Why the private rented sector EPC deadline must stay on track

Nearly 2.5 million private rented homes in England still fall below EPC band C, according to government data. That is roughly one in three rental properties, and the tenants living in them pay, on average, £340 more per year on energy than those in C-rated homes.

The Energy Saving Trust has now submitted its formal response to the government consultation on tightening the minimum energy performance standard for private rented homes. As reported by the Energy Saving Trust, the charity supports the government’s proposed 2028 deadline for all new tenancies to meet EPC C, with existing tenancies following by 2030. But the detail, who pays, how much, and what counts as a valid exemption, will determine whether the policy works or collapses into a compliance theatre.

Who qualifies, and who doesn’t

The proposed rules apply to all private rented homes in England and Wales. Landlords must ensure their property achieves at least EPC C before granting a new tenancy from 2028. Existing tenancies get until 2030. The Energy Saving Trust recommends that exemptions should be limited to properties where the cost of improvements exceeds a cap, likely £10,000 per property, adjusted for inflation, and for listed buildings where planning constraints prevent wall insulation.

But the trust also warns against blanket exemptions for small landlords or older housing stock. The catch is that a third of non-compliant homes are pre-1919 terraces or flats with solid walls. Insulating those costs £8,000–£15,000 externally or £6,000–£12,000 internally, according to Energy Saving Trust figures. For a landlord on a single property with a modest yield, that could wipe out two years of net profit.

What it costs a typical 3-bed semi

Take a typical 1930s semi-detached rental in Manchester, currently rated EPC D. To reach C, the landlord would likely need cavity wall insulation (if feasible), loft insulation top-up to 300mm, double glazing on any single-glazed windows, and a modern gas boiler or heat pump. The Energy Saving Trust estimates the total at £7,500–£10,000. The tenant’s annual bill drops from £1,450 to about £1,100, a saving of £350 a year.

For the landlord, that is a payback period of 21–28 years on the tenant’s savings alone. But the property’s value typically rises by 5–8% after an EPC upgrade, and void periods shorten because C-rated homes let faster. Ofgem data shows that homes in bands A–C also attract a growing share of tenant searches, especially among younger renters who track energy costs closely.

Grants and timelines for early adopters

The Boiler Upgrade Scheme currently offers £7,500 towards a heat pump installation, and the Great British Insulation Scheme covers cavity and loft insulation for low-income households. Landlords can also access the Local Authority Delivery scheme in some areas. But these pots are limited and often oversubscribed. The Energy Saving Trust recommends landlords start EPC assessments now, not in 2027, because installers are already booking 6–12 weeks out in most regions.

What the consultation does not address is enforcement. Currently, local authorities can fine non-compliant landlords up to £5,000 per property, but prosecutions are rare. The trust says the new system needs automatic penalties linked to council tax records and tenancy deposit schemes, not a complaints-based model that punishes only the worst offenders.

What to do next

Landlords with properties below EPC C should request an Energy Performance Certificate assessment this quarter. If the report identifies insulation or heating upgrades, apply for a Boiler Upgrade Scheme voucher before the April 2025 budget allocation runs out. Tenants in EPC D–F homes can ask their landlord for an improvement plan and, if refused, contact their local authority’s private sector housing team. The 2028 deadline is not a suggestion, it is a statutory instrument waiting to be laid before Parliament.