Consultation outcome

Reforms to the Energy Performance of Buildings regime – partial government response

Updated 21 January 2026

1. Introduction

1. This is a partial response to the ‘Reforms to the Energy Performance of Buildings regime’ consultation that was published on 4 December 2024. It deals with proposals on what reformed Energy Performance Certificates (EPCs) will measure and when EPCs will be required. A further response, covering the remaining parts of the consultation on Display Energy Certificate (DEC) validity periods, EPC and DEC data, managing EPC quality, air conditioning inspection reports (ACIRs), and additional questions will be published in 2026. Subject to parliamentary approvals, we intend to bring forward regulations in 2026 to make these changes ahead of implementing new-style domestic EPCs.

2. The Ministry of Housing, Communities and Local Government (MHCLG), supported by the Department for Energy Security and Net Zero (DESNZ), consulted on these changes in line with our commitment to a sustainable future for our built environment, recognising the need to reform the Energy Performance of Buildings (EPB) regime in England and Wales to achieve this. These reforms are integral to creating a regime that supports people in better understanding and managing the energy performance of their buildings whilst achieving key national goals, including reaching net-zero emissions by 2050, alleviating fuel poverty, and enhancing building standards across the country.

3. The consultation ran for 12 weeks, from 4 December 2024 to 26 February 2025. It was published online at GOV.UK and respondents were encouraged to complete an online survey or submit responses via e-mail or in writing. The consultation received over 1,600 responses from a broad range of stakeholders including landlords, homeowners, energy assessors, retrofit installers, financial institutions, consumer rights groups, and the heritage building and short-term let sectors. The consultation posed 48 questions. This partial response includes questions 1 to 21, covering what EPCs measure, and when EPCs are required.

4. We are bringing forward this partial response alongside publication of DESNZ’s consultation on ‘The Home Energy Model: Energy Performance Certificates’, DESNZ’s response to the ‘Improving the energy performance of privately rented homes’ consultation, and publication of the government’s Warm Homes Plan. This follows publication of DESNZ’s response to the Home Energy Model: replacement for the Standard Assessment Procedure (SAP)’ consultation in October 2025.

5. In addition to supporting consumers to better understand and manage the energy performance of their buildings, MHCLG’s planned reforms to EPCs will provide better information to determine eligibility for energy efficiency schemes, whilst supporting compliance with minimum energy efficiency standard (MEES) regulations including reforms outlined in the ‘Improving the energy performance of privately rented homes’ response and proposed in the ‘Improving the Energy Efficiency of Socially Rented Homes’ consultation. These reforms will support the ambition laid out in the Warm Homes Plan, to provide greater clarity to consumers and help them to lower energy bills as we accelerate towards net-zero.

2. What EPCs measure

2.1 We asked

6. Questions 1 to 11 sought views on a set of proposed metrics for assessing the energy performance of buildings to be displayed on reformed EPCs, recognising the existing headline Energy Efficiency Rating (EER) for domestic buildings and Environmental Impact Rating (EIR) headline metric for non-domestic buildings have limitations, including driving unintended outcomes and providing an incomplete picture of energy performance. Question 12 invited views on transitional arrangements from current to reformed EPCs.

7. We requested respondents’ views on using multiple metrics on EPCs, to provide a more complete representation of a building’s energy performance. We aimed to understand the potential of a range of metrics that could be used on EPCs, for both domestic and non-domestic buildings. These included: energy cost, fabric performance, heating system, smart readiness, energy use, carbon, and Smart Meter Enabled Thermal Efficiency Ratings (SMETERs).

8. We proposed that domestic EPCs use four headline metrics: fabric performance, heating system, smart readiness and energy costs, with other metrics provided as secondary information.

9. We proposed that the carbon metric be maintained as the single headline metric on non-domestic EPCs.

10. We also requested respondents’ views on key transition issues, between current and new-style EPCs.

2.2 You said

11. There was broad agreement with the proposal to increase metrics for domestic buildings from key stakeholders including consumer rights groups, the heritage buildings sector, energy assessors, lenders and environmental groups. Many respondents provided a positive response to providing new metrics on EPCs, but were keen to understand more details on the proposed underlying calculation methodology, building on the technical annex included in the consultation.

12. There was conditional support for adding these additional metrics if they could be provided on the certificate in a way that was clear, and did not lead to confusion. Additionally, some respondents wanted reassurance that the metrics were flexible enough to allow new technologies to be incorporated as they become available.

