Improving the energy performance of privately rented homes

On 21 January 2026, the Government published its paper ‘Improving the energy performance of privately rented homes’ in response to its February 2025 consultation on the future of Minimum Energy Efficiency Standards (MEES) for privately rented properties in the UK. This announcement provides welcome certainty for landlords, on their future MEES obligations , but does not come without challenge, or cost.

Background

Although it has been mandatory since 2008 for landlords of privately rented properties to provide an Energy Performance Certificate (EPC) to new tenants and for this to have a rating of E or above, the private rented sector continues to suffer from the highest levels of energy poverty of any housing tenure.

The Government has finally confirmed a series of key policy decisions to improve the energy efficiency for up to five million homes in England and Wales by 2030, through its ‘Warm Homes Plan.’ Amongst other things, this long-term strategy will be achieved by reform of the EPC and MEES regime. The Government states that it  promises to provide landlords with ‘clear and actionable information on their properties and the latest measures available to improve energy performance.’

Proposed reform

The Government’s response to is domestic MEES consultation and partial response to its EPC consultation contain the following key take aways:

• EPC of C by 2030: domestic properties will require an EPC of C from 1 October 2030 in order to be lawfully let
• Cost cap for works increases to £10,000: In order to reach this higher EPC rating, landlords may be required to invest up to a cost cap of £10,000, per property before a valid exemption applies. This is fortunately lower than the figure proposed in the original consultation document of £15,000 per property
• Heritage properties: Heritage properties will be required to have a valid EPC when sold or let
• Valid EPCs will be required when a property is marketed: EPCs will be required when a property is marketed (the current 28 day grace period to obtain a certificate after marketing will be removed). EPCs will be based on different metrics but will still last 10 years as they do now
• New EPC may be required when an existing one expires: The Government state they are working on refining their position on this to ensure the MEES policies have their intended effect.

Below we look in a little more detail at the proposed new framework for EPCs, transitional arrangements and importantly what new exemptions may be available if an EPC of C cannot be reached.

A new EPC framework?

A partial response from the Government on their 2025 EPC consultation has been confirmed that there will be a ‘dual metric standard’ for privately rented properties , assessed against two metrics:

• Fabric performance; and
• The secondary standard. Based on either:
  1. smart readiness; or
  2. heating system metrics.

The fabric performance standard, measuring the insulative efficiency, will be mandatory and all landlords will be required to meet this standard.

Landlords will have a choice of two secondary metrics with which they must comply: the heating system metric, measuring energy efficiency of heating technology within a property, and the smart readiness metric, which measures the capacity of a property to accommodate energy-saving technology.

The MEES transitional period

To ensure a smooth transition to the new EPC and domestic MEES regime, EPCs issued before 1 October 2029 and with a rating of C or above will remain valid until expiry. Properties with an EPC rated D or below on 1 October 2029, will be required to commission a new EPC prior to completing improvements works, to comply with the standard set against new EPC metrics. Landlords will also be required to commission an EPC after they have concluded installing the relevant measures to meet the standard in order to demonstrate compliance by 1 October 2030. The cost of these EPCs will count towards the MEES £10,000 cost cap for works.

MEES exemptions and reliefs

Exemptions and reliefs available to landlords are to be extended in recognition of the fact that different properties will require different improvement works to be carried out to them in order to meet the new standard. Once the new exemptions are added the full list includes the following : –

• New landlord – landlords taking on properties with existing tenants will be granted 6 months from the date on which they become the landlord of a property to comply with the new standard
• Third party consent – consent from a relevant third-party, for example, tenant, superior landlord, planning authority, is not granted. The exemption would last for 5 years
• Cost-cap – landlords will not be required to invest more than £10,000 per property in order to meet the new standard. The validity period for this exemption will be 10 years
• All relevant improvements made – if a landlord can produce an EPC stating that there are no further recommendations or a report showing no possible improvements, they will be exempt for 5 years
• High cost exemption – if the cost of making the cheapest recommended improvement is greater than the cost cap, the landlord will be exempt for 5 years
• Negative impacts – if a landlord can evidence that a measure will adversely impact or devalue their property by at least 5%, they may be able to register a 10-year exemption
• Property Value Adjustment – for properties valued at below £100,000, the cost-cap is reduced to 10% of the value of the property. The validity period for this exemption will be 10 years
• Solid wall insulation – landlords of solid wall properties not wishing to install solid wall insulation may record this decision via this exemption, which will remain valid for 5 years
• Portfolio approach exemption – a potential new exemption is also currently being considered by the Government which would allow landlords to group investment properties together and pool their collective cost-caps across all of the properties in the group. The validity period for this exemption if it is included would be 10 years.

It has been confirmed that at present MEES will not apply to short term lets.

Final points to consider

The dual metric standard balances the need to improve energy efficiency in the private rented sector and reduce carbon emissions with granting landlords flexibility in deciding how to achieve this. Whilst these changes were expected, residential landlords may wish to carry out portfolio reviews now in order to plan a program for any works that may need to be carried out under the new regulations. Landlord’s may wish to renew EPCs for those properties they are confident will have an EPC rating of C or above before 1 October 2029; although it is advisable to seek expert advice from an energy assessor before doing this as EPC ratings can go down upon reassessment.

If you have any questions regarding the contents of this article, EPCs, or MEES, please do not hesitate to contact us.