Policy paper

Improving Energy Performance Certificates: action plan - progress report

Published 8 November 2021

Applies to England

1. Executive summary

This EPC action plan progress report provides an update on the progress made to deliver the actions detailed in the EPC action plan (‘the Plan’), published in September 2020. The Plan set out a series of 35 actions following a call for evidence on Energy Performance Certificates (‘EPCs’) that was launched in July 2018.

The actions were designed to deliver:

1. An EPC system that produces accurate, reliable, and trusted EPCs

Actions delivered to date include the new Energy Performance of Buildings Register (‘the Register’) designed according to government standards and extensively tested with Register users; the implementation of EPC lodgement rules that help prevent lodgement errors; and the publication of a consultation on options for the introduction of a new performance-based operational ratings scheme for non-domestic buildings.

2. An EPC that engages consumers and supports policies to drive action

Actions delivered to date include updating EPCs to include current information about government policy which relies on an EPC rating; a new format for the EPC which presents the most important EPC information upfront whilst allowing interested consumers to drill down into further levels of detailed information where relevant; and the publication of a consultation on how mortgage lenders can support homeowners to improve the energy performance of their homes.

3. A data infrastructure fit for the future of EPCs

Actions delivered to date include the transition to the new version of the Register; the quarterly publication of the extended data sets on the Open Data Communities website; and helping consumers locate information on improving energy efficiency of their building by signposting from the Register to websites that can provide trusted advice.

One year on since the publication of the Plan, we have either met or exceeded the target commencement dates for all actions. Additionally, we have now completed eleven of the 35 actions and have made significant progress towards the completion of the remaining actions. Eleven of these remaining actions will require changes to the Energy Performance of Buildings (England and Wales) Regulations 2012 (‘EPB Regulations’) and we are working towards publishing a consultation on the Regulations in 2022.

The annex includes the report in tabular form with the actions listed in the order detailed in the original plan for use as a reference to this document.

2. Introduction

Background

EPCs are a widely used measure of the energy performance of buildings in the residential, commercial, and public sectors and are a key tool in promoting energy performance improvements in buildings. Since their introduction in 2007, EPCs have been required when a property is constructed or offered for sale or let. The purpose of an EPC is to indicate the energy performance of the property to prospective tenants or buyers.

EPCs provide policymakers and markets with information about the energy performance of the building stock, as well as supporting and encouraging individuals to make informed choices about how to improve the energy performance of their building. Increasingly, government regulation and policy has relied upon buildings having a current EPC and certain measures have been linked to a building achieving a specific EPC rating. Examples of this include the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 (‘PRS Regulations’) and the Domestic Renewable Heat Initiative (‘Domestic RHI’), which provides support to install renewable energy production.

A qualified energy assessor uses government approved software to process information that has been collected about a building and its installed heating, lighting, ventilation, and air conditioning systems to produce an overall rating of A to G (for domestic buildings) or A+ to G (for non-domestic).

EPCs and their underlying data are lodged on the Energy Performance of Buildings Register along with Display Energy Certificates (DECs) and Air Conditioning Inspection Reports (ACIRs). Anyone can access the Register and search for an EPC, DEC or ACIR that has been lodged against an address. There are currently 22,430,000 EPCs on the Register for England and Wales.

Heating and powering buildings currently accounts for 40% of the UK’s total energy usage. In 2018, heating and powering homes accounted for 22% of all greenhouse gas emissions in the UK. The UK has set in law a target to bring its greenhouse gas emissions to net zero by 2050 – one of the most ambitious targets in the world.

The EPC action plan

In July 2018 we launched a Call for Evidence on Energy Performance Certificates (EPCs) with the aims of:

1. gaining evidence on how well the current EPC system is working
2. gathering information on the suitability of the current system of EPCs for both their current and emerging role in measuring building energy performance
3. obtaining feedback and suggestions for improvement

The call for evidence outlined the government’s view of what EPCs are used for, what they are likely to be used for in the future and what important characteristics are required for these uses. The call for evidence identified that to maximise the effectiveness of EPCs in improving the performance of the existing building stock it is important to ensure that EPCs:

• provide a trusted, accurate and reliable measure of a building’s energy performance
• engage consumers and support action to reduce energy use in buildings
• enable consumers and third parties to access the data they need to make decisions

In response to the call for evidence we received a total of 229 responses from a wide range of stakeholders. The substance of those responses was set out in our call for evidence summary of responses document, published in September 2020 alongside the EPC action plan (the Plan). The EPC action plan identified 35 actions that would improve the efficiency and effectiveness of EPCs to deliver:

1. An EPC system that produces accurate, reliable, and trusted EPCs.

Policies to achieve our aspiration for as many homes as possible to be EPC Band C by 2035 are likely to increasingly depend on an EPC rating. The rating of EPCs will begin to have financial implications and incentives to improve the rating are likely to increase as a result. EPCs therefore need to be accurate, reliable, and trusted.

2. An EPC that engages consumers and supports policies to drive action.

We need to engage consumers and third parties to help them understand how a building is performing and how they can make improvements that will be appropriate to them and to the property. EPCs need to work for consumers, rather than be regarded purely as a regulatory necessity. A greater number of policies are likely to rely on EPCs in the future as we move towards meeting our aspiration for as many homes as possible to be EPC band C by 2035.

3. A data infrastructure fit for the future of EPCs.

As part of achieving the UK’s ambitious target for net-zero greenhouse gas emissions by 2050, EPCs provide consumers, building owners and occupiers and third parties with information on the performance of the building stock and support effective decisions on improving the energy efficiency of buildings. It is, therefore, important that it is easy to access EPC information and link it to other relevant sources of data. The data infrastructure for EPCs also needs to continue to evolve to meet future needs.

Delivering the Plan

The Plan is an important tool in delivering improved EPCs, improving the EPC framework, and engaging with stakeholders to deliver this.

Following the publication of the Plan we arranged discussions with stakeholder organisations to seek their views on the 35 actions and how best to take them forward. We engaged with a wide range of stakeholders including energy assessor Accreditation Schemes (’Schemes’), energy efficiency professionals, property industry, estates/letting agents, construction industry, consumer groups, housing bodies and charities, energy efficiency industry manufacturers and installers, energy technology industry, and research organisations.

The outcomes from these discussions have helped to inform our approach to progressing many of the actions in the Plan. Those changes which were simpler and faster to make have been made, however some improvements to EPCs will take several years to implement and involve changing complex processes, as well as requiring amendments to the supporting legislation. Despite the challenges of implementing these changes, we have already made significant progress and have been able to progress all the actions contained in the Plan. A forthcoming consultation on the EPB Regulations will seek views which will be used to inform our future domestic policy and will allow us to make those more complex changes requiring legislative changes.

This progress report outlines the progress we have made on delivering the Plan, as well as the next steps in delivery as we continue to improve EPCs. We have either met or exceeded the target commencement dates for all actions in the Plan and have completed eleven actions to date. We have made significant progress towards the completion of the remaining actions.

