Can EPC rules regarding insulation be a retrograde step?

Do not remove bathroom extractors or kitchen extractors if you have them.

If the property then suffers from excess moisture and results in mould you will be very likely held responsible for removing the mould, if not deemed by Environmental Health as contributing to the mould.

If having to increase insulation then under Net Zero etc would landlords be fined for putting in passive air vents?

Victorian/Edwardian properties has air bricks in each room near ceiling level to increase ventilation and stop mould. In many’s wisdom these air bricks have been plastered over, stupid!

These net zero fanatics don't understand that older houses need ventilation. They would have you insulate against every potential draught, but this only leads to damp and rot. So, you do what the EPC surveyor recommends, it results in damp, your tenant complains to the council, you remediate the damp at yet more cost, and invalidate the EPC level.

Although this is at our own house, we have a loft installed P.I.V. (passive input ventilation) unit which pushes air through the building. It can be heard, but hardly.
We also have external wall insulation of this 100 year old property (over pebble dash), and it's been in place for about 8 years.
We didn't really suffer from mould, but it removed a distinctly musty smell from downstairs and, if you are sometimes going to dry something inside the house (we don't use a tumble dryer), it will assist clothes horse drying when relatively nearby, whilst reducing humidity, as we have all dried stuff indoors in inclement weather, so tenants definitely will also!
We have them in several rental properties and have a clause in the AST where the tenant agrees to the approx. £50 annual cost of running the fixed wired unit and undertakes not to remove the fused spur fuse in the loft or to reduce the output level.
Very approximate cost of supply and install is £450, but less if you want to cut the ceiling hole, fix to joists or rafters in some cases, then get a spark to complete, say if already there doing something else. 5 year filter change approx £25 by self fitting by landlord (not tenant!).

Accommod8, The Tenant Fees Act 2019 prohibits landlords and letting agents charging tenants and other relevant persons any fee unless it is a "permitted payment". Your charge is not a "permitted payment"
A breach of the ban is a civil offence with a potential £5k fine. If you are convicted of an offence under the ban this will constitute a "banning order offence" under the Housing & Planning Act 2015

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/922898/Tenant_Fees_Act_2019_-_Guidance_for_landlords_and_agents.pdf

Thank you very much David for bringing this up. I have actually recently written to my local MP, Jeremy Hunt, about the same thing. Why should we be forced to make changes to our properties that could result in potentially very costly problems in the future?

His response on 20 June was: “I am afraid this falls under the remit of the Department for Levelling Up, Housing and Communities so I will write to them on your behalf to ask for further detail on the policy and the protections for landlords. I will of course let you know when I receive a reply.”

Sadly I don’t think there is a lot of common sense in the government when it comes to the private rental sector, and the Conservatives are making multiple ill-considered changes to regulations that will cause more harm than good in the long run.

I will update you when I hear from Jeremy again, but I’m not holding my breath for a helpful or fair response. Maybe I’ll be surprised.

Marksw4-
I have re-read the act guidance and I thank you for flagging this up.
We will re-pay the estimated annual charge, and from the next ASTs the clause will be removed, with a letter to be sent now to advise of the effective deletion of the charge clause.
It can just become part of the hard wired systems such as many bathroom extractor fans where the tenant is automatically paying, as it's their duty to adequately ventilate such rooms.
Extract from an Openrent AST:
"9.24. To take all reasonable precautions to prevent condensation and damp by keeping the Premises adequately
ventilated and heated."
If anyone decided they didn't want to pay for a property with a PIV system, they would be welcome to look elsewhere.
We could also add a clause reminding tenants that they must not disconnect the system for new ASTs and presumably for the forthcoming periodic only contracts.
We made the investment in installing them to help both parties. We could also in theory add the £5 monthly running costs to the rent for a new tenancy whereby £600 becomes £605pcm.
It's a sensitive topic with responsibilities for both parties, so I appreciate the intervention in correcting me thanks.