Research and analysis

Energy Performance of Buildings Regulations 2012: Post-implementation review 2018 to 2023

Published 2 April 2026

Applies to England and Wales

© Crown copyright 2026

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Introduction

1. There is a statutory requirement in the Energy Performance of Buildings (England and Wales) Regulations 2012 for the Secretary of State to undertake a review of the regulations every 5 years and to publish the conclusions of the review in a report. This Post-Implementation Review (PIR) fulfils that requirement and covers the 5-year period from 2018 to 2023.

2. The regulations state that the report must in particular:

  • set out the objectives intended to be achieved by the regulations;
  • assess the extent to which those objectives are achieved and assess whether those objectives remain appropriate and if so, the extent to which they could be achieved with a system that imposes less regulation. In carrying out the review the Secretary of State must, so far as is reasonable, have regard to how Directive 2010/31/EU of the European Parliament and of the Council on the energy performance of buildings of 19 May 2010 (recast) is implemented in other member States.

Background

3. The Energy Performance of Buildings (England and Wales) Regulations 2012 (EPB Regulations), as amended, implemented the Energy Performance of Buildings Directives 2002/91/EC, 2010/31/EU and 2018/844/EU. The EPB Regulations consolidated the Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations 2007 (“the 2007 Regulations”) with subsequent amendments to them since they came into force.

4. The EPB Directive was designed to increase the energy efficiency of buildings, reduce their carbon emissions and lessen the impact of climate change. At the time the EPB Regulations were implemented emissions from buildings accounted for 40 - 45% of all carbon emissions in the UK and the regulations supported the carbon reduction targets in the Climate Change Act 2008.

5. The EPB Regulations require that energy certificates are produced at specific trigger points to provide information on energy performance in buildings to help support people to make decisions. They must also contain recommendations for improving energy performance. Full details of the objectives of the EPB Regulations and of the requirements that they impose for the production of energy certificates are provided in Annex C.

Format of the review and key findings

6. An in-house review was carried out using a range of evidence on how the EPB Regulations have been implemented. The attached PIR (Annex A) explains the issues in detail and supporting evidence used in the review is contained in Annex B. The key findings can be summarised as follows:

  • There have been improvements to the energy efficiency of the building stock over the period 2018 to 2023, but it has not been possible to directly attribute this to the EPB Regulations, particularly as the regulations are primarily an enabling policy designed to support and inform decision making around building transactions and retrofit, rather than specifically requiring that actions are taken.
  • EPCs appear well embedded in the property transaction process for both selling and rental markets, with 10,163,120 EPC lodgements over the period. The information provided on EPCs allows prospective buyers and renters to compare the energy performance of buildings that they have under consideration.
  • There is evidence included in the English Housing Survey 2022-23 of direct benefits attributable the EPB Regulations in terms of improving the energy performance of buildings. This survey found that of those people who remembered seeing their EPC and were recommended improvement works, 57% reported acted on the improvements suggested.
  • There is evidence of indirect benefits to the improvement of the energy performance of buildings attributable to the EPB Regulations in the adoption of EPCs as the tool used for setting minimum energy efficiency standards for the private rented sector and as part of the eligibility criteria for some government capital grant funds for installing energy efficiency and decarbonisation retrofits. In addition, private sector lenders are offering favourable terms on certain mortgage products based on EPC ratings.
  • Cost of certificates continue to be low, relative to the other costs involved in a property transaction, with estimated average costs of £70 for domestic EPCs, £395 for non-domestic EPCs and £400 for DECs. There are no cost figures available for ACIRs. Given the validity period of EPCs, these costs might only be incurred once every 10 years.
  • There continues to be room to improve the accuracy, reliability and trust in the regimes, and an EPC Action Plan was launched in September 2020 containing recommendations for changes specifically to address these issues.
  • New policies, such as private rented sector minimum energy efficiency standards (PRS MEES) and government funded decarbonisation schemes, have utilised the EPC as a benchmark for which it was not initially designed. This has led to calls by industry stakeholders and the Climate Change Committee (CCC) for changes to the EPB regime, including changing the headline metric on certificates so they can more effectively support government objectives on Net Zero, clean heat, and fuel poverty. Tenure trends in the English Housing Survey show the PRS has homes with some of the lowest energy efficiency, which stronger MEES standards based on EPCs can help address.

Next steps

7. A consultation on reforms to the EPB regime was launched in December 2024, in part to address the findings of this post-implementation review. This included proposals on changing domestic EPC metrics to provide more useful and actionable information for consumers, by better representing distinct elements of a home’s energy performance, and to support our ambition to deliver Net Zero by 2050, alleviate fuel poverty, and enhance building standards. We sought views on clarifying requirements for heritage buildings, houses of multiple occupancy (HMOs) and short-term lets, to consistently provide information on their energy performance and support owners on improvements and consumers to make purchasing decisions. We also proposed changes to the sharing of EPB data, on measures to improve the quality of EPCs, and improvements to DECs and ACIRs. An impact assessment was published alongside this consultation.

8. In January 2026 we confirmed our intention to introduce 4 new headline metrics for domestic EPCs – fabric performance, heating system, smart readiness, and energy cost – whilst retaining the existing headline non-domestic metric, whilst updating on where EPCs will be required. A further response is planned in 2026 confirming the government’s position on outstanding elements of the December 2024 consultation, alongside an updated impact assessment.

9. A new primary power to allow amendment of the EPB Regulations was secured in October 2023 via provisions in the Energy Act 2023, following the UK withdrawal from the European Union at the end of December 2020. This will enable government to make regulatory changes proposed in the consultation once finalised, subject to parliament approvals.

10. Additionally, in January 2026 government responded to the February 2025 consultation on raising PRS MEES standards. This confirmed that from October 2030 this will be based on a dual-metric standard, with a fabric performance standard first followed by landlord discretion to meet either a heating system or smart readiness standard on reformed domestic EPCs. This reinforces the continued importance of EPCs to wider decarbonisation policy beyond their core informational purpose.

Annex A: Post-implementation review

Title: Energy Performance of Buildings Regulations 2012 – Post-Implementation Review - 2018 to 2023

PIR No: RPC-MHCLG-26131-PIR(1)

Original IA/RPC No: MHCLG 1051 (Impact Assessment for the EPB Regulations 2012)

Lead department or agency: MHCLG

Contact for enquiries: Harrison.cutler@communities.gov.uk

Date: 3 February 2026

Type of regulation: EU

Type of review: Statutory

Date measure came into force: 9 January 2013

Recommendation: Amend

RPC Opinion: Green

1. What were the policy objectives of the measure?

These regulations implement the Energy Performance of Buildings Directives 2002/91/EC, 2010/31/EU and 2018/844/EU and they incorporate the policy objective from the Directives. These are to improve the energy efficiency of buildings, reduce the carbon emissions of buildings, and lessen the impact of climate change.

2. What evidence has informed the PIR?

An EPC Call for Evidence was published by government in 2018 which resulted in the publication of an EPC Action Plan in September 2020. The EPC, DEC and ACIR ratings and recommendation reports, including trends over time have been considered. The English Housing Survey (Energy Report) 2021-22 contains statistics on the EPC ratings of homes. The State of the State Report 2021-22 contains information on public sector buildings. Directive 2018/844/EU was consulted on in 2020. See Annex B for full details.