Eleven of the remaining proposed changes will require changes to the EPB Regulations, and we are working towards publishing a consultation on the Regulations in 2022.

The annex includes the report in tabular form with the actions listed in the order detailed in the original Plan for use as a reference to this document.

3. An EPC system that delivers accurate, reliable, and trusted EPCs

This section relates to EPC Actions to address questions of reliability, accuracy and compliance as set out in the Plan, which identified thirteen actions to consider in this area.

Several government targets and aspirations for improving energy performance standards set out in the Clean Growth Strategy are based on the EPC rating of a property. Policies are therefore likely to increasingly depend on an EPC rating in the future. This is already the case with PRS Regulations in the private rental sector.

In September 2020 the government published the Improving the energy performance of privately rented homes consultation with proposals to use the EPC rating to improve energy performance of buildings in the domestic private rented sector. The rating of EPCs will therefore increasingly have a financial value, and incentives to improve the rating are likely to increase as a result. As such, EPCs will need to be accurate, reliable, and trusted.

To ensure that greenhouse gas reduction and energy efficiency goals are met, consumers, government and third parties will need to have greater confidence that changes to a building which improve EPC ratings will have a measurable effect on energy use. In the short term, this is being delivered through the actions we are progressing to improve EPC reliability as part of the Plan, but in the longer-term broader changes will be needed and we are already beginning to consider these.

Progress on ‘An EPC system that delivers accurate, reliable and trusted EPCs’

Three of the 13 actions in this section of the Action Plan have now been completed – Actions R2, R5 and R10 – and the remaining actions have been commenced.

As part of the Register development, we said we would consider how consumer information around EPCs could be improved and the necessary limitations of the process better explained (Action R2). This action has now been completed as the new Register has been developed using a significant amount of user research. All content on the Register website has been designed according to government standards and extensively tested with Register users and a helpdesk service is available to address service users’ questions.

We said we would consult on options for the introduction of a new operational ratings scheme for non-domestic buildings, including considering how a new operational ratings scheme would align and interact with the existing Display Energy Certificates (DECs) framework (Action R5). This consultation was published on 17 March 2021 and closed on 9 June 2021. The consultation was in two parts: ‘Introducing a performance-based policy framework in large commercial and industrial buildings in England and Wales’ and ‘Introducing performance-based ratings in commercial and industrial offices above 1000m2 in England and Wales: phase 1 of the introduction of a national performance-based policy framework’. A response will be published in due course.

We said we would consider the case for putting in place a formal error reporting system to flag up incorrect or fraudulent EPCs for investigation and how issues raised in this system could also be fed back into the smart auditing process (Action R10). Since September 2020, the revised Register service has been operated directly by the government and this has allowed us to have greater oversight of error reporting and helpdesk enquiries, allowing us to respond to these and rapidly amend Register systems and lodgement rules. The new Register has lodgement rules that help prevent lodgement errors by stopping clearly incorrect data being lodged. We are able to alter existing rules and add new lodgement rules to react to new information that we receive to further prevent lodgement errors.

Additionally, feedback channels are available on the Register website with agreed escalation points from the service desk, through to assessors, then Schemes and their independent panels. Feedback about the Register itself is received and managed by the government. This has already brought issues to the attention of the Register team that have been dealt with or escalated via other appropriate routes. The Register also has infrastructure in place that allows the logging of patterns of EPB lodgements that could indicate misuse, allowing us to quickly address issues. In the future, we will move towards a system where highlighted errors, issues and patterns of lodgements will be used to inform smart auditing of the Register services.

To improve data processes to enable EPC enforcement authorities to better identify non-compliance and enable better identification of input errors in EPCs (Action R1), we are working on a data warehousing solution to improve the extraction of data from the Register and are undertaking user research with enforcement bodies to identify data/information useful for enforcement. Further details on our data warehousing solution plans are outlined later in this document in Progress on ‘A data infrastructure fit for the future of EPCs’.

We have worked with Schemes to identify opportunities to improve the use of certificate lodgement data to assess and better target smart auditing to check the quality of EPCs (Action R3). We have also worked with Schemes to identify opportunities to improve the training and strengthen the continuous professional development evidence requirements for energy assessors (Action R4).

We are also working with Schemes to identify the best options to implement unique assessor registration numbers on the Register (Action R6). Implementing this feature will require significant development and amendment of the present energy assessor membership services on the Register and the revision by Schemes of their membership management processes in order to correctly match individual assessors working for a number of different Schemes. A system of informing all Schemes when one of their members is struck off or suspended is in place and the Register allows Schemes to check whether an assessor applicant was previously struck off by another Scheme.

We are working with stakeholders and Register service users to develop the presentation of the EPC to fulfil Action R7 (alongside Actions C10 and C11). Working with stakeholders, and through research with Register service users, we expect to identify a list of features or data items that could be added to an EPC as additional information, while considering any issues of data security on these being annexed to an EPC. We are examining if this additional data could be provided on the EPC or whether there is a more practicable route of publishing this data through other means, such as the Open Data Communities.

The Standard Assessment Procedure (SAP) methodology that is used by energy assessors to produce EPCs for new buildings has been updated (Action R8). The SAP 10.2 update was published by BRE in August 2021 and is available to download now . This is a near-complete edition of the SAP specification that will come into force in 2022. The final updates will be confirmed in the forthcoming government response to a consultation on the treatment of heat networks in SAP and the Future Buildings Standard consultation response, due to be published in December. We are working on an update to the Reduced Data SAP (RdSAP) methodology, used for existing buildings, to follow the SAP update.

We are progressing work to develop SAP 11, the version of SAP due to come into force alongside the Future Homes Standard in 2025. We commissioned a scoping project to explore what SAP 11 should model and how it should do this, which reported back earlier this year; the report has been published.

We said we would review the penalties for EPC non-compliance so that they act as an effective deterrent and encourage EPC compliance and also consider options for improved enforcement and ways to improve EPC compliance through working with other actors (Actions R11 and R12). We have held discussions with stakeholders to explore compliance and enforcement penalties alongside compliance and enforcement amendments, as well as options for improved oversight and accountability of the whole EPC system to deal with quality, compliance, and potential gaming and fraud issues in a more comprehensive way (Action R13).

There were issues raised on the level and consistency of penalties between EPB and PRS Regulations. The feedback from stakeholders is being taken into consideration as we develop proposals which we expect to include in a public consultation on the EPB Regulation in 2022 (see Next Steps).

