Consultation outcome

Improving the energy efficiency of socially rented homes in England: Summary of consultation responses

Updated 28 January 2026

Overview

This document briefly summarises the responses to the consultation on ‘Improving the energy efficiency of socially rented homes in England’ which closed on 12 September 2025. This evidence has been used by government to inform the decisions announced on 28 January 2026 as part of the update on the Decade of Renewal in Social Housing. It is intended as an executive summary and is not intended to replace the full government response which will be published shortly.

The consultation ran from 2 July 2025 to 12 September 2025 and consulted on the following proposals:

• That government should set the Minimum Energy Efficiency Standard (MEES) in the social rented sector (SRS) using new metrics that are proposed following Energy Performance Certificate (EPC) reform which assess the energy performance of buildings based on fabric performance, smart readiness, and the efficiency and emissions of the heating system.
• That MEES should be included in the Decent Homes Standard (DHS) as part of a Criterion D on thermal comfort.
• That the standard will apply to all registered providers of social housing in England and will be regulated by the Regulator of Social Housing (RSH). This will apply to both private registered providers and local authority registered providers of social housing. It does not include properties owned under Low-Cost Home Ownership Schemes (LCHO) such as shared ownership properties. We will refer throughout the document to those in scope collectively as ‘providers’.
• Requires providers to meet a standard using reformed EPC metrics taking a ‘dual metric’ approach meeting the fabric metric at band C and either the heating system or the smart readiness metric.
• Has a compliance date of 2030 to meet the standard, after which it will be regulated by the RSH. This means that we propose to implement MEES sooner than the rest of the new DHS which is proposed to be implemented in either 2035 or 2037.

The consultation also sought views on how MEES will be introduced and implemented. government proposed that:  

• There is a time-limited spend exemption for providers, meaning the maximum a provider would be required to spend to comply with MEES between now and 1 April 2030 is £10,000 per property. If the property still does not meet the minimum standard after the £10,000 expenditure, the exemption would allow providers to delay meeting the proposed minimum standard for a further 10 years from 2030. This would not be a maximum spend, and providers can spend more if they wish.

• Social rented homes achieving EER C against existing EPCs, before new EPCs are introduced, would be considered compliant with the standard until those EPCs expire.

• Social rented homes that meet the existing EER C standard between the introduction of the new EPCs and 1 April 2028 would also be considered compliant with the proposed standard until their EPC expires. This will support providers who already have multi-year projects in train to achieve the current EER C and avoids delaying work to make homes energy efficient.

Government recognised that the proposed standard would be different to that which providers have been working towards (EPC Energy Efficiency Rating (EER) C) and that for some homes, it would be more expensive to meet the new MEES than the EPC EER C standard. Recognising this increased ambition, the consultation also sought views on the suitability of alternative standards. This included using different combinations of metrics, allowing greater provider flexibility over which metric they satisfy or by using a single fabric metric to prioritise warm homes. 

The update on the Decade of Renewal in Social Housing confirms the final standard required of social housing providers in meeting Minimum Energy Efficiency Standards in England. This confirms that post EPC reform metrics will be used to assess compliance with MEES and that a valid EPC will be required to demonstrate compliance. Further detail will be set out in the full government response. 

In summary, social housing providers must:

• Ensure all new and existing social rented properties are at an EPC C or equivalent by 1 April 2030, or for a valid exemption to have been registered. This means to meet EPC C using reformed EPCs against any one EPC metric, at the landlord’s discretion, by 1 April 2030.
• Choose from any of the following proposed EPC metrics at band C: Fabric Performance, Smart Readiness or Heating System. Social landlords will have a choice of what metric is best suited to their stock and will deliver the biggest benefits to their tenants.
• Meet EPC C using reformed EPCs against a second EPC metric by 1 April 2039 (Fabric Performance, Smart Readiness or Heating System) or for a valid exemption to be registered.

A transitionary period will also apply until 2030 meaning properties that meet the current EPC ‘C’ standard by this date and have a valid EPC certificate will also be considered compliant with MEES for the duration of the validity period of that certificate. This is in addition to a time limited spend exemption of £10,000. Further detail on the mechanics of how to apply these exemptions will be published as part of the government response. 

This revised standard has significant benefits for reducing Fuel Poverty and the cost of energy bills for millions of tenants, while giving social housing providers sufficient financial capacity to be able to meet other regulatory duties and build much needed new social and affordable homes. 

