Landlords Face Surprising 2028 Deadline for EPC ‘C’ Compliance

Landlords are facing an unexpected 2028 deadline to meet the EPC ‘C’ rating for new tenancies, not 2030 as previously anticipated. However, all tenancies must comply by 2030. The full timeline and definitions are outlined below.

The government’s consultation clarifies that the 2028 deadline for new tenancies is designed to give landlords more time to plan and make necessary property improvements. The new law is expected to be enacted by 2026, at which point the cost cap will be confirmed.

Landlords are encouraged to start improvements before the 2028 deadline, as the government announced a £15,000 cap on upgrade costs.

EPC Reform Timeline and Higher MEES Implementation

Here is the government’s proposed timeline for EPC reforms and higher Minimum Energy Efficiency Standards (MEES) for privately rented homes:

    • 2025
        • Government responds to consultations on EPC reforms and improving energy performance in privately rented homes.

        • Consultation on the proposed Home Energy Model (HEM) for new EPC metrics.

    • 2026
        • Final HEM methodology published.

        • Preparations for the introduction of new EPCs, including the training of energy assessors, are completed.

        • New EPCs with updated metrics become available.

        • Government confirms new standards for privately rented homes and lays secondary legislation to raise MEES.

        • Updated guidance for landlords on meeting the higher standards is issued.

    • 2028
        • New tenancies in privately rented homes must meet the higher EPC standard.

    • 2030
        • All tenancies must meet the higher EPC standard.

Definitions of ‘New Tenancies’ and ‘All Tenancies’

    • New tenancies: A new tenancy is defined as a rental contract with a new tenant or a renewal/extension of a current contract.

    • All tenancies: This refers to properties where the same tenant has remained in the property continuously. The deadline for “all tenancies” sets a final date for meeting the EPC standard across the sector.

New EPC Standards Expected by 2026

Landlords are advised to begin upgrading their properties now to meet the new Energy Performance Certificate (EPC) standards, which will be in effect starting in 2026. Financial support, including grants for eligible landlords, is currently available.

To meet future Minimum Energy Efficiency Standards (MEES), landlords should aim for an Energy Efficiency Rating (EER) of ‘C’ based on current EPCs. Properties with an existing EPC rating of C (EER) will be compliant with the future standards until the current EPC expires or is replaced.

After 2026, properties will need to meet the new metrics under the revised EPC standards.

Proposed 2028 Implementation Timeline

The consultation suggests the following:

    • The 2028 deadline for new tenancies and 2030 for all tenancies allows landlords more time to make necessary home improvements.

    • The £15,000 cap on energy-efficiency upgrades would be effective from the secondary legislation laid in 2026.

    • The government encourages early action ahead of the 2028 deadline, and guidance on compliance will be published after the regulations are laid.

Several support programs are currently available for properties that are among the least energy-efficient, such as the Boiler Upgrade Scheme and fuel poverty schemes like the Energy Company Obligation. In Wales, schemes like the Warm Homes Nest and Leasing Scheme Wales also offer assistance.

Additionally, a zero VAT rate on energy-saving measures, including insulation and low-carbon heating, is available until March 2027, reducing costs for landlords.

Need for a Stable Cost Cap

The government acknowledges the importance of a stable cost cap on energy-efficiency upgrades for landlords. To provide certainty, they propose a £15,000 cap (including VAT) per property, with no automatic inflation-linked increases.

Current estimates suggest the average investment needed to meet the higher EPC standard will range from £6,100 to £6,800, making the £15,000 cap a balanced approach that allows for widespread property upgrades while addressing fuel poverty and providing tenants with warmer, more affordable homes.

While a £10,000 cap (as proposed in 2020) would lower costs for some landlords, it would limit the overall effectiveness of the reforms.

Consultation Question for Landlords

The government is seeking feedback on its proposed timeline. The key question for landlords is:

“Do you agree with the 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 can respond to the consultation on the official government website Improving the energy performance of privately rented homes in England and Wales – 2025 update – Department for Energy Security and Net Zero – Citizen Space