Next steps

We have begun preparations to hold a consultation on potential changes to the EPB Regulations in 2022. This will allow us to progress a number of actions relating to the delivery of an EPC system that delivers accurate, reliable, and trusted EPCs. We are developing proposals for possible inclusion in the consultation, to:

• further the use of, and access to, data to improve the audit of EPCs to raise their quality (Action R3)
• inform our future domestic policy including considering revising penalty rates (Action R11)
• inform our future domestic policy on EPB compliance and enforcement (Action C2)
• Take forward options for improved oversight and accountability of the whole EPC system, which have been discussed with stakeholders (Action R13)

We will also continue to progress the non-regulatory actions in this section.

• We expect to complete work on a scalable, queryable data warehousing solution to improve the extraction of data from the Register (Action R1)
• We will consider the option of amending the National Occupational Standards (NOS) for energy assessors on which energy assessor training is based. Improving the way energy assessments of buildings are carried out should improve the quality of EPCs. We will be considering further enhanced assessor training to improve EPC quality (Action R4)
• We will continue working with schemes to implement unique assessor registration numbers, which we expect to have in place by July 2022 (Action R6)
• We will continue to explore whether further data could be annexed to the EPC, or via another route such as the Open Data Communities. If appropriate, we intend to have this in place by the beginning of 2022 (Action R7)
• We expect to confirm the final updates to SAP 10.2 in the forthcoming government responses to the consultation on the treatment of heat networks in SAP and the Future Buildings Standard consultation due to be published in December 2021. We will also continue working on an RdSAP update to follow this. We will bring the SAP update into force in mid-2022 (Action R8)
• We expect to produce detailed proposals for the development of SAP 11 for consultation with interested parties. Following feedback from the consultation the amendments to SAP 11 will be finalised and the methodology updated. The SAP 11 roll-out is expected in 2025 (Action R9)
• We will continue to progress work to develop SAP 11, reviewing the recommendations within a recent scoping report on the future of SAP calculations that was commissioned to support the development, and procuring a delivery partner(/s) to take forward the development project, building on the recommendations in the report (Action R9)

4. An EPC that engages consumers and supports policies to drive action

This section of the Plan had 14 actions relating to questions on encouraging action, influencing property decisions, and making EPCs up to date.

We have been considering the actions in the Plan and how best to engage consumers and third parties to enable them to better understand how a building is performing and how they can make improvements that will be appropriate to them and to the property. EPCs need to work for consumers, rather than be regarded purely as a regulatory necessity.

To meet our aspiration for as many homes as possible to reach EPC Band C by 2035, an increasing number of policies are likely to rely on EPCs in the future and we have been considering the actions which could support policies to achieve this.

Progress on ‘An EPC that engages consumers and supports policies to drive action’

Five of the 14 actions in this section have now been completed - Actions C3, C6, C9, C11 and C13 – and work on the remaining actions has commenced.

We said we would update the EPC format to include more up-to-date information about government policies which rely on an EPC rating, such as PRS Regulations and government EPC targets (Action C11). This action has now been completed; where an EPC rating is below the requirement set out in the PRS Regulations permitting the property to be rented out the EPC now indicates that such properties may not be let. We have also engaged with stakeholders on the ways in which EPC guidance can be clarified to align more closely with PRS Regulations. Following this engagement, the EPC guidance has been updated and will be published in due course (Action C4). As part of our continuous improvement efforts, we will continue to investigate what further information or metrics about the building’s performance and its compliance with government policy could be added to EPCs. We will continue to review this information to ensure it remains up to date. We also expect to investigate what proportion of current HMOs were created before 2008 and are currently not legally required to have an EPC (Action C4).

As part of the Register development, we said we would move to an improved presentation of EPC data online which provides a certificate as a URL instead of a PDF (Actions C1 and C6), whilst still providing for a robust offline process to enable legal copies of EPCs and to ensure accessibility for all consumers. The new Register service went live on GOV.UK in September 2020 and a post-implementation Government Digital Service (GDS) assessment, required for all new government web services, was passed successfully in November 2020. As detailed in the Plan, this new format for the certificate presents the most important EPC information upfront whilst allowing interested consumers to drill down into further levels of detailed information where relevant.

The move to GOV.UK means that the EPC data now has more authority. We have engaged with stakeholders on further options to improve EPC accuracy which are being considered for inclusion in a consultation on the EPB Regulations in 2022 (see Next steps).

Our Register development team is engaged in continuous user research as part of business-as-usual to continually enhance the Register service (Action C13). To facilitate future changes to the EPC format we have commissioned research into the information, advice, and guidance homeowners need to take action to improve the energy performance of their homes, and the final report for this research will be available soon.

We have amended the estimated costings on the EPC to provide costs over 1 year instead of 3 years (Action C10). We will be identifying information sources on the government website highlighting non-financial benefits of energy efficiency improvements that could be linked to and noted on the Register. We are conducting user research with home buyers and tenants to get feedback on the best options to present this on the Register. Additionally, we will be reintroducing an Environmental Impact Rating (EIR) on the EPC to show the estimated CO2 emission impact of the building on the environment and provide a rating. The reintroduction of the EIR on certificates is expected to be delivered by the end of November 2021.

We have conducted research with Register users to identify useful consumer information about smart meters and the presence of a smart meter that could be highlighted on the Register EPC webpage (Action C12). The EPC energy assessment calculation methodology, Standard Assessment Procedure (SAP), has been amended to allow data on the presence of a smart meter to be captured in the upcoming version of SAP. The near-final update to the SAP 10.2 calculation methodology is currently available (see Progress on ‘An EPC system that delivers accurate, reliable and trusted EPCs’). Following the final release of SAP 10.2 and an update of the EPC format, the presence of a smart meter in a building will be shown on the certificate and the link to the smart meter guidance would only appear when there is not a smart meter in the building.

We have been investigating options for amending EPC recommendations, including those detailed in the Plan, such as the order in which recommendations appear on the EPC and the potential to make recommendations more tailored to the individual property (Action C8). We are continuing to consider options on amending recommendations for inclusion in a consultation on the EPB Regulations in 2022 (see Next steps).

We have been considering the advantages and disadvantages of reducing the validity period of EPCs from 10 years to a shorter period and how this should be targeted and have held discussions with stakeholders to explore potential amendments to the validity period. These options are being considered for inclusion in the consultation on the EPB Regulations in 2022 (see Next steps).

We said we would publish a consultation on the merits of setting requirements for lenders to help households improve energy performance of homes in their portfolios (Action C3). The consultation Improving home energy performance through lenders was published on 18 November 2020 and closed on 12 February 2021. The proposals included setting requirements on lenders to disclose information relating to the energy performance of their portfolios and setting a target for improving that energy performance rating. We are currently considering the feedback received before publishing the government’s response in due course. We also consulted on Improving the energy performance of privately rented homes to EPC Band C by 2028. The consultation proposed to raise the maximum spend landlords are required to invest to £10,000, with the proposed requirements applying to new tenancies from 1 April 2025 and to all tenancies by 1 April 2028. We are finalising the policy design and will be publishing a government response in due course.