13. There was agreement from large landlord groups of older properties who outlined the expanded metrics would broaden the information available to support retrofit of older properties.

14. Most of the disagreement to the proposals was not focused on the new metrics themselves, but from landlords concerned by the cost of undertaking works to their properties to meet existing and proposed strengthened minimum energy efficiency standard (MEES) in the private rented sector.

15. Particular concerns were raised by the heritage sector, owners of older buildings, and the short-term let sector where installing certain fabric or heating measures might be impractical, costly or not permissible.

16. Owners of short-term let properties felt that the metrics in general would not be representative of their energy performance as the buildings are only used intermittently throughout the year.

2.3 Metrics

17. Question 1 invited views on an energy cost metric. There was recognition that an energy cost metric is responsive to energy prices, which can change over the validity period making the information out of date, whilst it can penalise electric heating systems relative to fossil fuel heating on basis of cost.  Respondents also observed that the current EER rating is not well understood. However, many agreed a cost metric was important to retain given energy costs remain a priority for consumers, as well as businesses when renting properties.

18. Questions 2 and 3 invited views on a fabric performance metric. There was support on the basis that a fabric metric provides an assessment of elements of a building that do not change with external factors, unlike a cost metric. Consumer groups recognised the benefit of a fabric metric as a proxy for how well a building stays warm. Owners of older properties raised concerns that their properties would perform poorly on this metric, and that recommendations for improvements might not be appropriate. Meanwhile, there was recognition that a Fabric Energy Efficiency Standard (FEES) methodology would be consistent with Building Regulations compliance for new construction.

19. Questions 4 and 5 invited views on a heating system metric. There was support in providing consumers with more information about upgrading to a lower carbon heating system, which would be rewarded with an improved EPC rating. However, concerns were raised about the greater cost of running a heat pump relative to a gas boiler and other fossil fuel heating.

20. Questions 6 and 7 invited views on a smart readiness metric. There were mixed views on inclusion of a smart readiness metric, with some respondents requiring more information on how this would work. Meanwhile, there was support in providing consumers with information for smarter and flexible technologies to help decarbonise their homes. Concerns were also raised that smart technologies might not be viable in rural areas with limited internet access.

21. Questions 8 and 9 invited views on an energy use metric.  There was support in providing clear information to consumers on likely energy demand of a property, that is not linked to changing energy costs. There was a preference for delivered energy rather than primary energy, with the latter subject to fluctuations in grid supply rather than energy use in the building. The holiday let sector raised concerns that the energy use metric might reflect actual energy use - which might penalise items like hot tubs or electric vehicle charging – though the metric currently measures predicted energy needs for space heating, hot water, lighting, and pumps and fans rather than plug in appliances. Consumer groups and environmental advisory groups also highlighted there may be limited consumer understanding of energy use metrics.

22. Questions 10 invited views on a carbon metric. There was some support for maintaining the existing carbon-based metric on non-domestic EPCs to support businesses to report on the carbon efficiency of their buildings. Other respondents observed that the current EIR is influenced by the carbon-intensity of electricity generation, which is outside the building owners’ control, meaning it is less useful to drive decarbonisation. Similar to the energy use metric, consumer groups and environmental advisory groups highlighted there may be limited consumer understanding of carbon use metrics.

23. Question 11 invited views on incorporating smart metering technologies, like SMETERs, into the energy performance assessment framework for buildings. Many respondents were unfamiliar with SMETER technology, with responses focusing on the roll-out of smart meters more generally. Some respondents recognised the benefits of collecting real world data to better understand building performance and compare design and in-use performance. Many private landlords, including in the holiday let sector or those in rural communities, suggested SMETER methodologies might not be appropriate for their buildings. Most concerns related to barriers to a universal or mandatory metric based on SMETERs, such as costs, time required for measurement and occupant choice as to use of their data for measurement.

2.4 Transition

24. Question 12 invited views on the transition to reformed metrics. Many landlords, including in the short-term let sector, raised concerns about the application of minimum energy efficiency standards were they to be extended to the sector. Some respondents indicated the need for clear transitional timelines to provide guidance to consumers and certainty for industry, and to support understanding of new-style EPCs and how they interact with existing regulations.

2.5 We will

25. For domestic EPCs, we will replace the existing single cost metric with four new headline metrics: energy cost, fabric performance, heating system and smart readiness. The separate metrics will provide clearer and more useful information to consumers, whilst enabling government to be more targeted in addressing issues such as fuel poverty and net zero, in a way that is not possible with the existing single metric.