3. To what extent have the policy objectives been achieved?

Energy certificates are well embedded into the property transaction process, supporting people to compare the likely energy costs associated with taking on different properties. As they are primarily information tools to support people making decisions, improvements in energy efficiency cannot be attributed to the regulations directly. However, there are direct contributions attributable to certificates influencing the purchase, rental and retrofit of buildings and indirect contributions from enabling other government policies, such as energy efficiency capital grant schemes and minimum energy efficiency standards. In 2024 we consulted on reforming the regime, including introducing new complementary headline metrics to domestic EPCs, bringing more building types into the scope of requiring EPCs, intended to better deliver the objective of supporting consumers to increase the energy efficiency and reduce emissions of buildings.

Sign-off for Post-Implementation Review: Chief Economist and Minister

I have read the PIR and I am satisfied that it represents a fair and proportionate assessment of the impact of the measure.

Signed:  Stephen Aldridge, Chief Economist                                             Date: 25 March 2026

Signed:  Samantha Dixon MBE MP, Parliamentary Under Secretary of State
Date: 25 March 2026

Further information sheet

Please provide additional evidence in subsequent sheets, as required.

4. What were the original assumptions?

The 2012 IA on Recast of the Energy Performance of Buildings Regulations assumed EPC costs were £50 and £800 to £1,000 (in 2012 prices) for a domestic EPC and a non-domestic EPC respectively.[footnote 1] Updated information gives a domestic EPC cost of roughly £70 and an average non-domestic EPC cost of £350, with a range of £195 to £2,000 (both in 2024 prices).[footnote 2] There was an assumption that energy certificates, including recommendation reports, would provide information that would drive building owners to improve the energy efficiency of their buildings. Analysis of data from the English Housing Survey indicates that EPCs provide information that encourages building owners to undertake energy efficiency improvements.

5. Were there any unintended consequences?

Unintended consequences have been minimal and relate to the changing use of EPCs as a benchmark for policies beyond the purpose for which they were originally designed. The EPC was designed to provide an assessment of the energy efficiency of a building alongside recommendations about how to improve it. Over time new policies have used the EPC as a benchmark for which it was not designed such as domestic decarbonisation policies. This has led to calls by industry stakeholders for changes to the EPC, including for example, increased metrics in the certificates.

6. Has the evidence identified any opportunities for reducing the burden on business?

Businesses are required to have a valid EPC at the point of marketing a property for sale or rent and those with an air conditioning system in scope must obtain an ACIR. Requiring building owners and occupiers to acquire energy certificates about improving the energy efficiency of their buildings, how to reduce energy consumption and carbon emissions, through EPCs, DECs and ACIRs, will achieve cost savings and may encourage additional actions by proposing improvements that could be made to the building’s fabric or services. Whilst we believe the mandatory requirements of the regulations should be retained we are making progress in improving the EPB framework to ensure it is clear to businesses what their responsibilities are and the details on how to improve their energy performance is accurate and reliable. We intend to update the Regulations to make them work better for business.

The updated digital Energy Performance of Buildings Register services has already helped individuals and businesses to have easier access to energy certificates. It provides clear information on compliance with minimum energy efficiency standards and links to further information to improve their buildings. including the obligations on the owner or landlord to make an EPC available to the prospective buyer or tenant for a building that is sold or rented out.

7. How does the UK approach compare with the implementation of similar measures internationally, including how EU member states implemented EU requirements that are comparable or now form part of retained EU law, or how other countries have implemented international agreements?

All Member States have established EPB regimes. It is left to Member States to choose the regime which corresponds best to its specific situation as long as the general principles of EU legislation are observed. By 2020 there were approximately 6 million domestic EPCs being issued annually across the EU, with the UK leading the way with more than 20 million EPCs registered in total. The UK was at the time one of the few Member States with a Register for lodging EPCs.

Annex B: Supporting evidence for review

11. This annex includes the supporting evidence used whilst undertaking this post-implementation review (PIR). It is laid out to match the sections of the PIR in Annex A.

1. What were the policy objectives of the measure?

12. The EPB Regulations have 3 policy objectives:

  • improve the energy efficiency of buildings
  • reducing the carbon emissions of buildings, and
  • lessening the impact of climate change

13. The regulations aim to do this through a number of measures including structured assessments and reporting on aspects of buildings which have a bearing on their use of energy such as the construction style, the fabric used, insulation measures and the predicated performance of fixed building services for lighting, hot water, heating and cooling. Additionally, the reports contain recommendations which provide owners with optional actions and improvements that they may make to increase the energy efficiency of their building.

2. What evidence has informed the PIR

14. The previous PIR for the EPB Regulations published in May 2020[footnote 3] was considered and the progression of its findings in improving the Energy Performance of Buildings (EPB) regime are noted in this report for the period January 2018 to January 2023. Some areas for improvement of the EPB regime identified in the previous PIR were taken forward through an EPC Call for Evidence[footnote 4] in 2018. In September 2020, the government published an EPC Action Plan[footnote 5] detailing a series of commitments to maximise the effectiveness of Energy Performance Certificates (EPCs) as a tool for improving the energy performance of buildings, engaging consumers and creating a data infrastructure fit for the future. The EPC Action Plan set out a wide-ranging programme of improvements to the EPB regime so that it produces accurate, reliable and trusted EPCs. In November 2021 an EPC Action Plan Progress Report[footnote 6] was published detailing the significant progress made thus far in delivering the commitments within the EPC Action Plan. The government is continuing to deliver the outstanding actions and is considering future reforms to the regulations in support of this.

15. The numbers of EPCs, Display Energy Certificates (DECs), Air Conditioning Inspection Reports (ACIRs) and Recommendation Reports produced and the trends shown in the energy efficiency ratings of buildings over time were considered. This includes the use of evidence from the English Housing Survey (Energy Report) 2021-22,[footnote 7] for example evidence on the improvement of energy performance of dwellings which identified that the proportion of A to C rated dwellings increased from 16% in 2011 to 47% in 2021, while the proportion of the least energy efficient dwellings (E to G rated) decreased from over a third of dwellings (35%) in 2011 to one in ten dwellings (10%) in 2021.[footnote 8]

16. Information from the State of the Estate Report 2021-22[footnote 9] was noted relating to energy efficiency in some public buildings.

17. Data from the EPB live table DEC1[footnote 10] for the period 2018 to end of 2022 showed that there were 167,000 (rounded to the nearest 1,000) DECs lodged in England and Wales on the EPB Register. DECs provide an indication that energy efficiency and energy usage in some public buildings that are frequently visited by the public have improved during the period covered by this report. In 2018 the proportion of DECs for buildings rated from A+ to C was 36%, by 2022 the proportion had increased to 43.4%.