Summary of consultation responses

The consultation on ‘Improving the energy efficiency of socially rented homes in England’ received 254 responses. The consultation closed on 12 September, extended from 10 September. All responses received by the extended closing date have been considered. Respondents were not required to answer all the questions in the consultation. A breakdown by type of respondent is set out in Table 1 below:  

Table 1: Summary of respondents

Option	Total	Per cent
Social housing resident	6	2.36%
Local authority registered provider	83	32.68%
Housing association/ private-registered provider	72	28.35%
Leaseholder in a building with social rented homes	1	0.39%
Tenant/ resident representative group	5	1.97%
Landlord/ registered-provider representative group	6	2.36%
Industry body (e.g. National Housing Federation)	13	5.12%
Manufacturer, supplier or supply chain representative body	19	7.48%
Charity, NGO or campaign group	8	3.15%
Public body (e.g. Homes England, Regulator of Social Housing)	0	0.00%
Academia, think tank or any other research organisation	3	1.18%
Standards/ accreditation body (e.g. TrustMark, PAS)	2	0.79%
Finance/ lending organisation	1	0.39%
Government body	3	1.18%
Member of the public (not in social housing)	7	2.76%
Other	25	9.84%
Not Answered	0	0.00%

The consultation asked questions around 4 broad areas of the policy as follows:

• Questions 1 to 4 sought views on the proposed compliance metrics
• Questions 5 and 6 sought views on the proposed compliance dates
• Questions 7 to 12 sought views on the proposed exemptions
• Questions 13 to 19 sought views on the propose transitionary arrangements

Additional questions (Questions 20 and 21) were asked around leasehold considerations that have been considered as part of the final government response, due to be published shortly and Question 22 provided respondents with the ability to provide any further comments on the consultation. 

This document will consider the responses to the 4 main areas of the policy that have been confirmed as part of the update on a Decade of Renewal in Social Housing. 

Metrics

The consultation proposed a preferred option of a dual metric approach, requiring homes to meet a standard for Fabric Performance first and then to meet either the Smart Readiness or Heating System standard.  

The consultation sought views on whether this approach, or one of the four alternative options suggested would be most appropriate. It also asked for suggestions for any further alternative metrics that should be considered. Registered Providers of social housing (RP’s) were also asked to indicate whether they would be more likely to comply with the proposed secondary metric for the majority of their homes under either the Smart Readiness or Heating System metric. This will be addressed as part of the full government response. 

Question 1 asked whether respondents supported the preferred government option of meeting a ‘dual metric’ but prioritising fabric improvements. Overall, respondents were split between with 46.06% of respondents supporting it. Support was lower amongst registered providers of social housing with 49% of local authority registered providers and only 26% of housing association/private-registered providers supporting the proposal. Support amongst social housing industry bodies was also lower than average (31%) whereas 83% of social housing tenants and 80% of tenant representative groups supported the proposals.

The main reasons for not supporting the proposal were around cost concerns, deliverability and uncertainty around the fact that EPC reform had not been confirmed at the point of consultation. There was also a significant number of respondents who noted the approach outlined was too rigid or that additional flexibility in how providers meet the standard was needed.

Social housing industry bodies also highlighted how social housing providers have been working towards meeting current EPC C boundaries and that the preferred approach would represent a significant departure from the approach the sector has been delivering to date, introducing greater risk and higher costs. It is also important to note that amongst some housing providers who responded as supportive of the preferred approach, did so on the condition of support on the right funding and compliance timeframes to ensure deliverability.

Tenant focused organisations highlighted the importance of tenant choice and that measures were installed to improve energy efficiency that clearly benefitted tenants and that this should be taken into account in provider decision making but broadly supported the preferred approach. This was also supported through additional tenant engagement conducted throughout the consultation period, with tenants overall supportive of the changes. Campaigners on Fuel Poverty were strongly supportive of the government’s preferred approach due to additional reductions in Fuel Poverty by 2030 compared to other options.

Questions 2 and 3 sought views on alternative approaches should respondents not agree with the preferred ‘dual metric’ approach. This offered a range of options, from different ways of demonstrating compliance with a dual metric other than a ‘Fabric First’ approach, to less ambitious ‘single metric’ approaches. 

