Countdown to EPC C: Key risks and actions for residential landlords

As part of the Government’s Warm Homes Plan, from 1 October 2030, the minimum EPC rating for privately rented residential property in England will increase from E to C, unless an exemption applies.

The Government has also confirmed that all new and existing social rented residential properties must achieve an EPC rating of C (or equivalent) by 1 April 2030 or have a valid exemption in place.

We have put together a list of key questions and answers for residential landlords to consider. The changes to the EPC regulations are particularly pertinent for rural landlords, such as our charity or estate clients, with heritage properties or short-term lets such as holiday cottages, as they are brought within the new rules.

What is the new HEM:EPC metric?

The Government is introducing a new EPC methodology called the Home Energy Model: Energy Performance Certificate (HEM:EPC). This will replace the existing Energy Efficiency Rating (EER).

The system is expected to launch in late 2026 and become mandatory for all new EPCs from 1 October 2029.

If I achieve EPC C now, will it still count under the new system?

Yes. If a property achieves EPC C before 1 October 2029, whether under the current EER or the new HEM:EPC system, it will be treated as compliant until that EPC expires.

How will properties be assessed under the HEM:EPC?

Under the proposed HEM system, properties will be assessed on three main factors:

1. Fabric performance – insulation, glazing, and draught proofing.
2. Heating systems – efficiency, with a strong preference for heat pumps.
3. Smart readiness – ability to generate or manage energy, e.g. solar panels.

Properties would be scored first on fabric, and then on either heating system or smart readiness.

Will landlords need to install a heat pump or solar panels?

Possibly. Given the new assessment weightings, many landlords may ultimately need to install heat pumps or solar PV to meet the revised definition of EPC C.

How long will the EPC be valid for?

EPCs will continue to be valid for 10 years. However, the Government intends to amend the regulations so that an EPC must be in place at the point of marketing, removing the current 28‑day grace period after a property is first advertised for sale or let.

Should landlords act now rather than wait?

Landlords may wish to secure an EPC C under the current methodology before 1 October 2029, locking in compliance for up to 10 years before the new requirements apply.

What happens if a landlord does not comply?

Failure to comply could result in civil penalties of up to £30,000 per property. Landlords such as our charity clients will also consider the reputational risk of non-compliance.

What is an EPC exemption and how long does it last?

If a property cannot reasonably be improved to meet EPC C, a landlord may apply to register an exemption.

An exemption lasts for 10 years, during which time the property may continue to be let. When it expires, the landlord must reassess and carry out any improvements that have since become feasible.

What is the new £10,000 cost cap?

A major exemption is the introduction of a £10,000 cost cap for most properties. Landlords will not be required to spend more than this on energy-efficiency improvements.

For properties valued at under £100,000, a separate “Property Value Adjustment” applies, requiring landlords to spend up to 10% of the property’s value.

Any costs incurred from 1 October 2025 will count toward the new cap.

Do grants count towards the cost cap?

Yes. Works funded through recognised grant schemes will contribute to compliance and will also count against the overall cost cap.

Can landlords claim an exemption if they cannot get permission to carry out the works?

Yes. An exemption is available where a landlord is unable to complete improvement works because a third party refuses consent, for example:

• a freeholder refusing permission, or
• a tenant refusing access for the necessary works.

To rely on this exemption, landlords must show clear evidence that consent was requested and refused. All requests should be made in writing, and detailed records kept of the responses.

Do listed buildings need to meet EPC requirements?

Currently, heritage buildings have a limited exemption where meeting EPC standards would unacceptably alter their character. However, the Government intends to remove this exemption, bringing all listed buildings fully into the EPC framework.

What challenges will this create for heritage landlords such as our charity and estate clients?

This shift will require careful forward planning, including navigating the listed building consent process.

The Government has committed to:

• tailoring EPC recommendations for listed properties, and
• retaining MEES exemptions where listed building consent is refused.

A new exemption will also cover “negative impacts”, allowing landlords to evidence that a particular improvement would damage the property.

Those with large portfolios of heritage properties will no doubt wish to start reviewing the requirements with their professional advisors on a property by property basis now, so they can plan for works and consider exemptions where relevant.

Do holiday lets and short‑term rentals need EPCs?

Yes. Short‑term rental properties, including holiday lets and Airbnb-style accommodation, will require a valid EPC whenever they are let. Many such properties are in rural or heritage settings, so the impacts of these reforms are likely to be significant for our rural clients. It is important to consider works to be completed early so any necessary consents can be applied for and clients can take advice on any exemptions that may be available for their specific property. 

How can Foot Anstey help?

For more information on the forthcoming changes to EPC regulations and how to prepare your property portfolio for compliance, please get in touch with our team.