The Future of Domestic EPCs

Significant changes are on their way to the format of Energy Performance Certificates (EPCs), the way they are produced, and the minimum standard required when properties are rented out in the Private Rental Sector (PRS).

The Scottish Government has officially laid the new 'Energy Performance of Buildings (Scotland) Regulations 2025' in the Scottish Parliament, and the regulations are confirmed to come into effect on 31st October 2026.

https://www.gov.scot/publications/energy-performance-buildings-scotland-regulations-2025-update-government-response-epc-reform-consultations/

In addition, the Scotish Government have consulted on introducing MEES in Scotland, and we are still awaiting an update from the Scottish Government on this. Currnetly MEES does not apply in Scotland:

https://www.gov.scot/publications/consultation-draft-energy-efficiency-domestic-private-rented-property-scotland-regulations/

So the changes to EPCs mentioned in the 'Energy performance of Buildings (Scotland) regulations 2025' will come into force on the 31st October 2026.

The main points are:

• All EPCs issued under the previous 2008 EPB Regulations will cease to be valid and a new EPC meeting the requirements of the 2025 Regulations will be required for all properties from October 2026. This is subject to specific transitional arrangements:
  • Properties which are already advertised for sale or for let on the day on which the regulations come into force
  • Short term let properties which are often continually advertised
  • Certain large non domestic buildings (frequently visited by the public) which are required to always display a valid EPC
• As previously, an EPC will be required when:
  • A new building has been constructed
  • A building is to be sold
  • A building is to be let to a new tenant
• The EPC penalty charges will be retained at the level currently set in the 2008 Regulations

• A new rating system will be introduced for domestic buildings, including the follwoing metrics, instead of the single cost-based metric used currently:
  • Heat Retention Rating (reflecting fabric energy efficiency),
  • Heating System Rating (covering type, emissions and efficiency),
  • Energy Cost Rating (an updated version of the existing Energy Efficiency Rating).
• A new rating system will be introduced for non-domestic buildings, including the following metrics, instead of the single emissions baseed metric used corrently:
  • Energy Performance Rating
  • Energy Use Rating
  • Direct Emissions Rating
• A new Property Report will set out potential improvement measures that could improve the energy efficiency and lower the energy costs of the building; and which will set out information on potential alternative heating systems which could reduce emissions (and their potential installation and running costs)
• The validity period of EPCs will be reduced from 10 to 5 years.
• Strengthened operational governance arrangements will be introduced for EPC assessors and Approved Organisations through new accreditation scheme requirements (including new onsite audit and inspection requirements) to enhance quality assurance for consumers.
• EPC lodgement fees will be ammended to £6.00 for domestic certificates and £15.50 for non-domestic certificates, to ensure that they can cover the costs of providing the technical and operational infrastructure (EPC Register, calculation methodologies, onsite audit and inspection) to support the EPC regulations and which provide benefit to consumers.
• The requirements on disclosure of energy performance data will be updated.

There are other mundane points as well, which I have not included here.

The transitional arrangements are as follows:

On the 21st January 2026, the government released its initiative called the 'Warm Homes Plan':

https://www.gov.uk/government/publications/warm-homes-plan

On the same day, three additional EPC related documents were also released:

Reforms to the Energy Performance of Buildings regime (a partial update following the E&W EPC reform consultation last year)

https://www.gov.uk/government/consultations/reforms-to-the-energy-performance-of-buildings-regime

Improving the energy performance of privately rented homes: 2025 update (an update regarding future E&W MEES following the consultation last year)

https://www.gov.uk/government/consultations/improving-the-energy-performance-of-privately-rented-homes-2025-update

HEM EPC Wrapper Consultation (a new consultation regarding banding thresholds etc).

https://www.gov.uk/government/consultations/home-energy-model-energy-performance-certificates

The proposals include: 

• Proposal for a modular approach to EPC assessments
• Fabric Performance Metric - to use the FEE Methodology, incorporating a single standard heating/cooling system, and graded to result in C/D band threshold in line with most existing EER ratings around this threshold. Optional SMETER HTC data entry.
• Heating System Metric - To include efficiency of space heating, hot water, cooking and cooling. Will also include emissions intensity. Primary fossil fuel systems to score D or below. Heat pumps to score C or above. Electric panel heaters without storage to score D or below. Guarded wording ref storage heaters being a C likely depending on type. All electric property preferred. Electric cooking to assist with band A/B ratings.
• Smart Readiness Metric - To be a numerical rating (1 to 100 with bands A to G) and based on a standardised model of occupant behaviour. To consider: Smart meters, solar PV and other micro generation, electric batteries, thermal energy storage systems, smart heating controls, smart EV charge points, and connection to the electricity network. Considerations for the threshold of getting a 'C' - eg Solar PV plus a smart meter or maybe Solar plus battery plus smart meter.
• Energy Cost Metric - Predicted cost (£) of energy use
• Legacy EER Rating - To be present on EPCs until at least the end of 2029 (not clear whether this will be calculated using SAP or HEM?). This will eventually be removed from EPCs.

Then on the 28th January the following executive summary was published:

Improving the energy efficiency of socially rented homes in England (Summary of consultation responses)
https://www.gov.uk/government/consultations/improving-the-energy-efficiency-of-socially-rented-homes-in-england/outcome/improving-the-energy-efficiency-of-socially-rented-homes-in-england-summary-of-consultation-responses

• This is effectively an executive summary of decisions and a full government response is to follow.

• Social housing providers will be required to meet one of the new 'reformed' EPC metrics (building fabric, heating system or smart readiness) by 2030.

• They will then be required to meet a second metric by 2039.

• Providers can choose any of the metrics - they will not be required to apply the 'fabric first' principle.

• EPCs with an EER of C or better issued up to 2030 will be deemed to meet the standard until they expire.