Of those who answered this question, 29% preferred a fabric performance metric only by 2030 (Option 2), but this increased amongst housing providers, where 50% of local authority providers that answered this question and 36% of private registered providers preferring this. The main reasons cited for choosing this option was that this more closely represented existing investment plans and affordability and funding pressures. 

Some responses (28%) chose one of the more flexible approaches outlined in Options 4A and 4B such as allowing provider discretion in which metrics they chose to satisfy. Reasons given for choosing this option was to allow greater flexibility for diverse housing stock where it may be more difficult to pursue a fabric-first approach. Social housing providers Peabody and the G15 outlined in their response how providers should be able to select the most appropriate route to meet the standard to avoid stop-gap or piecemeal works that add cost and disruption to tenants.

Some respondents (25%) to Question 3 also outlined other approaches to be considered, such as an operational or metered performance metric or retaining a ‘cost-based metric’ similar to the current Energy Efficiency Rating (EER) standard.

Compliance date

Questions 5 and 6 sought views on the proposed 2030 compliance date for social homes to comply with MEES. 56% of respondents supported the 2030 compliance date with 38% of respondents who opposed the compliance date representing mixed views. 

Most stakeholders supported some form of EPC C standard by 2030, with the proposed revised compliance metrics being the main causes of concern as this represented an increased ambition on existing EPC ‘C’ plans. Some respondents who expressed support, particularly those responding on behalf of a social housing provider or representative body, were clear that support was conditional on key enablers being in place, such as additional funding or staggered compliance dates. 

A major concern highlighted by some respondents and industry bodies was continuing uncertainty over the exact requirements of the new ‘post reform’ EPC metrics, making planning very difficult. Some respondents doubted that there would be sufficient supply chain and workforce capacity for all homes to meet two metrics by 2030. 

Some large HAs (Riverside/G15/Peabody) suggested a later compliance date of 2037 to allow sufficient time to address hard to treat homes, while others suggested an earlier 2035 date aligning with the proposed Decent Homes Standard.

However, stakeholders campaigning on fuel poverty (such as End Fuel Poverty Coalition) were clear that they could not support any delay from 2030 due to the need to lift as many homes as possible out of Fuel Poverty.

Government response

The government considered the feedback on compliance metrics and the compliance together to arrive to a standard that reflected the responses received. 

The standard will retain the proposed ‘dual metric’ approach where providers should meet EPC C in two post reform metrics, but will have some key alterations to the government preferred approach at consultation as follows:

• Providers will only be required to meet one metric by 2030 rather than two. Providers will be required to meet the second metric by 2039. This responds to the concerns raised about deliverability and affordability, balancing the need for social housing providers to also have sufficient financial capacity to build new social and affordable homes and meet other regulatory commitments, allowing the unexpected additional ambition of the policy to be adequately planned for over a longer period of time.

• Providers will no longer be required to apply the ‘Fabric First’ principle. Social landlords will have a choice of which metric they choose to meet (smart, heat or fabric) by 2030 and 2039 and can therefore consider which metrics are best suited to their stock and will deliver the biggest benefits to their tenants. Where properties have insufficient fabric insulation, we encourage providers to prioritise compliance via fabric upgrades. However, where other metrics could provide greater benefits to tenants - for example greater bill savings - social housing providers will have the flexibility to choose them.

These decisions reflect the need for any standard to be affordable and deliverable, while also upgrading homes for millions of social housing tenants that deserve a safe and warm home.

Exemptions

The consultation proposed that the exemptions outlined in the Decent Homes Standard consultation should also apply to MEES as well as introducing a MEES specific exemption called the ‘Spend Exemption.’ This would cap the required spend on energy efficiency measures, with the government expressing a preference for this to be set at £10,000 in the consultation. This would be time limited and last for a period of 10 years.

Question 7 sought views on the principle of setting this exemption. Generally, most respondents agreed with the time limited spend exemption (77%) with only 13% disagreeing. Common reasons for support suggested it helped with budgeting pressure and supported long-term planning as well as being needed for hard-to-treat property types such as heritage properties, to prevent property disposals if reaching the standard is disproportionately onerous. There were also some practical questions over definitions of the exemption which are not answered here and will be addressed in the full government response.

There were some concerns around ‘gaming’ the system or that even with the exemption, the preferred government approach would present a significant financial burden to social housing providers. There were also some concerns over the duration of the 10-year exemption, with some arguing this was too long.