We have also held discussions with stakeholders to explore compliance and enforcement amendments (Action C2) and to explore amendments to the validity period of EPCs (Action C14), which is currently 10 years. These will form proposals that will be considered for inclusion in a consultation on the EPB Regulations in 2022 (see Next steps).

We have worked with Schemes to identify opportunities to improve the training and continuous professional development requirements placed upon energy assessors (Action C7). As detailed earlier in this document, we are currently considering options to amend the National Occupational Standards (NOS) for energy assessors on which energy assessor training is based and we will be considering further enhanced assessor training to improve EPC quality. These steps will help us progress both Action C7 and Action R4.

Accurate and up-to-date information tailored to occupants and owners is a key aspect of effectively improving the energy performance of homes. We are committed to continually improving the government provision of energy advice in accordance with research and user needs, and to best support current and future government schemes. We will enhance our digitally led service which includes moving our Simple Energy Advice service to GOV.UK, to improve user experience and help households to improve the energy performance of their homes (Action C9). Therefore, no further development of the current Simple Energy Advice site will take place.

Next steps

We have begun preparations to hold a consultation on potential changes to the EPB Regulations in 2022.This will allow us to progress a number of actions to deliver an EPC that engages consumers and supports policies to drive action. We are developing proposals for possible inclusion in the consultation, to:

• improve EPC accuracy, building on the work we have already completed in this area (Action C1)
• inform our future domestic policy on EPB compliance and enforcement (Action C2)
• amend EPC recommendations (Action C8)
• inform our future domestic policy on the validity periods of EPCs, Display Energy Certificates (DECs) and Air conditioning Inspection Reports (ACIR) (Action C14)

We will also continue to progress the non-regulatory actions in this section.

• We will publish updated EPC guidance that clarifies issues raised in relation to PRS minimum standards (Action C4)
• We will consider the option to amend the National Occupational Standards (NOS) for energy assessors on which energy assessor training is based and consider what further options there may be for enhanced assessor training (Action C7)
• We continue to consider options for amending EPC recommendations, including options to reorder recommendations or provide more information on cost savings and carbon emission savings and ways in which we can better tailor recommendations to a particular building (Action C8)
• We expect to reintroduce the Environmental Impact Rating (EIR) onto the EPC to show the CO2 emission impact of the building on the environment and provide a rating by November 2021 (Action C10)
• DLUHC and BEIS will continue to ensure any future policy changes are reflected on the EPC (Action C11)
• We will update the EPC format following the final release of SAP 10.2 to show the presence of a smart meter in a building on the EPC. The link to the smart meter guidance would only appear when there is not a smart meter in the building (Action C12)
• We continue to engage user research as part of the business-as-usual live service running to continually enhance the Register service (Action C13)
• We will publish the government response to the consultation on improving the energy performance of privately rented homes to EPC Band C by 2028 in due course (Action C2)
• We will publish the government response to the ‘Improving home energy performance through lenders’ consultation in due course (Action C3)

5. A data infrastructure fit for the future of EPCs

This section relates to EPC Actions about questions of access to data, as set out in the Plan, which identified 8 actions to consider on access to EPB data.

As part of meeting the challenge of achieving the UK’s ambitious target for net-zero greenhouse gas emissions by 2050, EPCs have a role to play in providing consumers, building owners and occupiers and third parties with information on the performance of the building stock and supporting effective decisions on improving the energy efficiency of buildings.

It is therefore important that it is easy to access EPC information and link it to other relevant sources of data to allow us to deliver the information that building owners, occupiers, and policy makers need. The data infrastructure for EPCs also needs to continue to evolve to meet future needs.

Progress on ‘A data infrastructure fit for the future of EPCs’

Three of the 8 actions have been completed - Actions D1, D2 and D3 – and work on the remaining actions has commenced.

We said we would publish an extended dataset on Open Data Communities which would include additional data fields permitted in the regulations and that we would build on this to provide improved access to data through the development of the Register (Action D1). The first extended data release of quarterly data was published in January 2021 for the period July to September 2020. This update also included the data for EPCs created since 2008. Updates of the data continue to be released on a quarterly basis and we will continue to consider whether further data can be released in the future based on user research and subject to data protection requirements.

Additionally, we have highlighted and signposted the Simple Energy Advice website on the Register website to help consumers find trusted advice on improving energy efficiency of their buildings, as well as providing additional information and signposting to PRS Regulations and Domestic RHI guidance (Action D3). We will use ongoing user research to identify further links to additional information for consumers that could be added to the EPC. We have also been working with TrustMark to create a Property Hub database allowing property owners access to a ‘logbook’ history for their property (Action D4). This work is being assessed to ensure it conforms to data protection requirements before any launch and we are investigating how the database could be linked to the Register.

As part of the transition to the new Register we said we would make a number of improvements to data processes (Action D5). The Register address data was improved as part of the Register development so that it now uses combination of address lists including from the Post Office Address File (PAF) and Ordinance Survey (OS) geographical locations. As part of this work, we will now publish OS UPRNs (Unique Property Reference Numbers) as part of our quarterly Open Data Communities publication. The first publication of data to include OS UPRNs will be made at the next update, expected in late November 2021, and will continue for each future update. We have further amended address data fields to improve address formatting on the EPC following user research feedback and we will continue to enhance the addressing functions on the Register through ongoing user research.

We have also created statistical releases for the Office for National Statistics (ONS), which releases statistics on a quarterly basis, and we are planning further solutions for enhanced data reporting in the future. We will consider further improvements to EPB data access via open data, with the possibility of the full or near full dataset being released in as up-to-date a form as possible. This would represent a significant Register development and would require amendment of the EPB Regulations. We will be considering the inclusion of proposals on amending the list of data that can be published as part of the consultation on the EPB Regulations in 2022 (see Next steps).

We have held discussions with stakeholders to explore amendments to the EPC opt-out that allows building owners or occupiers to exclude their EPC from appearing in the results of postcode or address-based searches of the Register and in the address level data on our Open Data Communities publication (Action D6). We will consider the inclusion of proposals on amending the Register opt-out function and seek further views in this area as part of the consultation on the EPB (see Next steps).

We have considered the options and feasibility of allowing EPC lodged data to be updated on the Register following changes to a building (Action D7). We are investigating a number of issues that would require resolution to allow this. In particular, we will investigate storing the SAP input data on the Register which is gathered during EPC assessments and is subject to data protection policies.

We have considered the current EPC data structure that is used to store data lodged on the Register, which is Extensible Markup Language (XML), however this is not an editable data format. An option that may allow an EPC to be updated is to allow accredited energy assessors access to data for the amendment and re-lodgement of EPC data to create a new EPC following work to improve a building. We are continuing to investigate options for ‘updating’ lodged EPCs. EPB Regulations require that data on the Register is not amended once lodged. Using previously collected EPC data to produce an EPC for an existing building would be a departure from the present requirement that an EPC is produced from an as-seen assessment of an existing building.

