The 2030 deadline for minimum EPC C in rental properties is barely six years away. Yet 1.2 million private rented homes still sit at band D or below, according to government data. For landlords who own those properties, the bill for insulation, glazing, and heating upgrades could hit £10,000 per home. That is not a forecast. It is the estimate from the Energy Saving Trust for a typical Victorian terrace needing solid wall insulation, new windows, and a heat pump.
As reported by Osborne Clarke, the compliance and cost challenge is now front and centre for landlords. The law firm notes that the government’s consultation on the new regulations closes in early 2025, meaning the final rules could be in place within 18 months. But the real shock is the scale of the work required.
Who qualifies, and who doesn’t
The proposed rules apply to all private rented properties in England and Wales. From 2028, new tenancies must have an EPC rating of C or above. By 2030, all existing tenancies must comply. The catch is that exemptions exist only for properties where the cost of upgrades exceeds £10,000, and even then, landlords must prove they have exhausted all grant options first.
That cap matters. A typical 3-bed semi from the 1930s with cavity walls and loft insulation might cost £3,000 to bring to band C. But a solid-walled Victorian terrace, common in cities like Manchester and Bristol, can require £15,000–£20,000 of work. The £10,000 exemption threshold will not cover that. Landlords will either pay or sell.
What it costs a typical 3-bed semi
Let us run the numbers on a 100m² semi-detached house with an EPC D, built in 1970. The standard upgrade path is: loft insulation (already likely present), cavity wall insulation (£1,200–£2,500), new double glazing (£4,000–£7,000 for 8 windows), and a modern gas boiler or heat pump (£3,000–£7,000). Total: £8,200–£16,500. For a property with solid walls, external wall insulation alone can cost £10,000–£15,000.
The government’s own impact assessment, cited by Osborne Clarke, puts the average cost at £5,000–£10,000 per property. But that average hides regional variation. In London, where housing stock is older and labour more expensive, costs can be 30% higher. In the North East, they may be 20% lower. Either way, the bill lands on landlords who have not budgeted for it.
Grants and the real-world gap
The Boiler Upgrade Scheme offers £7,500 off a heat pump, but only for owner-occupiers, not landlords. The ECO4 scheme can fund insulation for low-income households, but eligibility is means-tested and most rental properties do not qualify because the tenant’s income is below the threshold, a catch-22. The Great British Insulation Scheme is open to all, but its budget is small and the waiting lists are long.
What this misses is the tenant’s perspective. A home at EPC D costs roughly £300–£600 more a year to heat than one at C, according to Ofgem. For a family on a low income, that is money that could go on food or school uniforms. The health impact is also real: cold homes contribute to respiratory illness, cardiovascular strain, and excess winter deaths. The government’s own data shows that 10% of excess winter deaths are linked to fuel poverty in poorly insulated homes.
Yet the burden of fixing this falls on landlords, many of whom are small investors with one or two properties. A survey by the National Residential Landlords Association found that 40% of landlords plan to sell properties rather than meet the new standards. That would reduce rental supply and push up rents for everyone else, a perverse outcome from a policy built to help tenants.
The practical advice for homeowners who rent is to start now. If you are a tenant, check your EPC rating on the gov.uk register. If it is below C, ask your landlord about their upgrade plans. If you are a landlord, get an EPC assessment and a quote for the work. The cost will only rise as the deadline approaches and tradespeople get busier. The Boiler Upgrade Scheme may not apply, but the ECO4 and Great British Insulation Scheme are still options. Apply through your energy supplier or the Energy Saving Trust website. The deadline is 2030. The time to act is 2025.
Frequently Asked Questions
Not directly, but from 2028, landlords cannot grant new tenancies for properties below EPC C. If your current tenancy continues, you can stay until 2030. After that, the property cannot be legally let. If your landlord cannot or will not upgrade, they may choose to sell or end the tenancy, which could lead to a no-fault eviction under Section 21. You have protections, but it is worth discussing the timeline with your landlord now.
Yes, but they are narrow. If the cost of all recommended upgrades exceeds £10,000 (including VAT and labour), the landlord can register an exemption valid for five years. They must provide evidence, such as three independent quotes. However, the exemption only applies if the landlord has first applied for all available grants. If a grant covers part of the cost, the cap resets to £10,000 minus the grant amount. The exemption also does not apply if the property is already at EPC D and only needs minor work.
