Landlords face a shock 2028 deadline for meeting EPC ‘C’ deadline

The detail of the government’s consultation on implementing an EPC rating of C in privately rented properties reveals a deadline of 2028 for new tenancies – NOT 2030.

However, ALL tenancies will need to be EPC C compliant by 2030 – we have published the timeline and relevant definitions below.

The government says this extended timeframe is intended to provide landlords with extra time to plan and implement necessary property improvements.

Also, the new law is expected to be enacted in 2026 and that’s when the cost cap will be established.

The government makes clear in its consultation document that landlords are encouraged to begin making improvements before the 2028 deadline.

The government announcement was made today with a proposed £15,000 cap on upgrading costs.

Implementation of EPC reform

This is the government’s proposed timeline for the implementation of EPC reform and higher MEES for privately rented homes.

2025

• Government responds to the consultation on ‘Reforms to the Energy Performance of Buildings Regime’
• Government consults on a proposed Home Energy Model (HEM) methodology for producing new EPC metrics
• Government responds to the consultation on ‘Improving the energy performance of privately rented homes in England and Wales’.

2026

• The final HEM methodology for producing new EPC metrics is published
• Final preparation to introduce new EPCs, including the delivery of EPC software and the training of energy assessors, takes place
• New EPCs, displaying new metrics, become available for landlords to commission (and EPCs in their existing format displaying the EER are no longer available)
• Government confirms the explicit standards set against new metrics that privately rented homes are required to meet and lays secondary legislation to raise MEES in the sector
• Government updates guidance for landlords on complying with the higher standard.

2028

• New tenancies in the domestic PRS are required to meet the higher standard.

2030

• All tenancies in the domestic PRS are required to meet the higher standard.

This is the government guide to terminology:

Definition of ‘new tenancies’ and ‘all tenancies’, PRS Regulations –

• ‘New tenancies’ – A ‘new tenancy’ is defined as a tenancy where a domestic property is rented out to a new tenant, or a contract with an existing tenant is renewed or extended.
• ‘All tenancies’ – ‘All tenancies’ are defined as those where the same tenant has been in situ throughout. The ‘all tenancies’ trigger date effectively introduces a backstop date, by which all remaining properties which are required to have EPCs, will have to be improved to the required EPC rating.

New EPC standards expected in 2026

Landlords are being encouraged by the government to upgrade the energy efficiency of their rental properties before the new Energy Performance Certificate (EPC) standards take effect in 2026.

Government support, including grants – subject to eligibility – is currently available.

It says that landlords should aim to implement the recommendations on existing EPCs and aim for an Energy Efficiency Rating (EER) of C.

Achieving this rating now will help address fuel poverty and aligns with government targets.

The government also says that properties with a current EPC rating of C (EER) will be considered compliant with future Minimum Energy Efficiency Standards (MEES) until the current EPC expires or is replaced.

After 2026, when a new EPC is required, properties will need to meet the updated standards measured against the new metrics.

Proposed 2028 implementation timeline

The consultation states:

By proposing an implementation timeline of 2028 for new tenancies and 2030 for all tenancies, government would be providing additional time for landlords to plan for home improvements.

Government proposes that spend towards the cost cap would be counted from the date of secondary legislation being laid in 2026.

Early action would be encouraged prior to 2028 and following the updated regulations being laid, government would publish guidance to help landlords understand how to comply and what improvements would be counted towards the cost cap.

There is support currently available (subject to eligibility) for some of the least energy efficient homes through schemes including the Boiler Upgrade Scheme, the Great British Insulation Scheme, fuel poverty schemes such as the Energy Company Obligation, and, in Wales, the Warm Homes Nest scheme and Leasing Scheme Wales.

An eligibility tool is available on our ‘Help for Households’ GOV.UK page that will help people learn what support is available.

There is also a zero rate of VAT until March 2027 on energy saving measures, such as insulation, and low-carbon heating, making it cheaper for people to invest in their properties.

Need for a stable cost cap

The government also says that following the 2020 consultation, it recognises the need for a stable cost cap on energy efficiency improvements for landlords, one that isn’t automatically increased by inflation.

This will provide landlords with greater certainty.

Therefore, the government proposes a maximum investment of £15,000 (including VAT) per property, with no automatic inflation-linked increases.

This £15,000 cap aims to balance the need for improved energy efficiency with the flexibility for landlords to choose various improvement methods.

Current modelling (based on 2024 prices) suggests the average investment to meet the higher standard would be between £6,100 and £6,800.

The proposed cap ensures, the government says, more properties are upgraded, lifting more tenants out of fuel poverty and providing warmer, more affordable homes.

While a lower £10,000 cap (as proposed in 2020) would reduce costs for some landlords, it would also limit the overall impact of the reforms, benefiting fewer properties and tenants.

Consultation question for landlords

The government’s consultation question for landlords to consider is this:

7. Do you agree with government’s preferred implementation timeline to require ‘new tenancies’ to meet the higher standard from 2028 and ‘all tenancies’ to meet the higher standard by 2030? If not, do you have alternative suggestions?

Landlords wanting to respond to the consultation should do so on the .gov website.