Nearly 1.5 million privately rented homes in England and Wales still sit at EPC band D or below. That is the number the government wants to tackle with its latest consultation on minimum energy performance standards, published in December 2024 and open for responses until March 2025. The Energy Saving Trust has now submitted its formal response, backing the ambition but flagging several practical hurdles.
As reported by the Energy Saving Trust, the proposed timeline would require all new tenancies from 2028 to meet EPC C, with all existing tenancies following by 2030. That gives landlords roughly three to five years to act.
Who qualifies, and who doesn’t
The proposed rules apply to private landlords in England and Wales. Scotland already has its own trajectory to EPC C by 2025, though enforcement has been patchy. Exemptions will exist for properties where cost-effective measures cannot achieve the target even after the £10,000 cap is spent, or where listed building consent is refused. But the Energy Saving Trust warns that the exemption process must be simpler than the current system, which has seen landlords exploit loopholes by claiming they cannot afford upgrades without proving it.
For the typical 3-bed semi currently rated EPC E, reaching band C might require cavity-wall insulation (£1,500–£2,500), loft insulation top-up (£500–£1,000), double glazing (£4,000–£6,000), and a more efficient heating system such as a heat pump (£7,000–£14,000 after the Boiler Upgrade Scheme grant). The £10,000 cap covers all eligible measures, but many properties will need more than that to hit C. Landlords who exceed the cap can apply for a temporary exemption, but the Energy Saving Trust argues the cap should be reviewed annually against installation costs, which have risen 20% since 2021.
What it costs a typical household
Tenants in poorly insulated homes currently pay an estimated £500–£1,200 a year more in heating bills than those in EPC C properties, according to Ofgem figures. The government’s impact assessment suggests the average tenant would save £350 a year on energy after upgrades. But the upfront cost, which landlords will either absorb or pass on, could push rents up by £20–£40 a month in the short term. The Energy Saving Trust recommends that any rent increase linked to energy improvements be capped or phased, a point the consultation does not currently address.
The catch is that many landlords, particularly those with smaller portfolios, lack the cash flow for a £10,000 outlay. Mortgage rates near 5% and the phasing out of the buy-to-let interest deduction have squeezed margins. The Energy Saving Trust suggests the government reintroduce a targeted grant scheme for small landlords, similar to the now-closed Green Homes Grant, which paid two-thirds of costs up to £5,000.
Timeline and enforcement
Enforcement will fall to local authorities, who can already fine landlords up to £30,000 for non-compliance with the current EPC E minimum. The new regime would require councils to check EPC certificates against the register, a task the Energy Saving Trust says needs dedicated funding. Without it, enforcement will remain sporadic, as seen in the current system where fewer than 5% of non-compliant properties are penalised each year.
Landlords should register for the government’s consultation portal and submit their views before the 5 March 2025 deadline. For those with properties below EPC C, the advice is to start planning now: book an EPC assessment, identify the cheapest measures to move the needle, and consider spreading work across 2025–2028 to avoid a last-minute scramble. The Energy Saving Trust’s response makes clear that the direction of travel is set: minimum EPC C is coming, and the only question is how smoothly the transition will be managed.
Frequently Asked Questions
Since April 2020, private rented homes in England and Wales must have an EPC rating of E or above. The proposed new minimum is C, to be phased in from 2028 for new tenancies and 2030 for all tenancies.
Yes, if all cost-effective improvements have been made up to the £10,000 cap and the property still cannot reach band C, or if the property is listed and consent for works is refused. Exemptions must be registered on the PRS Exemptions Register and last five years.