18. Data from the EPB live Table A: Non-Domestic EPCs in England and Wales by energy performance asset rating[footnote 11] for the period 2018 to end of 2022 showed that there were 457,000 (rounded to the nearest 1,000) non-domestic EPCs lodged on the EPB Register. These EPCs provide an indication of the improvement in the energy efficiency of non-domestic buildings and that it has improved during the period covered by this report. In 2018 the proportion of non-domestic EPCs for buildings rated from A+ to C was 42.7% by 2022 the proportion had increased to 65.7%.

19. In 2020 in response[footnote 12] to the government consultation on the transposition of Directive (EU) 2018/844 which further amended the previous recast of the EPB Directive, it was decided following industry engagement, evidence from stakeholder responses and consideration of the cost benefit analysis, within the context of government’s wider climate change targets, to retain the existing threshold for the inspection of the energy efficiency of air-conditioning systems that have an effective rated output of more than 12kW and to diverge from the European Commission’s proposal to increase this threshold from 12kW to 70kW. The consultation recognised that some carbon savings would be lost from smaller systems and that energy assessors would undertake fewer inspections.

3. To what extent have the policy objectives been achieved?

20. The 3 objectives of the Energy Performance of Buildings (England and Wales) Regulations 2012 (as amended) (set out in the Explanatory Memorandum to the Regulations) are each considered below.

Improve the energy efficiency of buildings

21. The EPB Regulations have met the objective of improving the energy efficiency of buildings as energy certificates, particularly as EPCs have become embedded in the property transaction process. EPCs are a key source of information by providing energy efficiency assessments to building owners and potential buyers/tenants of a building in order for them to have information at the point a building is constructed, sold or let so they can consider making energy efficiency improvements to their buildings. The property market and property businesses use energy certificates to inform potential buyers and tenants of the energy efficiency of their potential purchase.

22. Recommendations are provided as part of the energy certificate assessments that identify suitable energy efficiency improvements. The English Housing Survey 2022-23[footnote 13] suggests 61% of households who moved after the introduction of EPCs remembered seeing an EPC before moving into their home. Of those that remembered seeing their EPC and were recommended improvement works, 57% reported carrying out works.

23. The English Housing Survey 2021-2022 noted that there was a substantial improvement in the EPC ratings of owner-occupied dwellings which increased on average from 56 SAP points in 2011 to 66 SAP points in 2021. Dwellings in the social rented sector (SRS) had an average SAP rating of 63 (D rating) in 2011 and 70 (C rating) in 2021. The English Housing Survey 2022 noted that there was a substantial improvement in the energy efficiency of private rented dwellings, which increased by 10 SAP points, from 55 in 2011 to 65 in 2021. The proportion of the least energy efficient dwellings (rating of E to G) in the private rented sector decreased from 41% in 2011 to 14% in 2021. Some of this improvement will be because of other government policies or natural replacement.

24. EPCs have been increasingly used as benchmarks for access to government grant programmes to target energy efficiency funding at the most energy inefficient buildings to help reduce energy use and energy costs in buildings, help to tackle fuel poverty and reduce greenhouse gas emission to net zero by 2050. Programmes that have used the EPC to help target energy efficiency improvement funding include the Energy Company Obligation scheme (ECO), the Home Upgrade Grant (HUG), Boiler Upgrade Scheme grant (BUS) (via local authorities), Social Housing Decarbonisation Fund and the Sustainable Warmth Competition (via local authorities).

25. The EPB Register service and energy certificates have been enhanced through the adoption of the government digital register service and user focussed amendments to the formatting of energy certificate information. This has improved accessibility and user understanding of the energy efficiency information to encourage informed decision-making for building owners when considering improving the energy efficiency of their buildings. The English Housing Survey 2022 estimated the average annual energy cost saving of bringing a dwelling up to band C was £285 per year.[footnote 14]

26. The EPB Regulations have also improved access to EPB data allowing expansion of the use of the data and broadened the focus on energy efficiency of buildings to areas of research and finances (mortgages and financial services) and allowed targeted policies and grant schemes to improve energy efficiency of the least energy efficient buildings. EPB data is also published as open data[footnote 15] which is made available for data analysis to enable independent research into energy efficiency issues including fuel poverty and climate change. More energy certificate data is being added to the open data communities website and the frequency of data updates has been increased to monthly to provide access to more up to date energy certificate information from the open data communities website. Access to energy efficiency data is a key driver to encouraging decision making on improving the energy efficiency of buildings.

27. Amendments to the EPB Regulations provided greater access to open data and increased items of data being published. This was to encourage access to data on energy efficiency of buildings to be used by business to drive improvements, such as use of data by mortgage lenders as there is a need for them to account for the energy efficiency of their mortgage books or by landlords and property owners to have the opportunity to use open data to model energy efficiency improvements in their buildings. Access to EPB data was also designed to encourage research into improvements of building energy efficiency and to encourage research to identify poor energy efficient homes and types of buildings and where these are located. This type of research could allow policies to be targeted to improve energy efficiency of these types of buildings.

28. From September 2020 the EPB Register on which energy certificates are lodged was transitioned from a contracted third-party provider to a MHCLG in-house digital service and hosted on the HM Government website at: https://www.gov.uk/find-energy-certificate. The digital EPB Register service allows better access for energy certificate users allowing them to search for energy certificates by reference number or by address/postcode and to search for accredited energy assessors in their area to undertake assessments. The format of the energy certificates and recommendation reports was also redesigned and enhanced on the digital register service following extensive engagements with users to make the certificates easier to understand and use. This is designed to enhance the access and engagement of EPB Register users to encourage users to understand the energy efficiency information and recommendations on the certificates. Engagement with users is ongoing to continue enhancing the EPB Register services to encourage user engagement with the energy certificates and recommendations.

29. The UK government uses the EPC rating as a key benchmark for providing grants and incentive schemes to improve the energy efficiency of the lowest rated buildings to reduce energy use and costs and help reduce fuel poverty and tackle the most energy poor homes. As part of proposed reforms to the EPB regime government is considering amending regulations requiring EPCs for Houses in Multiple Occupation (HMOs) and heritage buildings. These buildings can be the least energy efficient and EPC information will provide opportunity for building owners and tenants to identify low energy efficiency and recommend potential energy efficiency improvements. The proportion of the least energy efficient dwellings (E to G) decreased over the last 10 years from over a third of dwellings (35%) in 2011 to one in ten dwellings (10%) in 2021.[footnote 16] The English Housing Survey is a continuous national survey of all dwellings in England. The EPB Register covers around 60% of dwellings in England as not all have an EPC (these are only required when a dwelling is constructed, sold or let). While the key inputs to calculate an energy efficiency rating are the same for an EPC and ratings produced by the English Housing Survey (EHS), the data collection methodology for calculating it differs. For new dwellings the EPC uses the Standard Assessment Procedure (SAP) and for existing dwellings the Reduced Data SAP (RdSAP). The EHS predominantly uses RdSAP inputs but includes some full SAP inputs where the additional detail is collected in the EHS.

30. The State of the Estate Report 2021-2022[footnote 17] provides an assessment of the government property portfolio that is one of the largest and most diverse in the UK. The report uses EPC ratings as the benchmark of energy efficiency of the estate. The State of the Estate report includes assessment of government properties across all government areas such as health, schools, defence, prisons and probation centres, job centres, etc as well as government offices. The report fulfils a requirement in the Climate Change Act 2008 to assess and report on the energy efficiency of the buildings in the government estate including to report on the energy efficiency of newly acquired buildings.