These, and other considerations, mean that updating EPCs already lodged on the Register is a fundamental shift for the energy assessment industry and the Register. This will require major development and would require changes to EPB Regulations around access and amendment of lodged EPC data. We have held discussions with stakeholders to explore options to update EPCs already lodged on the Register. A consultation on the EPB Regulations in 2022 will seek views which will be used to inform our future domestic policy and we will be considering the inclusion of options to amend data on the Register which may allow EPCs to be updated and for EPC data to be reused in part to create a new EPC (see Next steps).

We have been considering the potential pathways for including SMETERs (Smart Meter Enabled Thermal Efficiency Ratings) in RdSAP (Action D8) and further work with stakeholders to address implementation issues is being commissioned, with a plan for reporting by the end of March 2022. This work would address the points identified in the Action Plan, as well as considering new purposes and value chains which in-use performance metrics could support.

As noted in the previous section, we will enhance our digitally led service which includes moving our Simple Energy Advice service to GOV.UK, to improve user experience and help households to improve the energy performance of their homes (Action D2) and therefore no further development of the current Simple Energy Advice site will take place.

Next steps

We have begun preparations to hold a consultation on potential changes to the EPB Regulations in 2022. This will allow us to progress a number of actions to deliver a data infrastructure fit for the future of EPCs. We are developing proposals for possible inclusion in the consultation, to:

• amend the list of EPC data that can be published (Action D5
• amend the Register opt-out function (Action D6)
• inform our future domestic policy on the amending data on the Register to allow EPCs to be updated (Action D7)

We will also continue to progress the non-regulatory actions in this section.

• We will continue to consider whether further data can be released in the future based on user research and subject to data protection requirements (Action D1)
• We will use ongoing user research to identify further links to additional information for consumers that could be added to the EPC. (Action D3)
• We will continue to investigate the delivery of The Property Hub and will work to look at ways to link it to the Register whilst complying with data protection legislation (Action D4)
• We expect to report on the work commissioned to address the SMETERS implementation issues for RdSAP (Action D8)

