrong building type or age - Heating system errors
Formal complaint to the accreditation scheme: If the assessor is unresponsive or you disagree with their review, you can complain to their accreditation scheme. All assessors must be registered with an approved scheme.
Get a reassessment: You can commission a new EPC from a different assessor. If the new assessment gives a different rating, the newer certificate is valid (though both will be on the register).
Common reasons for incorrect assessments: - Assessor did not access all areas (e.g., loft) - Improvements made after the last assessment not recorded - Assumptions made instead of actual measurements - Data entry errors
If getting a reassessment, provide the new assessor with evidence of improvements (receipts, guarantees, installation certificates) to ensure everything is correctly recorded.
The EPC rating and score are related but different:
EPC Score (1-100): - A numerical value indicating energy efficiency - Higher numbers mean better efficiency - More precise measure of performance - Important for understanding how close you are to thresholds
EPC Rating (A-G): - Letter grade derived from the score - A is most efficient, G is least - What most people refer to when discussing EPCs - Used for compliance thresholds
The rating bands are: - A: 92-100 points - B: 81-91 points - C: 69-80 points (proposed minimum from October 2030) - D: 55-68 points (legal to let) - E: 39-54 points (the minimum in force) - F: 21-38 points - G: 1-20 points
Why the score matters: If your property scores 67 (D), you need to gain just 2 points to reach C. If your property scores 56 (D), you need to gain 13 points.
Both are rated D, but the improvement challenge is very different. Always check your actual score, not just the letter grade.
The EPC certificate also shows: - Current energy efficiency rating - Potential rating (what could be achieved) - Environmental impact rating - Estimated energy costs
Exemptions
Understanding exemption criteria and registration
These apply where you cannot get a property to the band E minimum:
Cost Cap Exemption: If spending up to £3,500 including VAT still leaves the property below band E. You have to spend up to the cap first, then register.
Third-Party Consent Exemption: If a third party (freeholder, planning authority, mortgage lender) refuses consent for necessary improvements.
Devaluation Exemption: If an independent surveyor determines that improvements would reduce the property value by more than 5%.
Wall Insulation Exemption: If a surveyor confirms that cavity wall or solid wall insulation is not appropriate for your property (e.g., due to damp risk).
New Landlord Exemption: If you become a landlord through inheritance or certain other circumstances, you have a 6-month grace period to comply.
Temporary Exemption during Void Periods: Properties being marketed for sale or genuinely unoccupied may qualify for temporary exemption.
All exemptions: - Must be registered on the PRS Exemptions Register before you let - Require supporting evidence - Last 5 years, except the new landlord ground, which lasts 6 months - Do not transfer to a new owner - Must be renewed if circumstances have not changed
The government has proposed extending three grounds to 10 years: the cost cap, property value adjustment, and negative impacts. Everything else would stay at 5. That change is not law.
To register an exemption, follow these steps:
1. Ensure you qualify: Make sure you meet the criteria for the exemption type you are claiming. Do not register prematurely.
2. Gather evidence: You need documentary evidence to support your exemption: - Cost cap: Quotes showing costs exceed £3,500 after reasonable improvements - Third-party consent: Written refusal from the relevant party - Devaluation: Report from a RICS surveyor - Wall insulation: Survey report explaining unsuitability - New landlord: Proof of how you acquired the property
3. Register online: Visit the PRS Exemptions Register (gov.uk) and create an account. Complete the registration form, providing: - Property details - Exemption type - Supporting evidence (uploaded documents) - Declaration that information is accurate
4. Receive confirmation: You will receive confirmation of your exemption registration. Keep this safely.
5. Display or provide when required: You may need to show your exemption registration to tenants, letting agents, or local authority enforcement officers.
Important: False or fraudulent exemption claims can result in penalties. Only register if you genuinely qualify.
Evidence requirements vary by exemption type:
Cost Cap Exemption: - At least 3 quotes from reputable contractors for recommended improvements - EPC showing recommendations - Receipts/invoices for improvements already made (up to £3,500) - New EPC showing the rating after improvements, if still below band E
Third-Party Consent Exemption: - Copy of your written request for consent - Written refusal from the third party - Evidence that the refused work was necessary for compliance - Documentation showing who the third party is (lease, mortgage documents)
Devaluation Exemption: - Report from an independent RICS-qualified surveyor - Report must specifically state improvements would reduce value by more than 5% - Surveyor must explain the reasoning
Wall Insulation Exemption: - Survey report from a qualified installer or surveyor - Report must explain why wall insulation is not appropriate - Common reasons: cavity too narrow, flood risk, structural issues - Must cover all wall insulation options (internal and external)
New Landlord Exemption: - Evidence of how and when you became the landlord - For inheritance: grant of probate or letters of administration - For other circumstances: relevant legal documentation
Keep copies of all evidence for the duration of the exemption and any subsequent renewals.
Exemptions do not transfer when a property changes hands. If you buy a property with a registered exemption:
The existing exemption ends: When ownership transfers, any exemption registered by the previous owner is no longer valid. You cannot rely on their exemption.
You get a grace period: As a new owner, you typically have a 6-month grace period to either: - Make improvements to achieve compliance - Register your own exemption with new evidence
You must reassess the situation: The previous owner's circumstances may not apply to you. For example: - Their cost cap evidence is no longer valid (prices may have changed) - You may have different financing options - Building regulations or technology may have changed - Grant schemes may now be available
Due diligence when buying: Before purchasing a property below band E, or one you think would struggle to reach band C if the proposal lands, consider: - What improvements are needed? - What would they cost you? - Would you qualify for an exemption? - Factor improvement costs into your offer
Sellers should disclose EPC status, but always check the current certificate and consider getting an updated assessment as part of your purchase survey.
Exemptions last 5 years, except the new landlord ground, which lasts 6 months. When yours expires:
Reassessment required: You must reassess whether you still qualify for an exemption or whether circumstances have changed allowing compliance.
Things that may have changed: - New technologies may have become available or more affordable - Grant schemes may now cover previously expensive improvements - Building regulations may have been updated - Your property may have changed - RdSAP methodology changes may affect your rating
Renewal process: If you still qualify, you need to re-register with fresh evidence. You cannot simply renew the old exemption without new documentation.
New evidence required: - New quotes showing current costs - Updated EPC if your previous one has expired - Fresh surveys or reports where applicable
If you no longer qualify: If circumstances have changed and compliance is now possible, you must make the necessary improvements. Continuing to rely on an expired exemption is non-compliance.
Plan ahead: Start reviewing your situation 6-12 months before your exemption expires. This gives you time to gather new evidence or plan improvements if needed.