Question 8 sought views on options for a spend exemption, £10,000 (government preferred), £15,000 or for there to be no spend exemption. 53% of respondents supported the proposal for £10,000 with 20% of respondents choosing £15,000 and 14% specifying other approaches. Only 3% supported there being no spend exemption at all. 

£10,000 was particularly supported amongst registered providers of social housing, with 80% support amongst local authority registered providers rising to 91% of private registered providers. The main reason for support was the affordability of the £10,000 exemption which would be better for social housing provider business plan viability. 

Of those who preferred £15,000, some highlighted that this would mean greater investment in low carbon heating and whole house packages which was cited as costing more than the £10,000 spend exemption. It was also highlighted that a lower spend exemption would lead to a greater number of exempt properties. 

Questions 9 and 10 asked about agreement with the government proposals for the spend exemption to be time limited for 10 years from 1 April 2030. 57% supported this with 33% against. Of those who disagreed with the ten years, there was roughly equal numbers of responses that wanted less than 10 years (19%) and more than 10 years (18%). 

Government response

The government can confirm that it plans to implement a time limited 10 year spend exemption from 1 April 2030 at £10,000. Further details will be available on publication of the government response shortly.

Transitionary arrangements

To recognise early action and provide reasonable flexibility as providers work towards MEES based on the incoming EPC system, a transition period was proposed in the consultation. The consultation proposed that:

• Homes that have already achieved and EPC (EER) rating of C prior to the introduction of new EPCs should be recognised as compliant with the future standard until that expires.

From the date of introduction of new EPC certificates (likely to be in 2026) until 1 April 2028, properties that have already met EPC C on the previous EER methodology will be MEES compliant for the remainder of their EPC validity period.

Many respondents (86%) agreed with the proposal that homes that have already achieved an EPC (EER) rating of C prior to the introduction of new EPCs should be recognised as compliant with the future standard until their current EPC expires or is replaced, as part of the proposed transition approach for SRS MEES. This included 98% of social housing providers (including 98% of local authority registered providers and 97% of housing association/private-registered providers), 50% of social housing tenants and 62% of industry bodies. 

Some respondents noted that the proposed approach would provide clarity and stability during the transition to the new EPC framework while others noted that the proposed transition would allow providers to plan upgrades and improvements in a phased and strategic manner, rather than needing to reassess or retrofit properties already at EER C.

Respondents supported the proposal that properties that have achieved EER C from the introduction of new EPCs until 1 April 2028 should be considered compliant until the property’s EPC expires, after which they would need to comply with MEES, as part of the proposed transition approach for SRS MEES. Many respondents (78%) agreed with this aspect of the transition approach, including 85% of social housing providers, 50% of social housing tenants and 46% of industry bodies. 

Of respondents who did not agree with this aspect of the transition approach, the most common reason was delaying necessary works for tenants. A few respondents expressed concern that the approach could delay necessary improvements, potentially creating a two-tier system of properties on the old and new standards.  

Some industry bodies represented views from their members that it would be helpful to extend this transitionary period to 2030, given that current EPC C boundaries have been reflected in provider business plans and continued uncertainty on the requirements of new metrics meaning it will create significant uncertainty for housing associations and others.

Government response

Responses show that the broad principles underpinning the transitionary proposals were widely supported.

Given this, the government can confirm that homes that are already EPC C compliant and have a valid EPC that demonstrates this issued prior to the introduction of new style EPCs will be able to use that certificate to demonstrate compliance with the future standard until that EPC expires.

The government also proposed an additional transition period after the introduction of new style EPCs between 2026-28. These certificates will display both old and new methodologies for comparative purposes. This was to ensure that providers who are currently working toward EPC C standards but have not yet achieved them were able to benefit from the transitionary arrangements.

Giving feedback, the government has decided that the 2028 end date should be extended to 2030. This will ensure that social housing providers are able to deliver the standard. While we expect that the vast majority of homes that meet the current EPC C standard will also meet one of the post reform metrics, given that this won’t be confirmed until later in 2026, we want to give social housing providers confidence that they can proceed with their current business plans to 2030. This will also ensure sufficient confidence that the sector can meet other regulatory requirements and have sufficient clarity to be able to accelerate social and affordable house building.