Annex: EPC action plan progress report

An EPC system that delivers reliable, trusted EPCs

Ref No.	Target for Commencement	Action	Status	Progress
R1	By the end of 2021	We will improve data processes as part of the Register development to enable EPC enforcement authorities to better identify non-compliance and enable better identification of input errors in EPCs.	Ongoing	To improve data processes to enable EPC enforcement authorities to better identify non-compliance and enable better identification of input errors in EPCs (Action R1), we are working on a data warehousing solution to improve the extraction of data from the Register and are undertaking user research with enforcement bodies to identify data/information useful for enforcement. We expect to complete work on a scalable, queryable data warehousing solution to improve the extraction of data from the Register to further progress this action.
R2	By the end of 2020	As part of the Register development, we will consider how consumer information around EPCs can be improved and the necessary limitations of the process better explained, for example by providing a walkthrough of the EPC process and an FAQ section.	Completed	As part of the Register development, we said we would consider how consumer information around EPCs could be improved and the necessary limitations of the process better explained (Action R2). This action has now been completed as the new Register has been developed using a significant amount of user research. All content on the Register website has been designed according to government standards and extensively tested with Register users and a helpdesk service is available to address service users’ questions. A Frequently Asked Questions (FAQ) section has not been provided on The Register website as FAQ pages are not part of government digital services. A Register helpdesk service is available to address service users’ questions.
R3	By the end of 2021	We will investigate how improved quality assurance can improve EPC reliability. In particular, we will look at evidence of the effectiveness of smart auditing processes which were introduced in 2017 and consider ways in which these can be improved further.	Ongoing	We have worked with Schemes to identify opportunities to improve the use of certificate lodgement data to assess and better target smart auditing to check the quality of EPCs. We are developing proposals for possible inclusion in a consultation on the EPB Regulations in 2022 to further the use of, and access to, data to improve the audit of EPCs to raise their quality
R4	By the end of 2020	We will conduct a review of requirements for EPC assessor competence, and work with assessor schemes to tackle poor performance of both assessor schemes, and assessors themselves, including strengthening assessor training, continuous professional development and testing requirements and reviewing the sanctions for poor EPC practice.	Ongoing	We have also worked with Schemes to identify opportunities to improve the training and strengthen the continuous professional development evidence requirements for energy assessors. We will consider the option of amending the National Occupational Standards (NOS) for energy assessors on which energy assessor training is based. Improving the way energy assessments of buildings are carried out should improve the quality of EPCs. We will be considering further enhanced assessor training to improve EPC quality.
R5	By the end of 2021	We will consult on options for the introduction of a new operational ratings scheme for non-domestic buildings. As part of this we will consider how a new operational ratings scheme will align and interact with the existing Display Energy Certificates (DECs) framework.	Completed	The consultation was published on 17 March 2021 and closed on 9 June 2021. The consultation was in two parts: ‘Introducing a performance-based policy framework in large commercial and industrial buildings in England and Wales’ and ‘Introducing performance-based ratings in commercial and industrial offices above 1000m2 in England and Wales: phase 1 of the introduction of a national performance-based policy framework’. A response will be published in due course.
R6	By the end of 2021	As part of Register development, we will improve the existing assessor registration process to ensure unique assessor registration numbers to prevent multiple assessor records. This can help to identify errors where assessors who are suspended, or have been removed from The Register, by an assessor scheme are registered with more than one scheme. This aims to prevent EPC assessors who are banned from practising by one Accreditation Scheme to continue working by switching to another scheme.	Ongoing	We are also working with Schemes to identify the best options to implement unique assessor registration numbers on the Register. Implementing this feature will require significant development and amendment of the present energy assessor membership services on the Register and the revision by Schemes of their membership management processes in order to correctly match individual assessors working for a number of different Schemes. A system of informing all Schemes when one of their members is struck off or suspended is in place and the Register allows Schemes to check whether an assessor applicant was previously struck off by another Scheme. We will continue working with schemes to implement unique assessor registration numbers, which we expect to have in place by July 2022
R7	By the end of 2020	We will investigate whether it is possible to make available in an annex to EPCs the additional information used for calculating EPCs, such as installed measures, so that property owners can sense-check EPCs more easily	Ongoing	We are working with stakeholders and Register service users to develop the presentation of the EPC. Working with stakeholders, and through research with Register service users, we expect to identify a list of features or data items that could be added to an EPC as additional information, while considering any issues of data security on these being annexed to an EPC. We are examining if this additional data could be provided on the EPC or whether there is a more practicable route of publishing this data through other means, such as the Open Data Communities. We will continue to explore whether further data could be annexed to the EPC, or via another route such as the Open Data Communities. If appropriate, we intend to have this in place by the beginning of 2022
R8	By the end of 2021	We will introduce SAP 10.2, an updated version of SAP, which takes into account updated fuel prices, CO2 emissions and primary energy factors and includes monthly variation in these factors. This will refine the assumed heating pattern and summer internal temperature calculations. Other changes include changes to modelling of communal heating, revising solar panel self-use assumptions, and allowing for battery storage with solar panels. An RdSAP update is likely to follow also towards the end of 2021.	Ongoing	The Standard Assessment Procedure (SAP) methodology that is used by energy assessors to produce EPCs for new buildings has been updated (Action R8). The SAP 10.2 update was published by BRE in August 2021 and is available to download now . This is a near-complete edition of the SAP specification that will come into force in 2022. The final updates will be confirmed in the forthcoming government response to a consultation on the treatment of heat networks in SAP and the Future Buildings Standard consultation response, due to be published in December. We are working on an update to the Reduced Data SAP (RdSAP) methodology, used for existing buildings, to follow the SAP update.
R9	By the end of 2021	We will review the changes needed for SAP 11, expected to be rolled out in approximately 2025, to make EPCs a more accurate which could include considering the potential role of SMETERs data in SAP.	Ongoing	We are progressing work to develop SAP 11, the version of SAP due to come into force alongside the Future Homes Standard in 2025. We commissioned a scoping project to explore what SAP 11 should model and how it should do this, which reported back earlier this year; the report has been published. We will be producing detailed proposals for the development of SAP 11 for consultation with interested parties. Following feedback from the consultation the amendments to SAP 11 will be finalised and the methodology updated. The SAP 11 roll-out is expected in 2025. We will also continue to progress work to develop SAP 11, reviewing the recommendations within the scoping report on the future of SAP calculations that was commissioned to support the development, and procuring a delivery partner(/s) to take forward the development project, building on the recommendations in the report
R10	By the end of 2020	We will consider the case for putting in place a formal error reporting system for The Register, for EPC assessors, consumers, Ofgem and assessor schemes to flag up incorrect or fraudulent EPCs and have them investigated. Issues raised could also be fed back into the smart auditing process.	Completed	We said we would consider the case for putting in place a formal error reporting system to flag up incorrect or fraudulent EPCs for investigation and how issues raised in this system could also be fed back into the smart auditing process. Since September 2020, the revised Register service has been operated directly by the government and this has allowed us to have greater oversight of error reporting and helpdesk enquiries, allowing us to respond to these and rapidly amend Register systems and lodgement rules. The new Register has lodgement rules that help prevent lodgement errors by stopping clearly incorrect data being lodged. We are able to alter existing rules and add new lodgement rules to react to new information that we receive to further prevent lodgement errors. Additionally, feedback channels are available on the Register website with agreed escalation points from the service desk, through to assessors, then Schemes and their independent panels. Feedback about the Register itself is received and managed by the government. This has already brought issues to the attention of the Register team that have been dealt with or escalated via other appropriate routes. The Register also has infrastructure in place that allows the logging of patterns of EPB lodgements that could indicate misuse, allowing us to quickly address issues. In the future, we will move towards a system where highlighted errors, issues and patterns of lodgements will be used to inform smart auditing of the Register services.
R11	In 2021	We will review the penalties for EPC non-compliance so that they incentivise EPC compliance and consider options for improved enforcement.	Ongoing	We said we would review the penalties for EPC non-compliance so that they act as an effective deterrent and encourage EPC compliance and consider options for improved enforcement and ways to improve EPC compliance through working with other actors. We have held discussions with stakeholders to explore compliance and enforcement penalties alongside compliance and enforcement amendments. There were issues raised on the level and consistency of penalties between EPB and PRS Regulations. The feedback from stakeholders will form proposals that will be considered for included in a consultation on potential changes to the EPB Regulations in 2022.
R12	In 2021	We will investigate ways to improve EPC compliance through working with other actors such as mortgage lenders and lettings agents, in addition to EPC enforcement bodies.	Ongoing	We said we would review the penalties for EPC non-compliance so that they act as an effective deterrent and encourage EPC compliance and consider options for improved enforcement and ways to improve EPC compliance through working with other actors. We have held discussions with stakeholders to explore compliance and enforcement penalties alongside compliance and enforcement amendments. There were issues raised on the level and consistency of penalties between EPB and PRS Regulations. The feedback from stakeholders will form proposals that will be considered for included in a consultation on potential changes to the EPB Regulations in 2022.
R13	By end 2021	We will consider options for improved oversight and accountability of the whole EPC system to deal with quality, compliance, and potential gaming and fraud issues in a more comprehensive way. This will include reviewing the quality assurance regime and considering new measures to improve EPC fraud detection and prevention. One option could be to fund a National Trading Standards body to oversee EPCs, as is currently done for other trading standards issues.	Ongoing	We have held discussions with stakeholders on options for improved oversight and accountability of the whole EPC system to deal with quality, compliance, and potential gaming and fraud issues in a more comprehensive way. These options are being considered for inclusion in the EPB Regulations consultation in 2022.

