EPC C targets under fire over impact on older homes

Britain has some of Europe’s oldest housing stock, and with government plans to bring private rented homes up to EPC C, the question remains: how will older properties meet the standard?

Industry bodies have warned a “one-size-fits-all” approach to energy-efficiency targets is not the answer for older properties.

As older buildings become harder to maintain, there are concerns that landlords may sell up, tightening supply in the private rented sector (PRS).

Unintended consequences for pre-listed buildings

Pre-World War I buildings were designed very differently from modern homes

Their walls absorb and release moisture naturally through breathable materials such as lime mortar, lime plaster and soft brick or stone. Unlike modern cavity-wall construction, they were never intended to be sealed airtight.

These differences have fuelled concerns about how older properties will be assessed under tighter energy-efficiency standards.

The government has announced plans to overhaul the way EPCs are measured, arguing the current single-metric system is “insufficient”.

Under the current rules, EPCs are based on the amount of energy a property uses per square metre and how much energy it loses through factors such as poor insulation.

The proposed reforms would introduce four headline metrics: fabric performance, heating system, smart readiness and energy cost, with energy use and carbon emissions provided as secondary information.

However, heritage groups have warned that some of these measures may not accurately reflect the way older buildings were designed to function.

The Society for the Protection of Ancient Buildings (SPAB) told the government during its EPC consultation that applying modern insulation standards to traditional properties could have unintended consequences.

SPAB explains: “Fabric performance should only be used alongside other metrics.

“A ‘fabric first’ approach with older (‘traditional’ solid-walled) buildings, whereby measures are undertaken to try and make them match the fabric performance of their modern counterparts, resulting in over-insulation and other inappropriate work, risks harming both buildings and their occupants’ health.”

A one-size-fits-all approach does not work

Propertymark has also warned that for many older buildings in the private rented sector it simply won’t be feasible to install the necessary upgrades.

Timothy Douglas, head of policy and campaigns at Propertymark, told Property118: “We support efforts to improve the energy efficiency of privately rented homes, but we continue to stress that the proposed EPC C requirements across England and Wales present significant practical challenges for many landlords, particularly those with older and traditionally constructed properties.

“A major concern is that a one-size-fits-all approach does not reflect the diversity of housing stock across the private rented sector.

“Many older homes, including pre-1919 properties, solid wall buildings, and heritage homes, can be difficult and costly to retrofit to EPC C using conventional measures.

“In some cases, the recommended improvements may not be technically suitable, could negatively affect the fabric of the building, or may deliver only limited gains relative to the investment required. Many of our agent members consider the target unrealistic for certain property types without sustained financial support.”

Unable to hit proposed targets

The National Residential Landlords Association (NRLA) also agrees that not every property in the private rented sector will be able to meet EPC C targets by 2030.

Chris Norris, chief policy officer for the NRLA, told Property118: “We are firmly of the view that rental properties must be as energy efficient as practicable. However, it is simply not feasible for every property in the market to be retrofitted to meet an EPC ‘C’ rating within the previously proposed time frame.

“The current proposal doesn’t take into account the varying age and condition of housing stock inside and outside of the PRS, the complexity of the work required, or the lack of appropriately skilled tradespeople needed to make improvements.

“Without a coherent plan of action to help the retrofit industry scale up to support landlords in meeting these new benchmarks, it is highly likely that landlords will be unable to hit the proposed targets.”

He adds that many landlords will decide the cost of retrofitting is not worth the hassle and choose to sell up.

Mr Norris said: “Many landlords will therefore have little choice but to sell properties that will be difficult, and excessively costly, to retrofit. This will reduce the supply of available rental properties further reducing available housing during the ongoing, and acute, supply and demand crisis.

“Ministers need to develop a targeted programme of support to facilitate investment, as the Committee on Fuel Poverty and Citizens Advice has previously recommended.”

Cost burden is fair and proportionate

The government continues to defend EPC C targets for landlords, claiming the cost and compliance burden is “fair and proportionate”.

Responding in a written parliamentary question, energy minister Martin McCluskey said the government recognises the challenges landlords face in meeting EPC targets.

He said: “The government recognises there is no “one-size-fits-all” approach to tackling the UK’s diverse building stock. We have set out a range of provisions to ensure the cost and compliance burden is fair and proportionate for landlords.

“This includes a maximum spend requirement of £10,000 per property, and a range of exemptions for circumstances where the installation of measures is not feasible or appropriate.”

Under government plans, landlords will be able to choose between the smart or heat metrics, and the cap on the amount they are expected to invest to meet the new standards will be reduced from £15,000 to £10,000.

The cost cap will be lower where £10,000 would represent 10% or more of a property’s value.

Landlords unable to reach EPC C may be able to apply for an exemption if they have already spent up to the £10,000 cost cap, if further works would exceed the cap, or if recommended measures are not appropriate for the property.

For older buildings, supporting evidence could include surveyor reports highlighting moisture or fabric risks, quotations showing specialist retrofit works exceed the cost cap, planning restrictions, or evidence that certain measures are technically unsuitable.

Any exemption would need to be registered on the PRS Exemptions Register and supported by evidence. Once approved, a council enforcement officer’s role is to check whether a valid exemption has been registered, rather than reassess the technical evidence behind it.

Cost cap struggle for older buildings

Propertymark has welcomed the £10,000 cost cap but warns that many older buildings will still struggle to upgrade within the limit.

Mr Douglas explains: “We support the proposed extension of exemptions to 10 years within the £10,000 cost cap framework, as it offers landlords greater certainty and more time to plan improvements strategically.

“However, Propertymark has consistently argued that many properties will still struggle to achieve EPC C within the proposed cap, particularly older buildings requiring extensive retrofit works.

“Landlords need clearer guidance, long-term policy stability, and greater financial assistance if the sector is to meet the 2030 deadline without unintended consequences for housing supply.

“Targets should also be linked to the age and archetype of properties to ensure homes become as energy efficient as possible without losing much-needed rental stock from the private rented sector.”

Mr Douglas adds: “Propertymark has additionally called for incremental and realistic implementation targets rather than repeated changes to compliance timelines, arguing that landlords require certainty to make long-term investment decisions.

“Following previous EPC targets being delayed and ultimately scrapped, many landlords now question whether the 2030 deadline will proceed as planned. Greater policy stability and sufficient notice periods will be essential to give landlords the confidence to invest and ensure more homes are upgraded successfully.”

Help manage the burden on landlords

When contacted by Property118, the Department for Energy Security and Net Zero (DESNZ) said the government had consulted stakeholders with older and harder-to-upgrade properties and made changes to reflect their feedback, including making solid wall insulation discretionary where it may not be suitable.

Under current rules, landlords must achieve at least EPC E to let a property, with exemptions available for homes that cannot be improved to that standard. The government has hinted that a similar exemption system is expected to continue if the minimum requirement is raised to EPC C.

A DESNZ spokesperson said:  “Every renter has the right to a decent, safe and affordable home, and almost half of privately rented homes already meet the standards.

“We have built-in protections, including a strict cost-cap, alongside new and expanded exemptions, with the measures welcomed as a positive step forward by both tenant and landlord groups.

“These will help manage the burden on landlords, while still achieving our ambition to deliver significant bill savings for tenants and lift hundreds of thousands of households out of fuel poverty.”

Reaching EPC C may be impossible

With the 2030 deadline looming, many landlords face difficult decisions over whether to retrofit or sell.

For some older properties, reaching EPC C may ultimately prove impossible, leaving tenants to pay the price through a shortage of homes.