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It's Not On: Agents tell government new EPC targets can't be met

New long-term targets for improving energy efficiency across the private rental sector simply are not realistic, the government has been warned.

The broadside comes from the Association of Residential Lettings Agents‘ policy and campaigns manager, Timothy Douglas, following a consultation document released by government this week.

The target is to lift the minimum EPC for all privately rented homes to Band C - this would apply to new tenancies from 2025 and all tenancies from 2028. The government has outlined penalties of up to £30,000 for landlords who do not comply, and is considering banning agents and portals from listing properties that do not meet the standards.


“On the face of it these proposals simply do not take into account the state of the UK's housing stock. We all want to see more energy efficient homes, but the new rules and requirements must be realistic and achievable” says Douglas. 

The ARLA Propertymark chief continues: “Landlords and their letting agents are already taking the brunt of tax changes and many are providing support to tenants with Covid-related arrears. 

“A simplified [EPC] exemptions regime and additional financial support must be made available otherwise the measures in their current form, will not be achievable and that would mean further reductions in the supply of rented accommodation available.”

The government’s consultation document runs to 48 pages and includes options and detailed requirements regarding energy efficiency improvements it expects from the sector.

You can see the consultation document here with details of how to respond. The closing deadline for comments from agents is 11.45pm on December 30 - the government says it will respond next spring.

Poll: The government's EPC targets are...


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    From the NRLA a deafening silence! 😡

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    I am all for upgrading energy efficiency when feasible and reasonable, but there are going to be some homes which are hard to bring up to a C rating.

    Potentially you could find some landlords stuck in a trap wherein they don't have and can't get the funds for all the upgrading required, can't continue to rent without, and can't evict without cause.

    There may also be technical considerations. For example, the only way to upgrade wall insulation on a particular building may be internal dry lining, but the tenant may object to the disruption.

    What is such a landlord to do?

    Where possible, I guess take advantage of the currently available grants to upgrade ahead of time.

    I know there are currently exemptions for listed buildings and buildings which are hard to upgrade, however even so, there are likely to be some landlords who will struggle.

    Matthew Payne

    You can apply for exemption on any property if an owner spends £3,500 on addressing recommendations on the EPC but where that still doesn't get it to the required grade, whether E today, or later C. There is the Green Homes Grant that can be used to address some certain improvements like double glazing where the government will pay about 2/3 of the cost. A starting point is also to check the current EPC is accurate, many are not.


    Re Matthew's comment, one alarming aspect of the law is that the landlord is held liable if the EPC is incorrect which tends most often to occur through inaccuracies in measuring the floor area and volume of the property. Suppose you have a property with an EPC of E, and it turns out on checking that the EPC was inaccurate, and should have been rated F, then the property is unlawfully let and the landlord is held responsible even though as far as they are concerned, they did everything right.

    In pretty much any other situation, you can rely on the "expert" to get it right and hold them accountable for errors!

    Matthew Payne

    It's not just size and accidental errors though Gary even in 2020. Had a client ealier in the year put their 3 bed house on the market, got an EPC done, when it came back I noticed it was a low F. I know the house and thought it was far too low. When I looked at the detail, the assessor had pretty much checked nothing, and assumed 'no' to everything on insulation, including the fully lagged loft that was easily accessible on a drop down ladder to stick your head into. We challenged it with evidence and got it upgraded to a C. This won't be an isolated incident.

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    • 02 October 2020 10:34 AM

    LL should be selling these dud properties before the market wakes up to them being dud.

    Get them sold to dopey FTB ASAP.

    Let them upgrade to EPC C status if they wish.

    I'm sure once done LL will be content to buy at just the same price as an unimproved property.

    Let the FTB waste their money
    It will save LL wasting their's!

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    • 02 October 2020 10:51 AM

    You have to keep qualifying for EPC exemptions.
    Grants don't cover what could still be costly works.

    Still worth getting rid to save all the hassle.
    Use the sale proceeds to reduce leverage on other properties to build up resilience and to reduce the effects of S24 if a sole trader

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    • 02 October 2020 12:36 PM


    Based on what you and others have stated it would seem that the most sensible option for LL before they determine what to do with a dud EPC property is have another EPC and stand over the assessor like a hawk ensuring they have access all areas.
    Even cutting holes in walls.
    A C status is the prize.
    Get that and the LL saves fortunes.
    This is what I would do if I had a property less than C which fortunately I don't apart from my resi home which only has space for one lodger and I'm certainly not going to install IWI or EWI nor will I block up the chimney.
    I have no mould in this traditional EOT house unlike my C status flats

    Matthew Payne

    Standards vary in all industries, this is no different. I think the problem has been that we all just accepted the art of producing an EPC as an exact science when they were introdcued and people didnt much care what they said anyway as there were no implications to the ratings. 12 years on it suddenly matters. It was only when I started reading them a few years ago I realised that some assessors put more effort in than others, were more skilled perhaps and there was a default position that if you couldnt see it, it didnt exist.

    On insulation as per my example, that makes a massive difference to the outcome. Assessors are not paid to try and get the best rating though, so they won't question the owner and ask whether they have any invoices or gaurantees for example that demonstrate that cavity wall or sub floor insulation exists, so homeowners needs to be prepared for the appt, whether paperwork or drilling holes.

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    For your C status flats to overcome the mould issue, I would suggest installing a good humidistat controlled single room heat exchange ventilation unit in the most affected room. Should reduce humidity enough to eliminate the conditions required for mould to form.

    • 04 October 2020 05:00 AM

    Not going to do that.
    I just tell the occupants to ensure the air is changed every day by opening windows and French doors.
    I say this even though paying all bills.
    I advise I much prefer a relatively small increase in bills than mouldy flats.
    The windows and doors only need to be slightly open to manage this mould issue which isn't that great.

    As I intend to sell in the next 4 years; due to the anti-LL regulations I am not changing anything in what are only 12 year old flats.


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