The government has been warned that its plans to improve energy efficiency within English and Welsh privately rented homes are unrealistic as it seeks to enforce a ‘one size fits all’ policy.

It plans to force all landlords to ensure their rented homes reach an EPC ‘C’ grade or above by 2028 regardless of their age, condition or size.

The government also wants to set a £10,000 per property price cap; set a requirement for landlords to install ‘fabric first’ measures; as well as requirements on letting agents and online property platforms to only advertise and let properties compliant with the rules.

“Forcing tighter restrictions on landlords, without sustained financial support, is too ambitious and will not be achieved,” says ARLA Propertymark.

“A key concern from members is that the target is unrealistic, and it is impractical to improve many properties based on the construction type and age.

“For instance, Wales has the oldest private rented dwelling stock in the UK, with 43 per cent built before 1919. Furthermore, too large a proportion of existing privately rented stock requires significant improvements to meet the C rating, which would reduce the amount of housing stock available to rent.”

One size fits all?

The trade body is, instead, calling on the government to implement changes incrementally.

Ministers have said the recently-extended Green Homes Grant that pays for two thirds of a property’s upgrade costs to a maximum of £5,000 will help but ARLA says it ends too early (31st March 2022), particularly given the financial strain many landlords have been under during Covid.

ARLA also says listed buildings and those within conservation areas within the PRS present unique challenges that should be tackled separately, rather than being included in the current ‘one size fits all approach’

The government is now analysing the feedback after the consultation closed last week.


  1. ARLA are spot one! It is unreasonable and impractical to bring large numbers of the PRS housing stock up to a grade C in the time frames suggested – if ever! Implementing the proposals as they stand will result in either properties being rented out illegally or non-compliant properties being sold, reducing the stock in the PRS with more pressure being put on social housing and private rents.

    Quite modern properties on electric only estates & most Victorian / Edwardian terraces require significant investment to reach a C and the costs involved mean it is just not worthwhile for LLs to undertake the work.

    Add to this the fact that the Green Homes Grant is failing miserably to supply vouchers to those trying to access the scheme and the losses sustained by many LLs during the pandemic and you create a perfect storm which could destroy significant parts of the PRS.

  2. I think its a appalling most homes are over 200 years old which always needs repairs plus crazy repairs for bad Tenants who dont pay rent and leave homes in a rubbish site! The cost to get the home to C grade would cost 4/5 thousands pounds. And for what to keep a little fraction of heating !!. So the tenant saved 2 pounds on heating yet each day they are damaging the property on even wear and tear which the landlord will have to replace. Again more pressure on landlord which means rent goes up so again the tenant cant afford . They Will dispute landlord and cause a mess before they leave because they are forced to move to a cheap area with cheaper rent . Why? Because the government private energy contractors want to make money not caring that it goes down hill to the tenants .

  3. Most tenants are single parents or out of work this will effect them the most because of these new pressures and licence fees i mean 6/7 hundreds pounds per a flat is daylight robbery and was the main cause of rent went up over 30%. I and other landlords had no choice but to do the same again the tenants had to move . The hmo licence fee should be abolished. I understand yes you need electric and gas safety checks thats fine but 600 pound extra fee for licence is ridiculous and plain wrong. Especially for each property!

  4. For homes that are clearly not going to achieve a C, should we be issuing Section 21s now to evict the tenants prior to selling and investing elsewhere? Due to the backlog of court cases this might be prudent.

    If a property can’t reach a C and the tenant has proven mental health issues and claimed ‘breathing space’ , how will this affect a landlord’s ability to evict the tenant prior to selling the property?

  5. Another issue – if properties have to be upgraded to EPC C or better then in many cases the work would be significant/disruptive and could only be done if the property is vacant.

    If/when section 21 gets abolished, is the government going to permit eviction of tenants so that the landlord can gain vacant possession to do the EPC work?

    If not, it seems like the landlord would be between a rock (need to improve EPC) and a hard place (cant get the tenant out so that the EPC work can be done).

    I have 4 houses which would fall into this category.

  6. Those with your standard 100 year old properties would be better off selling such properties to mug FTB.
    It would take decades to get payback on achieving C status.
    Just not worth it.

    Sell to a FTB.
    They may CHOOSE to improve the EPC status especially as by doing so when they come to sell they would have a larger group of interested buyers.

    If I was intending to let a property if it didn’t have C status I wouldn’t be interested in buying unless at a massive discount to account for all the costs involved in achieving C status.

    Many FTB do tend to improve and for them it would make sense to carry out EPC C status improvements as they won’t mind living in a building site.
    A ‘luxury’ LL don’t have!

    It probably makes sense for LL to sell off these dud properties to then reinvest in better quality areas so avoiding all the nutters who will be claiming ‘ breathing space’.

    A flight to quality will be a pragmatic business move for many LL.

    Dealing with lower quality tenants and properties just isn’t worth the hassle anymore.

    Govt won’t change the EPC regulations as it is a very useful lever to force LL out of business which is of course exactly what the Govt wants.

  7. Our ex local authority property in Islington has been forced to allow the council to upgrade the communal heating system at a cost of over £14000 for each property owner. We have been advised the new ‘ECO System’ does not improve the EPC from Band ‘D’ due to the construction of the property. Islington Council have advised in writing the maximum EPC for the type of construction is Band ‘D’, where do we go from here!!

  8. The government first needs to modernise the EPC and make it fit for purpose.
    For example I have a 2 bed cottage in a village where there is no gas supply, EPC was 46 (E), put in LPG gas boiler and removed coal fired back boiler and electric immersion heater. The EPC went DOWN to 41. So hot water on demand made no difference, and the fact that in summer one would have had to put on an immersion heater for hot water.
    It gets worse, in order to improve the EPC, I inquired about fitting solar panels as one side of the pitched roof as it is south facing. I could fit 14 solar panels that’s 5kw, and have large 4kw battery in the roof space for even more efficiency. Before I did this I contacted the EPC people to inquire how many points it would give hoping that it would get the property into a D band. Here was the answer.. the EPC does NOT take into account how many solar panels you have, and it does not take into account the battery. In fact if you fit just one panel you will get ALL the points you can for solar. Which is not enough to get my property into D band. Note the property already has loft insulation, and has had wall insulation added internally already. There is no front garden and common ground at the rear is not owned by the property. So ground pumps etc are not an option, Even the EPC inspector said that without modernising the EPC there was no way the property could ever reach a band D!!

  9. Trouble is i cannot find any specific information on exactly what to do (or options) to increase the EPC rating. It seems i’m supposed to randomly upgrade stuff in the vain hope of achieving a better rating, because there’s no point being just below the top of the next band, you need to be certain you’re above it.

  10. Jim’s point is absolutely correct. One needs detail guidance on the effect any improvements made will have on the EPC score. For example if one replaces a non-condensing boiler with a fully condensing boiler (and all else within the property remains the same) then what increase in score results? You can’t get that information without doing the work and paying for a full survey! There appears no straight forward way to input potential improvements (to the SAP programmes that surveyors use to create the score) as a trial test to see if the intended improvement would be value for money.
    As R.F. says the EPC process needs to be made fit for purpose as it is far too idiosynchratic relying heavily on just how different surveyors interpret the situation. It would be very edifying for MHCLG to get the same marginal D to C rated property blind tested by a number of separate surveyors, my bet is they would find a spread of scores well either side of the C threshold.
    There is a very comprehensive report entitled “EPCs and the Whole House Approach: A scoping study” produced in May-2018 by the Sustainable Traditional Building Alliance that clearly describes the many weaknesses of the present EPC system


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