26. This change from a single headline rating addresses long-term criticisms, reflected across the consultation responses, that current EPCs are poorly suited to provide consumers with meaningful and actionable information.

27. Providing a broader range of metrics will allow for a more comprehensive assessment of a building’s energy performance, providing owners and occupiers with a wider range of retrofit options.

28. We recognise the concerns raised by the short-term let and heritage sectors about EPC recommendations not being applicable to their dwellings, and will ensure that any PRS MEES regulatory approaches provide sufficient flexibility for properties where certain retrofit might not be suitable, with further detail included in the ‘Improving the energy performance of privately rented homes’ government response.

29. Meanwhile, these additional metrics are expected to also increase the effectiveness of EPCs for older properties, where consultees raised concerns that recommendations may not be applicable to their properties. This is supported by the proposed ‘modular’ approach to energy assessments in existing buildings detailed in the ‘The Home Energy Model: Energy Performance Certificates’ consultation.

30. In addition to the headline metrics, we will include a secondary energy demand metric, based on delivered energy, to provide information on modelled energy usage of a building. We will also retain a secondary carbon-based metric on domestic EPCs, to provide a snapshot of the modelled emissions produced by the building.

31. We recognise the value that collecting real world data on the in-use performance of homes could offer for strengthening the buildings assessment framework. DESNZ are inviting further views on how SMETER measurements could be employed in their The Home Energy Model: Energy Performance Certificates’ consultation.

32. To support the transition to the new-style EPC for domestic buildings, we will retain the legacy EER metric to enable comparison with current EPCs, and to support ongoing compliance with existing regulatory measures until it is no longer required. Meanwhile, we will develop guidance that is clear to understand for consumers and industry to support implementation of new-style EPCs.

33. For non-domestic EPCs, we will maintain the single carbon-based Environmental Impact Rating (EIR) as the headline metric which will support businesses in the net zero transition, enable them to report on their emissions, and facilitate ongoing compliance with non-domestic MEES regulation.

3. When EPCs are required

3.1 We asked

34. Questions 13 to 21 requested respondents’ views on when EPCs are required, to improve access to up-to-date energy performance information across a broader range of property types, and to support delivery of regulation arising from the ‘Improving the energy performance of privately rented homes’ consultation. This includes reducing validity periods for EPCs, and removing flexibilities and exemptions for certain building types.

3.2 Reducing the validity period for EPCs

35. Questions 13 and 14 sought respondents’ views on reducing the validity period of EPCs, and the application of any changes to existing and reformed EPCs. This would allow building upgrades to be captured more frequently through EPCs, and provide prospective buyers and tenants with more accurate information to inform their decision making.

36. The majority of responses were in favour of retaining the existing 10-year validity period. A significant majority of landlords disagreed with reducing the validity period due to the increased cost and administrative burden of commissioning more regular EPCs.

37. Where respondents were in favour of a shorter validity period, the preferred option was five years. Several respondents, including consumer groups, recognised that reduced validity periods would give more up to date energy efficiency assessments of buildings, which empowers prospective buyers and tenants to make more informed decisions. In turn, this was felt to incentivise those selling or letting homes to ensure that buildings are improved, are as energy efficient as possible, and that the EPC is up to date and shows this.

38. Some respondents felt that EPCs should no longer be valid if substantial work has been undertaken on the property, although there was no clear consensus on what definition to use for this. Others stated that people who have made significant changes to their properties are already motivated to obtain a new EPC to demonstrate the improvements made, so there was limited benefit on setting a blanket shorter validity for all.

39. There were some calls for shorter EPC validity periods for properties with lower ratings (e.g. F and G rated properties) whilst those with higher ratings could maintain a 10-year validity.

40. There was concern that the combination of reducing the validity period alongside bringing more properties into the scope of the regime might put additional strain on the energy assessor workforce who may not be able to meet the demand.

41. Lenders also expressed some concern that reducing the validity period of EPCs would reduce the ‘active coverage’ of EPCs and felt that any change should be made together with additional trigger points that would require building owners to obtain new EPCs.

42. Where respondents were in favour of reducing the validity period of EPCs, the majority felt that any change should only apply to reformed EPCs, and that existing EPCs should be able to retain their existing validity period until they expire.

3.3 Requiring a valid EPC through the tenancy period

43. Question 15 requested respondents’ views on whether a new EPC should be required when an existing one expires for all private rented buildings. This would ensure landlords and tenants are equipped with accurate and up-to-date information on the energy performance of their properties, whilst supporting compliance with MEES.