An EPC that engages consumers and supports policies to drive action

Ref No.	Target for Commencement	Action	Status	Progress
C1	Ongoing	We will ensure that EPCs are accurate and may be relied upon for use in other government policies which are designed to drive consumers to act, recognising that EPCs alone are often unlikely to change behaviour. Part of the redevelopment of The Register includes moving the service onto GOV.UK URLs, meaning that we become the authority on EPC data.	Ongoing	The new Register service went live on GOV.UK in September 2020 and a post-implementation Government Digital Service (GDS) assessment, required for all new government web services, was passed successfully in November 2020. As detailed in the Plan, this new format for the certificate presents the most important EPC information upfront whilst allowing interested consumers to drill down into further levels of detailed information where relevant. The move to GOV.UK means that the EPC data now has more authority. We have engaged with stakeholders on further options to improve EPC accuracy which are being considered for inclusion in a consultation on the EPB Regulations in 2022.
C2	By the end of 2020	We will consider changes to the EPB Regulations which would improve compliance with Minimum Energy Efficiency Standards in the Private Rental Sector.	Ongoing	We have held discussions with stakeholders to explore compliance and enforcement amendments. These will form proposals which will be considered for inclusion in a consultation on the EPB Regulations in 2022 which will seek views which will be used to inform our future domestic policy on EPB compliance and enforcement.
C3	By the end of 2020	We will publish a consultation on the merits of setting requirements for lenders to help households improve energy performance of homes they lend to.	Completed	The consultation ‘Improving home energy performance through lenders’ was published on 18 November 2020 and closed on 12 February 2021. The proposals included setting requirements on lenders to disclose information relating to the energy performance of their portfolios and setting a target for improving that energy performance rating. We are currently considering the feedback received before publishing the government response in due course. We also consulted on improving the energy performance of privately rented homes to EPC Band C by 2028. The consultation proposed to raise the maximum spend landlords are required to invest to £10,000, with the proposed requirements applying to new tenancies from 1 April 2025 and to all tenancies by 1 April 2028. We are finalising the policy design and will be publishing a government response in due course.
C4	By the end of 2021	We will clarify EPC guidance around two issues that have been raised in relation to PRS minimum standards: - Highlighting the existing powers possessed by Local Authorities to delegate responsibilities to other local authorities, either upper or lower tier, under Section 101 of the Local Government Act 1972, which could help to resolve concerns around EPC and PRS enforcement not being aligned in two-tier authorities. - Making clear that where Houses in Multiple Occupation (HMOs) have been created since 2008 (when the requirement for an EPC was introduced), the whole building is legally required to have an EPC. Additionally, we will investigate what proportion of current HMOs were created before this date and are currently not legally required to have an EPC.	Ongoing	We have also engaged with stakeholders on the ways in which EPC guidance can be clarified to align more closely with PRS Regulations. Following this engagement, the EPC guidance has been updated and will be published in due course. We also expect to investigate what proportion of current HMOs were created before 2008 and are currently not legally required to have an EPC
C5	By the end of 2020	We will consider changes to the EPB Regulations which would improve compliance with Minimum Energy Efficiency Standards in the Private Rental Sector.	Ongoing	See EPC Action Plan C2 Action above which is a duplicate of C5 Action.
C6	Ongoing	As part of The Register development, we will move to an improved presentation of EPC data online which provides data as a URL instead of the current PDF, whilst still providing for a robust offline process to enable legal copies of EPCs and to ensure accessibility for all consumers. This new presentation will present the most important EPC information upfront and allow interested consumers to drill down into further levels of detailed information where relevant.	Completed	The new Register service went live on GOV.UK in September 2020 and a post-implementation government Digital Service (GDS) assessment, required for all new government web services, was passed in November 2020. As detailed in the Plan, this new format for the certificate presents the most important EPC information upfront whilst allowing interested consumers to drill down into further levels of detailed information where relevant. The move to GOV.UK means that the EPC data now has more authority.
C7	By the end of 2020	We will consider what additional training requirements would be needed for assessors in relation to suitability of recommendations in relation to heritage buildings, ventilation, damp, and overheating.	Ongoing	We have worked with Schemes to identify opportunities to improve the training and strengthen the continuous professional development evidence requirements for energy assessors. We will consider the option of amending the National Occupational Standards (NOS) for energy assessors on which energy assessor training is based. Improving the way energy assessments of buildings are carried out should improve the quality of EPCs. We will be considering further enhanced assessor training to improve EPC quality
C8	By the end of 2021	We will review EPC recommendations, which will include the ordering of recommendations and the potential to make recommendations more tailored to the individual property. Better information on the limitations of EPCs and where to go for future advice will be provided. This will also include better information on the potential effects of energy efficiency measures on ventilation, damp, and overheating, as well as the suitability of recommendations for older properties or those in conservation areas.	Ongoing	We have been investigating options for amending EPC recommendations, including those detailed in the Plan, such as the ordering of recommendations and the potential to make recommendations more tailored to the individual property. We will continue to consider options for amending EPC recommendations, including options to reorder recommendations or provide more information on cost savings and carbon emission savings and ways in which we can better tailor recommendations to a particular building. We will be considering the inclusion of proposals on amending recommendations as part of the consultation on the EPB Regulations in 2022.
C9	Ongoing	We will continue to make further improvements to the Simple Energy Advice website, including the facility to model how retrofit works would affect EPC ratings, subject to consumer research.	Completed	We are committed to continually improving the government provision of energy advice in accordance with research and user needs, and to best support current and future government schemes. We will enhance our digitally led service which includes moving our Simple Energy Advice service to GOV.UK, to improve user experience and help households to improve the energy performance of their homes. Therefore, no further development of the current Simple Energy Advice site will take place.
C10	Ongoing	We will improve the presentation of cost data on EPCs, including presenting energy costs over 1 year instead of 3 years, but will also include more details of the non-financial benefits of energy efficiency measures, such as improved comfort and health.	Ongoing	We have amended the estimated costings on the EPC to provide costs over 1 year instead of 3 years. We will be identifying information sources on the government website highlighting non-financial benefits of energy efficiency improvements that could be linked to and noted on the Register. We are conducting user research with home buyers and tenants to get feedback on the best options to present this on the Register. Additionally, we will be reintroducing an Environmental Impact Rating (EIR) on the EPC to show the estimated CO2 emission impact of the building on the environment and provide a rating. The reintroduction of the EIR on certificates is expected to be delivered by the end of November 2021.
C11	By the end of 2020	We will include more up-to-date information about government policy which relies on an EPC rating, such as the current minimum energy efficiency standards for the private rental sector and government EPC targets. We will continue to review this information to ensure it remains up to date.	Completed	We said we would update the EPC format to include more up-to-date information about government policies which rely on an EPC rating, such as PRS Regulations and government EPC targets. This action has now been completed; where an EPC rating is below the requirement set out in the PRS Regulations to allowing the property to be rented out the EPC now indicates that such properties may not be let. We have also engaged with stakeholders on the ways in which EPC guidance can be clarified to align more closely with PRS Regulations. As part of our continuous improvement efforts, we will continue to investigate what further information or metrics about the building’s performance and its compliance with government policy could be added to EPCs. We will continue to review this information to ensure it remains up to date.
C12	Ongoing	We will look at how the existence of a smart meter and other smart technologies can be reflected on EPCs to provide additional information about the features of a property.	Ongoing	We have conducted research with Register users to identify useful consumer information about smart meters and the presence of a smart meter that could be highlighted on the Register EPC webpage. The EPC energy assessment calculation methodology, Standard Assessment Procedure (SAP), has been amended to allow data on the presence of a smart meter to be captured in the upcoming version of SAP. The near-final update to the SAP 10.2 calculation methodology is currently available (see Progress on ‘An EPC system that delivers accurate, reliable and trusted EPCs’). Following the final release of SAP 10.2 and an update of the EPC format, the presence of a smart meter in a building will be shown on the certificate and the link to the smart meter guidance would only appear when there is not a smart meter in the building.
C13	Ongoing	We will carry out consumer research to inform more potentially comprehensive changes to the EPC format in the future. We will investigate the use of behavioural change insights to nudge consumers to make energy efficiency improvements that benefit them.	Completed	Our Register development team is engaged in continuous user research as part of business-as-usual to continually enhance the Register service. To facilitate future changes to the EPC format we have commissioned research into the information, advice, and guidance homeowners need to take action to improving the energy performance of their homes, and the final report for this research will be available soon.
C14	By end 2021	We will undertake careful consideration to the advantages and disbenefits of; reducing the validity period of EPCs from 10 years to a shorter period and how this should be targeted (for example properties where substantive works undertaken have triggered the Building Regulations).	Ongoing	We have also held discussions with stakeholders to explore compliance and enforcement amendments and to explore amendments to the validity period of EPCs which is currently 10 years. These will form proposals that will be considered for inclusion in a consultation on the EPB Regulations in 2022