31. Government departments continue to take significant strides in decarbonising their estate. There has been a 35% reduction in the greenhouse gas emissions from the government estate buildings since the 2017-18 baseline. During 2021-22 there were 291 acquisitions across the government estate adding approximately 530,000 m2 of floorspace; 97 of these acquisitions did not require an EPC due to operational reasons or lease renewals of existing government buildings.[footnote 18] Of the 194 acquisitions in-scope for an EPC, 79 or 41% were rated outside the top quartile for EPC energy efficiency.

32. Increasingly organisations such as financial institutions use EPCs and energy ratings of buildings to report on their own net zero targets such as the energy efficiency of the properties on their mortgage books. Financial institutions may also provide better financial rates for buildings that are more energy efficient. Access to data also drives research from academics on energy efficiency in buildings which helps to inform on where energy efficiency measures could have the greatest improvement in buildings.

33. Air conditioning systems or combined air conditioning and ventilation systems with an effective rated output of over 12kW are required to be assessed for energy efficiency under the EPB Regulations every 5 years. There is limited information on the compliance rates and levels of energy efficiency improvements that may be facilitated by these ACIRs.

34. Industry stakeholder feedback in 2020 identified an estimated compliance rate with ACIR requirements of fewer than 20% of in scope air conditioning systems with an effective rated output of more than 12kW.[footnote 19] Industry feedback in 2020 also identified that around 60% to 80% of current air conditioning assessments were undertaken on systems that had an effective rated output of between 12kW and 70kW. Therefore, even though the Energy Performance of Buildings Directive 2018/844/EU sought to raise the inspection level for ACIR to those with an effective rated output of over 70kW, it was decided, following consultation and industry feedback, to maintain ACIR inspections on air conditioning and combined air conditioning and ventilation systems with an effective rated output of over 12kW.

35. Although this may be considered a burden on businesses required to continue to have an ACIR for the lower output systems, the inefficient running of building systems would itself be an ongoing burden on businesses that could be addressed through them having the information and recommendations in an ACIR. We are aware of the low compliance rates of ACIR. We consider these to be lost opportunities for building owners to be provided with assessments of the energy efficiency of these systems and recommendations of how they may be improved or better managed to improve their energy efficiency, reduce energy use and cost of energy to the business/building owner.

36. Increases in compliance would provide the building system owner with an assessment and recommendations that can facilitate energy efficiency decisions. The importance of improving ACIR compliance is likely to become more significant as numbers of heat pumps are installed in buildings in the future as reversible heat pumps are captured under the air conditioning requirements in the EPB Regulations.

37. The Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 (‘the PRS Regulations’) establish a minimum level of energy efficiency for privately rented property in England and Wales. Landlords of privately rented domestic properties must ensure that their properties reach at least an Energy Performance Certificate (EPC) rating of E. From April 2018 landlords were required to respond to the regulations for new, renewed and extended tenancies only. From April 2020 this has been extended to all tenancies. The Energy Performance of Buildings (England and Wales) Regulations 2012 provide the EPC system that facilitates the PRS Regulations but have not directly contributed to the cost and carbon savings in the PRS stated below.

38. Overall, the analysis[footnote 20] found that the PRS regulations have had a statistically significant impact on the energy efficiency of private rental sector (PRS) properties in England and Wales. By comparing trends in energy efficiency in England and Wales with Scotland, where there were no equivalent regulations, the analysis found that the average impact of the PRS regulations on the energy efficiency of PRS properties is estimated to be an increase of 5 SAP points (on the 1 to 100 SAP scale used in EPCs to measure energy efficiency).

39. The PRS Regulations are also estimated to have resulted in an average assumed reduction in fuel costs of around £120 per year for an individual property.[footnote 21] There are similar positive findings on the estimated impact of the regulations on CO2 emissions. For individual properties this is an average assumed annual reduction of up to 500 kg CO2. Find further information on the PRS Regulations

40. From the lodgement data from the EPB Register in England and Wales the average monthly SAP rating for the energy efficiency of new dwellings in October 2020 was 77.4, EPC Energy Efficiency Rating (EER) C and by September 2023 this average had increased to 82.34 EPC EER B. For existing dwellings, the average EPC EER in October 2020 was 59.47 (EPC D) and in September 2023 the average EPC EER was 66.81 (EPC D), though close to EPC C rating20. For non-domestic buildings in England and Wales in October 2020 the average EPC EER in October 2020 was 71.83 (EPC rating C) and in September 2023 was 61.91 (EPC rating C). The EPC rating B is assessment level between 50 and 25.21 This shows that levels of energy efficiency of buildings is improving and that energy certificates are a useful tool in highlighting energy efficiency improvements to building owners and mapping the energy efficiency trends in the building stock. A proportion of these improvements will be to natural replacement that would have occurred and other government policies.

Reducing the carbon emissions of buildings

41. If a building owner chooses to action at least one of the recommendations because of the EPC there will be a reduction in the energy demanded to heat the building. This will have associated fuel bill savings and reduction in air quality damage due to less carbon being emitted. However, the rate EPCs lead to voluntary uptake of recommendations rather than natural replacement is uncertain.

42. EPB data is also used to identify and address energy efficiency issues and enable targeted policies to help to identify and then improve energy efficiency of the most energy poor homes – helping to tackle fuel poverty, improve energy efficiency of buildings to reduce energy use and cost and reduce greenhouse gas emissions.

43. The State of the Estate Report 2021-2022[footnote 22] provides an assessment of the government property portfolio that is one of the largest and most diverse in the UK. The report uses EPC ratings as the benchmark of energy efficiency of the estate. For government buildings over 250m2 and frequently visited by the public a DEC should be produced and displaying in a prominent place in the building. DECs provide an assessment of energy efficiency using the actual energy used in the building and can be used by building facilities managers alongside the EPC which is a standardised energy efficiency assessment.

44. The State of the Estate report includes assessment of government properties across all government areas such as health, schools, defence, prisons and probation centres, job centres, etc as well as government offices. The report fulfils a requirement in the Climate Change Act 2008 to assess and report on the energy efficiency of the buildings in the government estate including to report on the energy efficiency of newly acquired buildings.

45. Government departments continue to take significant strides in decarbonising their estate. There has been a 35% reduction in the greenhouse gas emissions from the government estate buildings since the 2017-18 baseline.[footnote 23] During 2021 to 2022 there were 291 acquisitions across the government estate adding approximately 530,000 m2 of floorspace; 97 of these acquisitions did not require an EPC due to operational reasons or lease renewals of existing government buildings. Of the 194 acquisitions in-scope for an EPC, 79[footnote 24] or 41% were rated outside the top quartile for EPC energy efficiency.

Lessening the impact of climate change

46. A range of measures are used in order to achieve the objectives set out in the EPB Regulations including structured assessment and reporting of aspects of buildings which have a bearing on their use of energy such as the construction style, the fabric used, insulation measures, the predicted performance of fixed building services for lighting, heating and cooling. This regulatory effectiveness contributes to the reduction of the impact of climate change from buildings.