44. Many private landlords and homeowners opposed the proposal, suggesting the existing requirements for an EPC at the start of a tenancy were adequate, and that a new EPC should only be necessary when significant changes are made to buildings.

45. Those in favour recognised the benefit of up-to-date information on energy performance being provided to tenants, and supporting landlords to identify most appropriate retrofit options to support regulatory compliance.

46. More up to date and accurate information was also identified as a benefit to financial institutions, to support them in understanding the energy performance of portfolios or investment opportunities.

3.4 Marketing a building for sale or rent

47. Question 16 requested respondents’ views on requiring a valid EPC before a property is marketed, shifting from the current regulations which allow up to 28 days following marketing for an EPC to be obtained. This change would ensure that buyers and renters have the information available to them at the point of making a purchasing decision, whilst making the requirements clearer.

48. The majority of respondents agreed with the proposal, recognising it is important for prospective buyers and tenants to have access to information on the likely energy performance of a property as part of the decision-making process.

49. Private rented sector landlords and in particular the short-term let sector disagreed with the proposal, highlighting they felt this would impact how properties are marketed and place a significant burden on agencies to ensure compliance.

50. Accreditation schemes and some energy assessors felt that there was sufficient capacity in the assessor workforce that this requirement would not slow down the process of placing a property on the market. Other assessors highlighted there might be practical challenges that might slow properties being marketed where they had exclusive relationships with letting agents and were unable to complete assessments due to leave.

51. Trading Standards bodies felt that this would help them with enforcement for non-compliance by clarifying the requirements, though other respondents raised concerns about capacity and robustness of current enforcement and how this would respond to the change.

3.5 Houses in multiple occupation

52. Questions 17 requested respondents’ views on expanding the scope of EPCs so that a valid EPC is required for an entire House in Multiple Occupation (HMO) when a single room is rented out, which current guidance states is not required. Question 18 invited views on a 24-month transitional period for HMO landlords to obtain an EPC and to comply with MEES regulations.

53. A majority of respondents agreed with the increased scope, which would bring requirements for rooms in HMOs into line with other private rented properties. This would provide renters of rooms in HMOs the same information about these dwellings as other rental properties. Many respondents also highlighted that HMOs tend to house a higher proportion of vulnerable residents, where the quality of accommodation may be poorer, so EPCs and equivalent regulation to other rental properties would support driving up standards.

54. Most disagreement came from landlords, who highlighted that renters in HMOs do not pay for energy costs, and therefore access to EPC information is of limited benefit. However, other respondents highlighted that renters indirectly cover the costs, so this information remains of interest. Some also highlighted that the requirement for an EPC and MEES compliance would add to costs for landlords and tenants.

55. There was a consensus that the EPC should be for the whole HMO rather than individual rooms. Some respondents observed that the EPC calculation methodology may not be suitable for very large HMOs, and that implementing retrofit in HMOs to meet increasing standards might be more challenging due to the need to access rooms rented out by different tenants.

56. A majority agreed with the proposed transitional period for HMO landlords to obtain an EPC to support compliance with MEES, with some expressing preference for a longer transition period, and for this to apply to landlords beyond the HMO sector. Many respondents who disagreed supported a shorter 12-month transition period.

3.6 Short-term rental properties

57. Questions 19 and 20 invited views on the proposal to update regulations to require short-term lets to have a valid EPC in place when let, irrespective of who is responsible for meeting energy costs. Currently there are no specific requirements in regulation, though guidance outlines where EPCs are required.

58. A majority of respondents disagreed with the proposal, with the largest response from short-term and holiday let landlords, highlighting the unique and historical character of their buildings which makes increasing their energy efficiency challenging, particularly if minimum energy efficiency standards were applied in addition to the requirement for a valid EPC. Short-term let owners also indicated holiday guests are not responsible for bills, and therefore have less interest in energy performance.

59. Where respondents agreed, this was on the basis of providing consistency of rules across all rental tenures, supporting owners to better understand the energy performance of their buildings and to identify appropriate opportunities to improve this, whilst improving data on the energy performance of all buildings, irrespective of who was responsible for paying bills.

60. Additionally, some respondents highlighted that more vulnerable tenants may reside in short-term let properties for a longer time period, meaning EPC information could support driving up performance standards for these tenants.

3.7 Heritage buildings

61. Question 21 requested respondents’ views on removing the exemption for landlords from obtaining an EPC for heritage buildings, and thus requiring them to have a valid EPC when marketed, let, or sold.