A data infrastructure fit for the future EPC

Ref No.	Target for Commencement	Action	Status	Progress
D1	Ongoing	We will publish an extended Open Data dataset which will include additional data fields permitted in the regulations; and we will be building on this to provide improved access to data through the development of The Register	Completed	The first extended data release of quarterly data was published in January 2021 for the period July to September 2020. This update also included the data for EPCs created since 2008. Updates of the data continue to be released on a quarterly basis and we will continue to consider whether further data can be released in the future based on user research and subject to data protection requirements.
D2	By the end of 2020	We will update the Simple Energy Advice website to link to the TrustMark website for finding accredited installers and improve the ability to link to financial assistance provided by Local Authorities and energy suppliers under ECO.	Completed	In July 2020 we updated the installer search on SEA to link to TrustMark and MCS accredited installers. We are committed to continually improving the government provision of energy advice in accordance with research and user needs, and to best support current and future government schemes. We will enhance our digitally led service which includes moving our Simple Energy Advice service to GOV.UK, to improve user experience and help households to improve the energy performance of their homes. Therefore, no further development of the current Simple Energy Advice site will take place.
D3	Ongoing	We will consider how to provide additional information to help consumers inform decisions on improving their property by: - improving the signposting from The Register to other relevant information to consumers, such as the Simple Energy Advice website for further advice, the TrustMark portal for information on trusted tradespeople and the PRS exemptions register for checking legal compliance. - considering additional information that consumers may want to access to inform decisions around improving their property and how this can be linked to The Register and the Simple Energy Advice service to form a coherent data infrastructure.	Completed	We have highlighted and signposted the Simple Energy Advice website on the Register website to help consumers find trusted advice on improving energy efficiency of their buildings, as well as providing additional information and signposting to PRS Regulations and Domestic RHI guidance. We will use ongoing user research to identify further links to additional information for consumers that could be added to the EPC
D4	By the end of 2020	TrustMark will launch the new consumer-facing Property Hub for the Data Warehouse, which will allow property owners to access a ‘logbook’ for their property showing works which have been carried out through the government-endorsed TrustMark scheme. We will investigate the potential to link this new database to The Register	Ongoing	We have also been working with TrustMark to create a Property Hub database allowing property owners access to a ‘logbook’ history for their property. This work is being assessed to ensure it conforms to data protection requirements before any launch and we are investigating how the database could be linked to the Register
D5	By the end of 2020	We will have transitioned to the new Register. As part of this transition, we will make the following improvements - Improving addresses on EPCs to include, where possible, OS UPRN numbers to allow The Register data to be compared easily with other government owned datasets - Providing a service similar to the current Open Data access to large EPC datasets, but allowing real-time data to be accessed rather than data being updated retrospectively as is currently the case with Open Data (subject to data protection considerations) - Being more responsive to data requirements. As the keepers of this data resource, we will be able to react quickly to changing requirements for data us within the bounds of data protection requirements	Ongoing	The Register address data was improved as part of the Register development so that it now uses combination of address lists including from the Post Office Address File (PAF) and Ordinance Survey (OS) geographical locations. As part of this work, we will now publish OS UPRNs (Unique Property Reference Numbers) as part of our quarterly Open Data Communities publication. The first publication of data to include OS UPRNs will be made at the next update, expected in late-November 2021, and will continue for each future update. We have further amended address data fields to improve address formatting on the EPC following user research feedback and we will continue to enhance the addressing functions on the Register through ongoing user research. We have also created statistical releases for the Office for National Statistics (ONS), which releases statistics on a quarterly basis, and we are planning further solutions for enhanced data reporting in the future. We will consider further improvements to EPB data access via open data, with the possibility of the full or near full dataset being released in as up-to-date a form as possible. This would represent a significant Register development and would require amendment of the EPB Regulations. We will be considering the inclusion of proposals on amending the list of data that can be published as part of the consultation on the EPB Regulations in 2022
D6	By the end of 2021	We will consider how to resolve the status quo where an individual has opted out of having their EPC data shown on the public register as this is displayed as no EPC existing, rather than showing that an EPC exists but is not displayed, which could be misleading when properties change hands. This will require consideration of data protection requirements	Ongoing	We have held discussions with stakeholders to explore amendments to the EPC opt-out that allows building owners or occupiers to exclude their EPC from appearing in the results of postcode or address-based searches of the Register and in the address level data on Open Data Communities. We will consider the inclusion of proposals on amending the Register opt-out function and seek further views in this area as part of the consultation on the EPB.
D7	By the end of 2021	We will review the necessary changes to The Register required to allow EPCs to be updated following changes to the property. In particular, we will investigate storing on the Register SAP input data gathered during EPC surveys, including necessary data protection policies. This is a necessary first step for creating a more flexible EPC system and allow EPCs to be updated in response to changes in a building.	Ongoing	We have considered the options and feasibility of allowing EPC lodged data to be updated on the Register following changes to a building. We are investigating a number of issues that would require resolution to allow this. In particular, we will investigate storing the SAP input data on the Register which is gathered during EPC assessments and is subject to data protection policies. We have considered the current EPC data structure that is used to store data lodged on the Register, which is Extensible Markup Language (XML), however this is not an editable data format. An option that may allow an EPC to be updated is to allow accredited energy assessors access to data for the amendment and re-lodgement of EPC data to create a new EPC following work to improve a building. We are continuing to investigate options for ‘updating’ lodged EPCs. EPB Regulations require that data on the Register is not amended once lodged. Using previously collected EPC data to produce an EPC for an existing building would be a departure from the present requirement that an EPC is produced from an as-seen assessment of an existing building. These, and other considerations, mean that updating EPCs already lodged on the Register is a fundamental shift for the energy assessment industry and the Register. This will require major development and would require changes to EPB Regulations around access and amendment of lodged EPC data. We have held discussions with stakeholders to explore options to update EPCs already lodged on the Register. A consultation on the EPB Regulations in 2022 will seek views which will be used to inform our future domestic policy and we will be considering the inclusion of options to amend data on the Register which may allow EPCs to be updated and for EPC data to be reused in part to create a new EPC.
D8	Ongoing	As part of The Register development, we will consider potential pathways for including SMETERs in RdSAP (looking ahead to the conclusion of the SMETERs innovation competition in March 2021) and the legal, data access and quality assurance processes which may be necessary. We will consider how the transition to such an approach might be managed and what the impacts would be on other aspects of the EPC system.	Ongoing	We have been considering the potential pathways for including SMETERs (Smart Meter Enabled Thermal Efficiency Ratings) in RdSAP and further work with stakeholders to address implementation issues, including this commitment, is being commissioned, with a plan for reporting by end March 2022. This work would address the points identified in the Action Plan, as well as considering new purposes and value chains which in-use performance metrics could support.