Energy Performance Certificate (EPC)

Why it matters

Under the Minimum Energy Efficiency Standard, it has been unlawful since April 2020 to continue letting a domestic property in England or Wales with an EPC rating of F or G, unless a valid exemption is registered. Enforcement sits with the local authority, which can issue penalties of up to 5,000 pounds per property and publish the breach. A missing or expired EPC also undermines other processes that rely on a compliant paperwork trail.

Legal requirements

• An EPC must be commissioned before marketing and provided free to prospective tenants at the earliest opportunity.
• The energy rating must be stated in any written advertisement of the property.
• The minimum rating for a domestic private rented property in England and Wales is band E, unless an exemption is registered on the PRS Exemptions Register.
• The certificate is valid for ten years; a new tenancy does not require a new EPC if the existing one is still valid.
• Exemptions include the seven-year payback rule, all relevant improvements made, wall insulation that would damage the property, third-party consent refused and devaluation over five per cent — each lasts five years and must be registered with evidence.
• Scotland has its own regime with EPCs required on let and a Repairing Standard route; Northern Ireland requires an EPC on let but does not currently apply MEES.

Common mistakes

• Letting a band F or G property while assuming the low rating is only a marketing problem.
• Relying on an exemption without registering it on the PRS Exemptions Register.
• Marketing a property without the rating shown in the advert.
• Letting an EPC expire mid-tenancy and forgetting it before the next letting or a sale.
• Spending on visible improvements that barely move the modelled score instead of insulation and heating controls.

Practical guidance

• Diarise the EPC expiry date ten years from issue, and re-assess after any significant works.
• Give the tenant a copy at the start of the tenancy and record that you did.
• Get the assessor recommendations report and price the top three measures before any refurbishment.
• Store the EPC with the gas safety record, EICR and How to Rent guide so the whole compliance pack is served together.

Properties that do not need an EPC

Certain buildings are exempt from needing an EPC at all: listed buildings where compliance would unacceptably alter character (a question of fact, not an automatic exemption), places of worship, temporary buildings with a planned use of under two years, and some standalone buildings under 50 square metres. Rooms let in an HMO where the tenant does not have exclusive use of a self-contained dwelling generally do not need an individual EPC, though the building may. Do not assume a listed building is exempt — the test is whether the minimum energy performance requirements would unacceptably alter it, and many councils expect evidence.

The proposed move to EPC C

The government has consulted on raising the minimum standard for privately rented homes to EPC C, with 2030 discussed as the target date and different dates floated for new and existing tenancies. This is not yet law and the detail, including any cost cap and exemption structure, has not been finalised. Landlords planning refurbishment now should still design towards a C where the marginal cost is small, because retrofitting later on a tenanted property is far more disruptive and expensive.

Improving a rating cost-effectively

The measures that most reliably move a domestic rating are loft insulation to 270mm, cavity wall insulation where the construction allows it, a modern condensing boiler or heat pump, low-energy lighting throughout, hot water cylinder insulation, and heating controls including a room thermostat and TRVs. Draught-proofing and secondary glazing help comfort but move the score less than owners expect. Ask the assessor for the recommendations report and the score uplift for each measure before spending — the model rewards some measures far more than others.

Evidence and record-keeping

Keep the certificate, the recommendations report and the assessor invoice with the property file, and re-run the assessment after works so the improved rating is on the public register. If you rely on an exemption, register it with the supporting evidence before the letting continues — a retrospective registration after an enforcement notice does not cure the breach.