47. Following withdrawal from the EU we are seeking to enhance the EPB Regulations in line with UK domestic ambitions to reduce energy usage and costs in buildings, help tackle fuel poverty and reduce greenhouse gas emissions to meet the government’s commitments to reach net zero emissions by 2050. As part of this enhancement we have given consideration to current compliance numbers as well as the cost of complying.

Compliance with the existing regulatory requirements

48. The ONS have estimated the proportion of dwellings that have had at least one EPC registration since records began by tenure through linking EPC lodgements data to VOA data[footnote 25] and also linking EPC lodgements data to Census data.[footnote 26] A dwelling is unlikely to have had an EPC if it has not been sold or rented during the last 10 years or had certain modifications carried out during that period.

49. ONS analysis suggests about 50% of owner-occupied dwellings in England and Wales are covered by an EPC since records began. According to the EHS, some 40% of owner-occupied households have not changed occupation for 17 or more years. Some of these dwellings will be heritage buildings or holiday lets which are exempt from the requirement to have an EPC. Taken together the evidence suggests high level of compliance with the EPB Regulations by owner occupiers.

50. It is estimated 60 to 70% of social rented dwellings in England and Wales are covered by an EPC since records began and the EHS suggests about 27% of SRS households would not have changed occupation for 17 years or more. Social landlords are also regulated and required to achieve defined standards.[footnote 27] Therefore, it is assumed there are high levels of compliance in the SRS.

51. The evidence suggests compliance rates with regulations could be lower in the PRS. Around 60 to 80% of PRS dwellings in England and Wales are covered by an EPC since records began, whereas only about 4% of PRS dwellings have been occupied for 17 years or more. Some HMOs and PRS heritage buildings are currently excluded from requiring an EPC. It is estimated about 11% of the PRS stock are either an HMO or listed dwelling. The Rent Smart Wales Energy Performance Dashboard reports 89.59% of PRS properties have an EPC.[footnote 28]

52. Whilst the Housing Health and Safety Rating System (HHSRS)[footnote 29] came into force in April 2006, an estimated 12% of PRS homes in England still suffered from a Category 1 hazard in 2022, meaning they fail the statutory minimum standard for housing in England. For comparison, this was estimated at 4% for SRS homes.[footnote 30] Using data from the 2018 English Private Landlord Survey (EPLS), MHCLG categorised 11% of Landlords in a ‘Lower compliance’ cluster and 35% of Landlords in the ‘mixed compliance’ cluster.[footnote 31]

53. There is insufficient evidence to provide an indication of non-compliance with the EPB Regulations for non-domestic buildings. There is also insufficient data on the levels of compliance for DECs that are required for public authority buildings above 250m2 that are frequently visited by the public, that said it is estimated to be high based on industry knowledge. There is insufficient data on the levels of compliance for ACIRs.

54. The EPB regime has approximately 16,000 energy assessor memberships[footnote 32] providing energy certificate assessments for domestic and non-domestic buildings. The cost of an energy certificate is market led and is based on the type, size and complexity of a building and the level of assessment being undertaken. The Energy Performance of Buildings register service allows energy assessors to lodge and consumers to access valid energy certificates. This EPB Register service is provided by the UK government and paid for via a statutory lodgement fee for each assessment uploaded to the register. Following the introduction of the government digital EPB Register service in September 2020 the levels of the fees significantly reduced providing savings to the energy assessor industry. The current cost of a lodgement for a domestic building is £1.50 and for a non-domestic building £1.70.[footnote 33] The difference in lodgement fees for domestic and non-domestic energy certificates is due to the additional complexity and variety of non-domestic energy certificate assessments. The lodgement fees are revised annually to ensure that they cover the costs of running the register.

Total Estimated Cost for the EPB assessment Regime for EPCs and DECs

55. The cost of implementing these regulations has been considered in relation to the achievement of the policy objectives (the benefits).

56. Table 1 and Table 2 below report the number of energy assessments undertaken and the estimated cost across domestic and non-domestic EPCs and DECs in England and Wales for the period 2018 to 2022, respectively. The number of energy assessments was estimated by referring to the EPB published live tables for the number of certificates lodged from 2018 to 2022.[footnote 34]

57. The national costs are based on estimated average costs derived through consultation with industry. The estimated costs are roughly £70 for domestic EPCs, £350 for non-domestic EPCs and £410 for DECs.

58. For additional context, the cost of an EPC to homeowners is compared with the overall cost of moving home and for landlords with annual rental income. The cost of moving house for an owner occupier is roughly on average estimated at about £16,200,[footnote 35] therefore the EPC cost would only be about 0.4% of this. For the PRS, there is no robust average cost estimate to move house because these costs vary depending on individual circumstances including letting agent or management costs. The cost of an EPC however is a small proportion of a landlord’s rental income. The estimated average annual rent paid by a tenant was £12,000 in 2022-3 according to the English Housing Survey.[footnote 36] The EPC cost is only 0.6% of this and the EPC will be valid for 10 years. VOA data suggests non-domestic buildings had an annual rateable value on average of £30,800 in E&W in 2022[footnote 37] and the cost of a non-domestic EPC at £350 is estimated to be only 1% of this.

Table 1: Number of energy assessment certificates lodged in E&W

Lodgements Domestic Non-domestic DECs Total
2018 1,384,916 90,176 34,323 1,509,415
2019 1,587,729 92,356 33,772 1,713,857
2020 1,513,431 72,910 31,485 1,617,826
2021 1,653,549 88,118 33,665 1,775,332
2022 1,761,692 113,027 33,285 1,908,004

Table 2: Estimated national cost of EPCs/ DECs, E&W, rounded to the nearest 100,000, price year: 2024

Total cost Domestic Non-domestic DECs Total
2018 £97,900,000 £31,700,000 £14,000,000 £143,500,000
2019 £112,200,000 £32,400,000 £13,700,000 £158,300,000
2020 £106,900,000 £25,600,000 £12,800,000 £145,300,000
2021 £116,800,000 £30,900,000 £13,700,000 £161,500,000
2022 £124,500,000 £39,700,000 £13,500,000 £177,700,000

59. The EPB Regulations are currently achieving the objectives of creating a system designed to improve the energy performance of buildings, which remain appropriate. In terms of reducing the carbon emissions and lessening the impact of climate change the evidence is less clear cut but there is evidence that energy certificates are effective in reducing carbon emissions and thus reducing the impact of buildings on climate change.

60. Energy Performance Certificates For Buildings: Call for Evidence Summary of Responses[footnote 38] and the recent consultation Reforms to the Energy Performance of Buildings regime[footnote 39] will both inform reforms to the existing regime. 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. These reforms will also enable us to change the objectives of the policy giving energy certificates more of a focus as an information tool.

