EPC C targets under fire over impact on older homes

The UK government’s plan to require private rented homes to meet an Energy Performance Certificate (EPC) rating of C by 2030 has raised significant concerns among landlords and industry experts, particularly regarding the impact on older properties. With Britain’s housing stock including many traditional and heritage buildings, questions remain about the feasibility and appropriateness of applying uniform energy-efficiency standards across such diverse property types.

Challenges of Upgrading Older Properties

Many of the UK’s older homes, especially those built before World War I, were constructed using materials and methods that differ markedly from modern standards. These buildings often feature solid walls made from breathable materials like lime mortar and soft brick or stone, designed to naturally manage moisture rather than being sealed airtight. This traditional construction poses challenges when attempting to retrofit energy-efficiency measures intended for contemporary cavity-wall buildings.

Industry bodies and heritage organisations have highlighted that applying modern insulation and energy standards to these older homes risks damaging their fabric and potentially affecting occupant health. The Society for the Protection of Ancient Buildings (SPAB) has cautioned against a ‘fabric first’ approach that attempts to force older buildings to meet the same fabric performance as modern homes, warning this could lead to over-insulation and inappropriate alterations.

Proposed Changes to EPC Assessment

The government has announced plans to reform the EPC system, moving away from a single metric based on energy use per square metre to a more nuanced approach. The new framework would include four headline metrics: fabric performance, heating system efficiency, smart readiness, and energy cost, with energy use and carbon emissions as secondary considerations.

While this aims to provide a more comprehensive assessment of a property’s energy efficiency, concerns remain about how accurately these metrics will reflect the performance of older buildings. Heritage groups have urged that fabric performance should be considered alongside other factors to avoid unintended consequences for traditional homes.

Practical and Financial Implications for Landlords

Landlords of older properties face significant practical difficulties in meeting the EPC C target. Retrofitting solid-wall or heritage buildings often involves complex, costly work that may not be technically suitable or deliver sufficient energy savings to justify the investment. Propertymark, representing letting agents, has emphasised that a one-size-fits-all policy does not account for the diversity of the private rented sector’s housing stock.

The National Residential Landlords Association (NRLA) has also expressed concerns that many rental properties will be unable to meet the EPC C standard within the proposed timeframe. The lack of skilled tradespeople and the complexity of retrofit work add further barriers. There is a risk that some landlords may choose to sell properties rather than undertake expensive upgrades, potentially reducing the supply of rental homes and exacerbating housing shortages.

Government Support Measures and Cost Caps

The government maintains that the EPC C requirement is a fair and proportionate step towards improving energy efficiency in the private rented sector. To mitigate the financial burden on landlords, a maximum spend cap of £10,000 per property has been introduced, lowered from an earlier proposal of £15,000. Additionally, landlords may apply for exemptions where improvements are not feasible, appropriate, or would exceed the cost cap.

For older buildings, exemptions may be supported by evidence such as surveyor reports highlighting risks to the building’s fabric, specialist retrofit cost estimates, or planning restrictions. These exemptions must be registered on the official PRS Exemptions Register and are subject to verification by local enforcement officers, who check the validity of the exemption rather than reassessing technical details.

Ongoing Concerns and Calls for Policy Stability

Despite the introduction of cost caps and exemptions, many landlords and agents remain concerned about the ability to meet EPC C standards without further financial support and clearer guidance. Propertymark has welcomed the extension of exemption periods to ten years but stresses that many older properties will still struggle to comply within the cost limits.

There is a strong call within the sector for long-term policy stability and incremental implementation targets to provide landlords with the certainty needed for strategic investment decisions. Previous delays and cancellations of EPC targets have contributed to uncertainty, and stakeholders urge the government to maintain consistent timelines and support mechanisms to avoid unintended consequences for housing supply.

What this means for landlords

Landlords with older or traditionally constructed properties should be aware that meeting the EPC C target by 2030 may present significant challenges. Retrofitting may require specialist advice and could involve substantial costs, even with the government’s £10,000 spend cap. It is important to assess each property individually, considering its construction, condition, and potential retrofit options.

Where improvements are not feasible or cost-effective, landlords may need to explore exemption routes, ensuring they gather appropriate evidence and register exemptions correctly. Staying informed about evolving regulations and available support will be crucial to managing compliance and maintaining rental property viability.

What TLA members should consider

• Conduct thorough energy assessments of older properties early to identify feasible retrofit measures and potential challenges.
• Seek specialist advice on appropriate energy-efficiency improvements for traditional and heritage buildings to avoid damaging fabric or occupant health.
• Keep detailed records and evidence to support exemption applications where meeting EPC C is not practical or cost-effective.
• Monitor government updates on EPC regulations, cost caps, and exemption criteria to ensure compliance and maximise available support.
• Plan retrofit works strategically, considering the extended exemption periods and aiming for incremental improvements where possible.
• Engage with letting agents and property managers to communicate with tenants about planned works and potential impacts on tenancy arrangements.

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