62. A majority of respondents disagreed with the proposal, with the largest response from landlords and owners of heritage properties including some holiday lets, highlighting concern that recommendations on EPCs were not appropriate for their properties, or that the cost of retrofit was significant, rendering compliance with MEES difficult. The heritage sector also registered concern about the applicability of assessment methodologies to older properties, and the need for assessors to have adequate skills and competence to assess their complex or unique buildings.

63. Many respondents agreed with the proposals, accepting that even though there might be additional complexity with retrofit measures in heritage properties, removing the exemption would provide greater clarity, and provide landlords and consumers with better information on energy performance. Respondents recognised this would support owners with improvements where viable, without impacting protected characteristics or the character of their building.

3.8 We will

64. We intend to maintain the current ten-year validity period for reformed EPCs, whilst existing EPCs will retain their ten-year validity, in recognition of consultation responses highlighting the cost of commissioning EPCs more regularly. Homeowners will still be able to commission an EPC voluntarily to seek information about how they might improve the energy performance of their home ahead of expiry, or to see how home upgrades have improved its energy performance.

65. In light of policy announcements on PRS MEES, we are working to refine the position on requiring a new EPC when an existing one expires for all private rented buildings, to ensure the policy has its intended effect. We will ensure the revised Energy Performance of Buildings and PRS MEES regulations interact effectively to place the right requirements on landlords without incurring undue burdens. MHCLG and DESNZ will engage landlord groups to help shape our plans which we will finalise in the final government response to this consultation.

66. The social rented sector is the subject of a consultation on MEES which closed on 10 September, which the government intend to respond to in early 2026. EPC arrangements for social landlords will be confirmed through that response and as part of the final response to the EPB reform consultation in 2026.

67. We intend to update regulations so an EPC is required at the point of marketing a property rather than the point of sale or rent, which will ensure appropriate information is available to people when making purchasing decisions. We also recognise this will support compliance with the regime, by providing clarity on when a valid EPC needs to be produced.

68. We intend to clarify the scope of the EPC regime by requiring a valid EPC to be provided for a whole HMO when a single room is let, short-term rental properties irrespective of who pays energy bills, and removing exemptions for heritage properties. This will provide greater consistency across the private rented sector, supporting landlords and tenants alike to better understand the energy performance of their buildings and to identify appropriate opportunities to improve them.

69. We acknowledge the concerns raised about the potential incompatibility of retrofit recommendations on EPCs, particularly where MEES applies. However, the EPC itself is intended to provide landlords and consumers with information about energy performance of buildings, with recommendations providing potential ways to improve energy efficiency and reduce energy costs that a building owner might consider as they explore retrofit options. Before proceeding with any works, building owners should seek further expert advice to identify if potential measures are suitable for their buildings.

70. Where MEES applies, exemptions are in place to ensure owners are not mandated to install unsuitable measures, with further detail provided in the ‘Improving the energy performance of privately rented homes’ consultation response. MHCLG and DESNZ will finalise transitional arrangements for when MEES will apply to dwellings brought into scope of the EPB regime in the final response to the EPB consultation.

71. Meanwhile, clarifying the inclusion of these property types will provide a fuller picture of the energy performance of buildings across the country, and support government to identify appropriate interventions to support decarbonisation to suit the needs of different sectors.

4. Next steps

72. We intend to publish the MHCLG and DESNZ response to outstanding consultation questions on when DECs are required, EPC and DEC data, managing EPC quality, ACIRs, and additional questions, in 2026. This will include an update on whether valid EPCs will be required throughout private rented tenancies.

73. This partial response is published alongside DESNZ’s consultation ‘The Home Energy Model: Energy Performance Certificates’, which explores how new-style domestic EPCs will be produced using HEM, and how we will develop the approach to banding the four headline metrics in the reformed regime. We will engage with the sector to support the transition, including ensuring accreditation schemes and assessors are equipped to assess buildings using the new methodology to produce new-style domestic EPCs.

74. Government is working hard to deliver new EPCs from October 2026. We recognise the timeline is ambitious and want to work with industry to build a shared  implementation plan and test our assumptions.

75. This response is also published alongside DESNZ’s response to the ‘Improving the energy performance of privately rented homes’ consultation, and will be followed in early 2026 by the MHCLG’s response to the ‘Improving the Energy Efficiency of Socially Rented Homes’ consultation. Government will continue to engage with landlords across all sectors to ensure they understand the reformed EPC regime, and how existing and reformed EPCs will operate with upcoming regulatory requirements.