4. What were the original assumptions?

61. The assumptions on the costs of EPCs were £50 and £800 to £1000 for domestic EPCs (2012 prices) and non-domestic EPCs respectively in the 2012 IA on the Recast of the Energy Performance of Buildings Regulations.[footnote 40] The latest estimate in 2024 prices for the domestic EPC cost is calculated at roughly £70, based on industry feedback for assessor fees, lodgement fees and travel costs.[footnote 41] Using industry feedback and ND-NEED data,[footnote 42] a weighted average non-domestic EPC cost of £350, with a range of £195 to £2,000, is calculated. The latest estimates continue to be low relative to the other costs involved in a property transaction. The latest costs will be used to inform further policy development on EPCs.

62. There was an assumption that energy certificates, including recommendation reports, would provide information that would drive building owners to improve the energy efficiency of their buildings. The English Housing Survey 2022-23 found that 61% of households who moved after EPCs were introduced remembered seeing an EPC, and 57% of those who saw their EPC carried out recommended improvements.[footnote 43]

5. Were there any unintended consequences?

63. Unintended consequences have been minimal and relate to the changing use of EPCs as a benchmark for policies beyond the purpose for which they were originally designed.

64. The EPC was designed to provide a standard assessment of the energy efficiency of a building and to provide standard recommendations to building owners on how they may, if they wished to, improve their building’s energy efficiency. Over time new energy efficiency policies have used the EPC as a benchmark for which it was not designed. This has led to calls by industry stakeholders for changes to the EPC to include, for example increased energy efficiency metrics in the certificates. The EPB reforms consulted on in 2024 aim to improve the applicability, quality, and data usage of energy certificates in domestic and non-domestic buildings.

65. The use of EPCs as the basis for energy efficiency incentive schemes and the take up of new technologies in improving building energy efficiency have put pressure on calculation methodologies to keep pace while still maintaining a standard assessment of energy efficiency allowing the energy efficiency of different buildings to be compared which was the original objective. The calculation methodologies are being reviewed and inclusion of different energy efficiency rating metrics in the certificates is being considered. The Climate Change Committee in its letter and annex published in February 2023[footnote 44] identified a number of potential different metrics calculations that could be provided on the EPC to engage and inform building owners. These proposals to provide additional metrics on domestic EPCs to provide more useful information to consumers to support improving energy efficiency and reducing carbon emissions have been taken forward in the 2024 consultation on reform to the EPB regime.

66. Levels of compliance with EPB Regulations requirements have been difficult to identify as information collected on the EPB Register is on the buildings that comply with EPB Regulations and not those that do not. As part of future reforms to the EPB regime, consideration will be given to opportunities to improve compliance through regulatory or non-regulatory methods such as guidance for enforcement authorities. As part of proposed reforms to the EPB regime government is seeking to work with enforcement authorities and other stakeholders to widen access to EPB data and review current guidance to help improve compliance and enforcement of EPB requirements. Government also proposes to increase penalty charges for EPB regulation non-compliance as the level of penalty changes have not increased since Regulations were introduced in 2007 and government is concerned they are insufficient to prove an effective deterrent to non-compliance.

6. Has the evidence identified any opportunities for reducing the burden on business?

67. Businesses are required to have a non-domestic EPC when they buy or let a non-domestic building or when it is constructed or certain modifications are undertaken. Landlords and business owners of domestic properties are also required to ensure a building has a valid EPC when they buy or let a domestic building or when it is constructed or certain modifications are undertaken. Building owners or building managers are also required to have an ACIR produced every 5 years on their building’s air conditioning or combined air conditioning and ventilation systems where the total effective output of the system is more than 12kW. These requirements have remained largely the same since the implementation of the recast of the EPB Regulations in January 2013, so burden on business has not increased due to added regulatory requirements since the recast of the EPB Regulations 2012.

68. The updated digital Energy Performance of Buildings Register services have helped individuals and businesses to have easier access to energy certificates and data that can allow them to consider recommendations to improve the energy efficiency of their buildings and potentially provide ongoing energy cost savings.

69. Following the withdrawal of the UK from the EU from 31 December 2020 the Energy Performance of Buildings Regulations were unable to be extensively amended due to the European Union (Withdrawal) Act 2018 revoking the powers used to amend EU derived regulations including the EPB. However, we now have a replacement primary power through the Energy Act 2023, to replace the power in the European Communities Act 1972 section 2(2) that was lost when the UK withdrew from the EU. Therefore, we can amend the energy performance of buildings regime to better meet the UK’s domestic priorities on improving energy efficiency in buildings. In 2024 we consulted on amendments and improvements to the EPB regime to ensure that the EPB regime is fit for purpose and meets UK domestic ambitions to achieve net-zero greenhouse gas emissions by 2050.

7. How does the UK approach compare with the implementation of similar measures internationally, including how EU member states implemented EU requirements that are comparable or now form part of retained EU law, or how other countries have implemented international agreements?

70. All Member States have established EPB regimes. It is left to Member States to choose the regime which corresponds best to its specific situation as long as the general principles of EU legislation are observed and Member States take all necessary measures to implement the requirements.

71. By 2020 there were approximately around 6 million domestic EPCs issued every year with the UK leading the way with a total of more than 20 million EPCs registered. The UK was at the time one of the few Member States with a Register for lodging EPCs.

72. The UK’s Registers date back to 2007 and are used for the lodgement of all types of energy certificate. Not all Member States chose to have a Register. The most recent re-cast of the EPB Directive[footnote 45] now requires Member States to set up a national database which allows data to be gathered on the performance of individual buildings and on the overall energy performance of the national building stock.

73. A Building Performance Institute Europe (BPIE) study showed that in 15 out of 28 European States, penalties are issued to the accredited experts for failure to comply with their EPB Directive regime. These penalties can include warnings, loss of accreditation, suspension of licences and financial penalties up to 20,000 euros. The penalty regime in the UK does not include any similar financial penalties.[footnote 46]

74. As the EPB Regulations are derived from the EU, following the UK withdrawal from the EU and the end of the transition period at the end of December 2020 there have been no substantive amendments to the EPB Regulations.

75. Following the UK withdrawal from the EU we now have a new primary power through the Energy Act 2023, to replace the power in the European Communities Act 1972 section 2(2) that was lost when the UK withdrew from the EU, that can be used to amend the EPB Regulations to better meet the UK’s domestic ambitions. We plan to reform the regime by amending the EPB Regulations in order to make it fit for purpose to improve energy efficiency in buildings, reduce energy use and costs in buildings and reduce greenhouse gas emissions to help meet the government commitment of net zero by 2050. Any amendments to EPB Regulations would be subject to an impact assessment to identify potential benefit/burdens on business.

Direction of EU Energy Performance of Buildings Directive Policy

76. The BPIE produced a report Future-Proof Buildings for All Europeans[footnote 47] (May 2019) which provided guidance on the implementation of the revised Energy Performance of Building Directive (2018/844/EU).[footnote 48] The updated EPBD was designed to improve the energy efficiency of existing buildings by requiring EU Member States to have long term renovation strategies to improve the energy efficiency of their existing stock to contribute to the required National Energy and Climate Plans (NECP)[footnote 49] to meet energy efficiency targets. Cost-optimal minimum energy performance requirements are the most efficient levels of energy performance that can be achieved while remaining cost-effective over the building’s lifetime. These requirements apply to new buildings, pre-existing buildings undergoing major renovations (including the Renovation Wave strategy)[footnote 50] and for the replacement and retrofit of building elements like heating and cooling systems, roofs and walls. This includes milestones for EU Member States buildings energy efficiency improvements by 2030, 2040 and 2050.

