New Consultation Launched on Minimum Energy Rating C by 2028!

A Brief History of EPC Regulations for Landlords

For years, successive governments have been pushing to improve the energy efficiency of rental properties. Since 2018, landlords in England and Wales have been required to ensure their properties achieve at least an Energy Performance Certificate (EPC) rating of ‘E’ before they can be legally let out.

In 2020, the Conservative government consulted on plans to raise this minimum standard to EPC ‘C’ by 2025 for new tenancies and by 2028 for all tenancies. That proposal was ultimately shelved, with little government support at the time. Previous attempts to introduce similar regulations had been brought forward as private members’ bills but failed to gain the necessary backing. As a result, landlords have been left in limbo, uncertain about what upgrades might be required in the future.

Now, the Labour  government has launched its own plans to improve energy efficiency in the private rented sector (PRS), with a fresh consultation led by the Department for Energy Security and Net Zero, under Minister Miatta Fahnbulleh. This consultation proposes new timelines and a higher cost cap. Here’s what you need to know.

What Are the New Proposals?

The latest government consultation, published in February 2025, proposes that all rental properties in England and Wales must achieve at least an EPC ‘C’ rating by 2030, with an earlier deadline of 1st January 2028 for new tenancies. This phased approach is supposed to allow landlords time to make the improvements while ensuring the transition to higher efficiency standards.

The key proposals include:

• A higher maximum spend cap of £15,000 per property (previously £10,000 was proposed).
• The ability for landlords to apply for an affordability exemption, reducing the cap to £10,000 in some cases.
• A new way of measuring EPCs, which will consider not just energy costs but also the fabric efficiency of a property and its heating system.
• A phased introduction, requiring new tenancies to meet EPC ‘C’ by 1st January 2028 and all tenancies by 2030.

Miatta Fahnbulleh MP, Minister for Energy Consumers, explained:

“Private renters face the highest rate of fuel poverty, often living in some of the least energy-efficient homes. These proposals will ensure that all rental properties meet higher energy standards, cutting tenants’ bills and reducing carbon emissions.”

Comment

The  Government estimates savings of £240 per property per year, and the average expense for landlord of £6,000 which gives a 25 year pay back on that investment. I suspect rents will increase by more than £240 per year to cover the additional expenses.

How Will This Impact Landlords?

There’s no denying that these changes will mean additional costs for landlords. According to government estimates, the average property will require between £6,100 and £6,800 worth of improvements to reach EPC ‘C’.

The increased cost cap of £15,000 means that, in some cases, landlords may need to invest significantly to bring older properties up to standard. If this level of investment is required but still doesn’t achieve EPC ‘C’, landlords will be able to register an exemption lasting for 10 years.

For student landlords, this timeline poses a significant challenge. Since student properties typically have new tenancies each academic year, landlords effectively have only the summers of 2026 and 2027 to complete any required upgrades without disrupting tenants. This puts enormous pressure on student landlords to plan and complete works in a very limited timeframe.

There are an estimated 110,000 student HMOs in the UK that currently do not meet the proposed EPC ‘C’ requirement. This represents a major logistical and financial hurdle, particularly for landlords in university cities where the student rental market is concentrated.

That said, landlords who take action early may be able to access financial support. Government funding schemes such as the Boiler Upgrade Scheme and the Great British Insulation Scheme can help reduce costs for eligible properties.

How Can Landlords Respond to the Consultation?

The government is actively seeking views on these proposals, and landlords should take this opportunity to have their say. The consultation runs until 2 May 2025, and responses can be submitted online via the government’s Citizen Space portal.

The key areas up for discussion include:

• Should the cost cap be £15,000, or is this too high?
• Should short-term lets (e.g. Airbnbs) be included in the regulations?
• Should landlords be required to install smart meters as part of the improvements?
• Is 1st January 2028 the right deadline for new tenancies, or should more time be allowed?

What Happens Next?

Once the consultation closes in May 2025, the government will review responses and publish its final decision later in the year. Regulations are expected to be formally introduced in 2026, giving landlords four years to comply before the 1st January 2028 deadline for new tenancies and the 2030 deadline for all tenancies.

What Should Landlords Do Now?

While nothing is set in stone yet, landlords should start planning ahead:

• Check your EPC rating – If your property is below ‘C’, start assessing what improvements may be needed.
• Consider early upgrades – Government grants are available now, but may not be in future.
• Respond to the consultation – If these changes will impact you, make sure your voice is heard. In our response, we’ll certainly be pushing for a reduction on the cap, which could easily be the whole year’s rent on a small property, and to get rid of the 2028 deadline, which would put huge pressure on the student HMO market.

With the government’s renewed commitment to energy efficiency, it seems inevitable that tougher EPC standards will be introduced. The question is how much flexibility landlords will be given to comply. If you’d like to respond to the consultation, you can do so here.

Purple Frog will work with our clients to work out the best way to meet the new proposed regulations.  Our Developments Director, Shaun Knight will be heading up these efforts, so please get in touch with him here: shaun.knight@purplefrogproperty.com.