77. The EU also required the reform of EPCs to expand these to become Building Renovation Passports identifying and recommending updates to buildings to improve their efficiency and reduce their environmental impact.

78. The new Directive also required Member States to set requirements to institute building automation and control systems within buildings to use new technologies to monitor and regulate the operations and functions of building services such as heating, cooling, ventilation, hot water and lighting to optimise and reduce energy use in buildings. Use of new technologies to manage building service was also designed to help improve air quality and ventilation in buildings.

79. The amended Directive also identified the potential for an optional EU wide Smart Readiness Indicator for buildings to identify how ready they are able to benefit from the installation and use of new technologies to regulate the buildings services to reduce energy use.

80. The EU is also investigating the potential for an EU wide EPC through its research into use of standardised EPC data across the EU. This is seen through EU research such as the European Location Interoperability Solutions for E-Government (ELISE) which undertook work producing a report to inform the EU on EPC data harmonisation across Europe. The report EPC4EU: Harmonisation of datasets of Energy Performance Certificates of buildings across Europe[footnote 51] (July 2021) provided a pilot study using methodology to harmonise data in Italy and Spain as an example of a methodology that could be used to harmonise EPC data across European countries where EPC data collected may not be immediately comparable. This would allow direct comparisons of energy efficiency of buildings across Europe and better inform EU future policy.

81. The TIMEPAC Consortium funded by the EU Horizon Programme undertook a pilot project[footnote 52] in Austria, Croatia, Cyprus, Italy, Slovenia and Spain to expand the EPC to obtain more data on a building and to consider the EPC becoming a Building Renovation Passport which would be designed to track a building’s renovation and performance overtime and to identify and plan for long term step by step renovations for specific buildings to meet net zero requirements. More data on the buildings were collected and used such as actual energy consumption as opposed to the standardised calculated estimate of performance. It was considered that improved data in a wider building renovation passport would drive building renovations and reduce energy use and increase building energy efficiency.

8. Do the objectives remain appropriate and, if so, to what extent could they be achieved with a system that imposes less regulation?

82. As part of the assessment of whether or not the objectives remain appropriate and then, if they do, determining the extent to which they could be achieved in another way which involves less onerous regulatory provision (for example, deliberation of alternatives to regulation) consideration was given to current compliance numbers as well as the cost of complying. This analysis is covered in paragraphs 38-52. In addition to this there is also evidence that energy certificates are seen as an effective tool, especially by public sector organisations, in reducing energy use and carbon emissions to improve the energy efficiency of buildings.

83. We have concluded that the EPB Regulations are currently achieving the objectives set out and are maintaining an established system which was designed to measure and improve the energy performance of buildings. In terms of reducing the carbon emissions and lessening the impact of climate change the evidence is less clear cut but there is evidence that energy certificates are effective in reducing carbon emissions and thus reducing the impact of buildings on climate change.

84. The department is therefore of the view that the mandatory requirements of the regulations should be retained, including the obligations on the owner or landlord to make an EPC available to the prospective buyer or tenant for a building that is sold or rented out. Requiring building owners and occupiers to acquire energy reports about improving the energy efficiency of their buildings, how to reduce energy consumption and carbon emissions, through EPCs, DECs and ACIRs, will continue to achieve cost savings and may encourage additional actions by proposing improvements that could be made to the buildings fabric or services.

85. Part of the 2024 consultation into reforming the EPB framework focused on clarifying and consolidating regulation and refining requirements for EPCs and DECs. The proposal for 4 new complementary headline metrics for domestic EPCs are intended to provide more useful information to consumers without additional regulatory burden. As part of proposed reforms to the EPB regime government is considering amending regulations requiring EPCs for HMOs and heritage buildings. These buildings can be the least energy efficient and EPC information will provide opportunity for building owners and tenants to identify low energy efficiency and recommend potential energy efficiency improvements. EPCs have been used as a benchmark to enable other government policies that are designed to improve the energy efficiency of buildings, such as via energy efficiency capital grant schemes and minimum energy efficiency standards.

86. The Energy Act 2023, which came into force in October 2023, provides the primary powers required to enable amendments to the EPB Regulations and therefore represents a new opportunity for government to make these regulations smarter, more efficient and better suited to England and Wales.

Annex C: Objectives of the Energy Performance of Buildings Regulations

1. The EPB Directive seeks to improve the energy efficiency of buildings, reducing their carbon emissions and lessening the impact of climate change. This complements the 2008 Climate Change Act as amended in 2019, which requires a reduction in carbon emissions by 100% on 1990 levels by 2050. As emissions from buildings account for around 30% of all carbon emissions in the UK,[footnote 53] it is important to ensure that this is mitigated by improving the energy efficiency of existing buildings and ensuring that new buildings are designed and built to a high standard of energy efficiency.

2. The EPB Regulations, as amended, aimed to implement the EPB Directive and in doing so improve the energy efficiency of buildings, thus reducing CO2 emissions and lessening the impact of climate change. It does this through a number of measures which introduced structured assessment and reporting of aspects of buildings which have a bearing on their use of energy such as the construction style, the fabric used, insulation measures, the predicted performance of fixed building services for lighting, heating and cooling. Additionally, the reports contain recommendations which provide owners with optional actions and investments that they may make to increase the energy efficiency of their building.

Energy Performance Certificates

3. The EPB Regulations came into effect on 9 January 2013 and have subsequently been amended. The EPB Regulations require Energy Performance Certificates (EPCs) to be produced when a domestic or non-domestic building is constructed, sold or let. EPCs show the energy efficiency of a building on a scale of A (A+ for non-domestic buildings) to G and include recommendations to improve the energy efficiency of the building. An EPC should be given free of charge to a prospective buyer or tenant and ultimately to the person who buys or rents the building.

Display Energy Certificates

4. Display Energy Certificates (DECs) are required to be produced and clearly displayed in buildings over 250m2, occupied in whole or part by public authorities and where the building is frequently visited by the public. DECs for buildings over 1,000m2 are valid for 12 months and the accompanying recommendation report for 7 years. In January 2013, the EPB Regulations extended DECs to public buildings over 500m2. The size threshold was amended on 9 July 2015 to include buildings over 250m2. Under these provisions, DECs for buildings between 250m2 and 1000m2 and the accompanying recommendation report are valid for 10 years.

5. DECs must be displayed in a prominent place clearly visible to the public, with the intention of raising public awareness of energy use. DECs provide an energy rating of the building from A to G based on the actual amount of metered energy used by the building over the last 12 months within the validity period of the DEC, where A is very efficient and G is the least efficient. An affected organisation must have in its possession, or control, a recommendations report.

Air Conditioning Inspection Reports

6. The EPB Regulations state that all air conditioning systems with an effective rated output of more than 12kW must be inspected at regular intervals no more than 5 years apart. This includes systems consisting of individual units which are less than 12kW, but whose combined effective rated output is more than 12kW.

7. An air conditioning system is defined as ‘a combination of all components required to provide a form of air treatment in which the temperature is controlled or can be lowered and includes systems which combine such air treatment with the control of ventilation, humidity and air cleanliness’. The Air Conditioning Inspection Report (ACIR) is intended to provide the building owner or manager with information regarding the efficiency of the air conditioning systems that they control to allow them to identify opportunities to save energy and reduce operating costs.

Inspection of heating systems

8. Although not specifically referred to in the EPB Regulations, the EPB Directive also requires the inspection of heating systems in buildings. The scope of the inspection covers all accessible parts of all systems used for heating buildings with boilers of an effective rated output of more than 20kW. However, the EPB Directive allows Member States to provide advice and adopt alternative solutions that achieve the same goals instead of a regular inspection regime. Member States adopting an alternative solution are required to prepare equivalence reports to demonstrate that their approach has a comparable impact to an inspection. This is the implementation route that the UK has adopted.

Recommendations report

9. EPCs, DECs and ACIRs are accompanied by a recommendations report that includes cost effective measures to improve the energy efficiency of the building or the air conditioning system. Under the EPB Regulations a recommendations report must include:

  • recommended cost-effective measures that could be carried out in connection with a major renovation of the building envelope or technical building systems
  • recommended cost-effective measures for individual building elements that could be carried out without the necessity for a major renovation of the building envelope or technical building systems
  • an indication of how the owner or tenant could obtain more detailed information about improving the energy efficiency of the building, including more detailed information about the cost-effectiveness of the recommendations and
  • information on the steps to be taken to implement the recommendations

  1. 2012 Impact Assessment - Recast of the Energy Performance of Buildings Regulations, page 9. ↩

  2. See paragraph 53 in Annex B. ↩

  3. Energy Performance of Buildings Regulations 2012: implementation report (2020). ↩

  4. Energy Performance Certificates in buildings: call for evidence (2018/2020). ↩

  5. Energy Performance Certificates for Buildings: Action plan (2020). ↩

  6. Improving Energy Performance Certificates: action plan – progress report (2021). ↩

  7. English Housing Survey 2021 to 2022: energy. ↩

  8. English Housing Survey 2021 to 2022: energy, ‘Main Findings’. ↩

  9. State of the Estate, 2021-2022. ↩

  10. Live tables on Energy Performance of Buildings Certificates, Table DEC1.      ↩

  11. Live tables on Energy Performance of Buildings Certificates, Table A: Non-Domestic EPCs in England and Wales by energy performance asset rating. ↩

  12. Energy Performance of Buildings: changes to The Energy Performance of Buildings Regulations 2012, No. 3118: Response to the consultation. ↩

  13. EHS 2022-23, of the 1.3 million households who remembered seeing an EPC with energy efficiency recommendations, 57% acted on the improvements suggested: English Housing Survey 2022 to 2023: energy report. ↩

  14. English Housing Survey 2021 to 2022: energy. ↩

  15. Energy Performance of Buildings Data England and Wales. ↩

  16. English Housing Survey 2021 to 2022: energy. ↩

  17. State of the Estate, 2021-2022. ↩

  18. State of the Estate, 2021-2022, page 47. ↩

  19. Response to the consultation, 2020. ↩

  20. Evaluation of the Domestic Private Rented Sector Minimum Energy Efficiency Standard regulations, page 3. ↩

  21. Evaluation of the Domestic Private Rented Sector Minimum Energy Efficiency Standard regulations, page 3. ↩

  22. State of the Estate 2021-2022. ↩

  23. State of the Estate 2021-2022, page 7. ↩

  24. State of the Estate 2021-22 Report, page 57. ↩

  25. ONS, Table 6a: Percentage of dwellings covered by an Energy Performance Certificate since records began, England and Wales, as at 31 March 2022. ↩

  26. ONS, Table 1 and Table 2, England and Wales, as at 31 March 2021. ↩

  27. Regulator of Social Housing, 2024, Regulatory standards for landlords. ↩

  28. Welsh Government Rent Smart Wales Energy Performance Dashboard, as of February 2025. ↩

  29. The HHSRS is a risk-based assessment that identifies hazards in dwellings and evaluates their potential effects on the health and safety of occupants and their visitors, particularly vulnerable people. The most serious hazards are called Category 1 hazards and where these exist in a home, it fails to meet the statutory minimum standard for housing in England. ↩

  30. English Housing Survey 2022-23 Headline Report, Annex Table 4.4. ↩

  31. DLUHC Segmenting private landlord compliance 2022. ↩

  32. An individual energy assessor may have more than one membership. ↩

  33. Energy Trust, domestic and non-domestic current lodgement fee, 2022 ↩

  34. Live tables on Energy Performance of Buildings Certificates. ↩

  35. To provide a high level estimate of moving costs (please note this does not apply for first time buyers), the mid-point of the cost range reported by Money Helper is used for estate agent fees. An average of the cost range was used for legal fees (and we assume VAT is included in the estimate), the house survey and removals: Money Helper: Mortgage fees and costs when buying or selling a home. Stamp duty is estimated using Land Registry data on the average house price for former owner occupiers in England and Wales in October 2023 as of February 2025. An EPC cost estimate of £70 was also used, which was sourced through engaging with industry. ↩

  36. Annex tables for English Housing Survey headline report 2022-2023, Chapter 2: Housing costs and affordability annex tables, Annex table 2.4, all England. Mean PRS weekly rents are converted to annual rents. ↩

  37. The average rateable value for a non-domestic property in England and Wales is estimated by dividing total rateable value by the number of rateable properties, NDR Stock of Properties Tables, 2023, Tables SOP3.1 and SOP3.2. ↩

  38. Energy Performance Certificates of Buildings: Call for evidence summary of resposes. ↩

  39. Reforms to the Energy Performance of Buildings regime - consultation. ↩

  40. 2012 Impact Assessment - Recast of the Energy Performance of Buildings Regulations, page 9. ↩

  41. TAG data book, Tables A1.3.1, Values of Working (Employers’ Business) Time by mode per person (distance banded), Car (driver or passenger) 0-50km, Resource cost - the price and value year are set to 2024 in ‘User Parameters. ↩

  42. Non-domestic National Energy Efficiency Data Framework (ND-NEED), 2023. ↩

  43. See paragraph 12. ↩

  44. Letter: Reform of domestic EPC rating metrics to Patrick Harvie MSP, The Climate Change Committee (2023) ↩

  45. Directive - EU - 2024/1275 - EN - EUR-Lex. ↩

  46. Energy Performance Certificates: Assessing their status and potential, X-tendo (2020). ↩

  47. Future-proof buildings for all Europeans. ↩

  48. Directive (EU) 2018/844 of the European Parliament and of the Council, 2018. ↩

  49. National energy and climate plans. ↩

  50. A Renovation Wave for Europe - greening our buildings, creating jobs, improving lives, 2020. ↩

  51. Harmonisation of datasets of Energy Performance Certificates of buildings across Europe, 2021. ↩

  52. https://energypost.eu/buildings-energy-performance-certificates-piloting-new-tools-to-ramp-up-renovations/. ↩

  53. Heat and Buildings Strategy, October 2021, page 28. ↩

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