A growing chorus of landlords and housing experts have queried the EPC appraisal process with some claiming that expensive upgrades won’t make any difference to the final EPC score.

Landlords will be expected to raise their properties to band C for all tenancies by 2028, but in a recent survey of 70 valuers by Countrywide Surveying Services, more than 30% said EPCs were not accurate or a reliable source or of high quality.

“The quality of EPCs is often questioned as is the calculation methodology and the growing number of assumptions made to produce the report,” says Ana Bajri, senior technical manager – risk and compliance.

Professor David Emmerson, whose family owns five rental properties, says the country is struggling under a grotesquely unfit-for-purpose algorithm which rewards gas boilers and ‘modern’ night-time electric storage heaters from the 1970s.

He adds: “There are several flaws in the EPC methodology as the price of external energy purchased is factored in the EPC algorithm which makes a nonsense of the EPC being a measure of the intrinsic energy performance of the dwelling itself.”

Not objective

One landlord agrees the EPC method of rating properties is not objective or consistent. “I have two identical purpose-built flats in the same block that have been rated differently, which suggests that the rating process is not standardised or fair,” she says.

“How can landlords work out the effect of improvements if the ‘experts’ responsible for determining the ratings don’t even know?”

Another landlord’s property received a D rating but she discovered it needed thousands of pounds spent on improvements which she could never recoup as the rent is only £530 a month.

“Our rental house is stone built and our tenant is very happy, and states that the house is warm. If we sell up, what will happen to our tenant?” She adds: “I would be happy to support a campaign to fight this injustice.”

NRLA says…

An spokeswoman says: “EPC assessments don’t take into account measures which may be hidden, for example cavity wall insulation, unless the property owner has documentary evidence that they have been installed.

“This can mean that assessments and ratings are inconsistent. We are calling for building renovation passports to replace EPCs.

“These would provide accurate information about the measures already installed and identify what further works can be made to properties in the long-term. 

“They would also provide landlords with useful information about what measures will improve their property’s energy efficiency and provide easily comparable information for tenants.”

Read more criticism of the EPC system.


  1. I have been a landlord for well over a decade, providing two homes to families. I have observed all of the ever inreasing costly legislative burdens placed on rental properties. I care for my tenants who are entitled to live in a safe , affordable and comfortable property. I have good tenants, and consequently tend not to raise the rent over their period of tenancy ,which can be some years.

    I do not think I am alone amongst many UK landlords in looking after decent tenants. For me it’s the right thing to do.

    Sadly,however, this further ill thought out plan has made me decide to leave the sector for good, and will sell up before 2028. This will mean two families will be looking for scacer rental property, or join the endless local authority housing lists. Often the same authorities who now see an opportunity to raise more money from landlords via their wasteful licencing schemes.

    The people who lose out to being squeezed by National and Local government policies, the tenants, are the very ones they purport to be helping. Either Westminster and local Council authorities lack the insight to see this, or they simply don’t care.

    So yes I am very saddened at leaving the sector and feel sorry for the future for those who rely on the private rental sector, both landlords and tenants.

  2. A rating of C or above by 2028? Are they mad? A huge amount of houses would need to be knocked down and rebuilt to achieve such a ridiculous rating. Another ‘great’ idea from some government body, which has not actually taken the time to see if its realistic or even bother to consult those that will be effected. I can only think the government choose not to discuss such proposals with the actual individuals concerned because they would be given a large dose of reality.

  3. I agree that the basic algorithms do not produce a good energy efficiency value, currently air source heat pumps do not do well on EPC’s yet the govt are pushing them which in theory is going to make achieving C even more difficult… That in itself makes a nonsense of EPC’s as a tool to drive down carbon emissions.

    A recent semi-detached property of mine was rated D when a new EPC was done, while the neighbour was C.
    A detailed comparison showed that my place had more insulation & more energy efficient lighting so I questioned the EPC with the assessor and he concluded that I should remove the electric fire that is in the living room. I don’t think it’s ever been used by anyone (The property is centrally heated) and is effectively ornamental.

    Just as an earlier contributor I bought a flat in a small block of 12 units built in 2000 yet when looking at the EPC’s they vary between flats with D to C but I have noticed that the properties that have no electric fire in the lounge are rated C. From what I can tell all the flats had boilers installed in 2000 and all had an electric fire installed too (Presumably the thinking was that in the summer no need to fire up the boiler just switch on the fire for a few mins if it got a bit chilly in the evening.

    My previous experience with the semi taught me a lesson and I took out the electric fire and made sure all lighting was LED and my flat is now rated C up from a D. No other changes such as boiler upgrade was required… total cost about £10 for LED’s

  4. I am leaving the sector for the same reasons as Ken above. I also provide good quality housing for families and have never put up rents for existing tenants some of whom are there for years. However the costly legislation and criminalisation of good landlords at the hands of LAs and legislation that means unscrupulous tenants can take advantage without repercussions, make the PRS unviable. It simply too risky and too expensive. I also feel sorry for good tenants chasing after scarcer and more expensive properties. These are the repercussions of govt policy. I also laugh out loud when I hear LAs offering discounts on licensing for C rated properties in wards where the housing stock is predominantly pre war/victorian with no chance of a C. Their focus is on the money, clearly.

  5. Apart from algorithms changing so its like shooting in the dark, EPCs make incorrect assumptions on things such as cavity wall and underfloor insulation – thereby creating a completely false EPC rating. This followed by the green debacle that gives my gas heated houses a better EPC that those heated by green electricity – the whole thin is a complete mess. What do I do when I cant replace a gas boiler – who knows! Time for a exit strategy.

  6. As Kev B’s comments I am one of the landlords that tries to ensure that my tenants are well catered for and like him once the tenant is in situe I do not raise the rent, I have three properties one of which is occupied by a couple who moved in January 2008, they are still paying the rent that was agreed over 13 years ago. They are excellent tenants as are the tenents in the house next door who have been in occupation for just three years having moved from a smaller property I own but retaining the rent that was agreed over 5 years ago. The property they moved from just before covid lock down has been renovated with replacement double glazing, it has a new gas boiler and well insulated roof space. It has however solid floors and walls and has ben given a performance certificate of D, as have the two other occupied properties.

    Each property has been estimated to require a minimum of between £8,000 and £20,000 spending in order to reach a rating of C with estimated savings in energy of £267.00 per property.

    The certificates state that the average household produces 6 tonnes of CO2, my properties produce 3.4 tonnes, 4.6 tonnes and 4.0 tonnes respectively.

    There are a number of options that are being forced on myself and I would imagine on the vast number of good landlords (for I don’t believe that the majority of landlords are the villains that all political parties would appear to believe they are) I can commence by spending the total annual income from each of my properties in these demanded so called improvements that will scarcely help my tenants, but I will be forced to increase their rents in order to claw back costs that they do not appear to want or sell the properties with the tenants in situe and I do not believe that an incoming landlord would be willing to accept the rents that I do, thereby increasing substantially the annual costs to my tenants, or I can recover the properties and sell them unoccupied.

    As ever political expediency and incompetent thinking will force ever increasing costs on those less able to afford.

  7. We set monetary policy to achieve the Government’s target of keeping inflation at 2%. Low and stable inflation is good for the UK’s economy and it is our main monetary policy aim. We also support the Government’s other economic aims for growth and employment.
    Bank of England

    Note it does not say below 2% The bank aims for 2% therefore any investor who is not keeping up is holding a diminishing asset.

    Every year utilities increase, council tax, etc etc
    I would argue that PART of the reason EPC improvements are seemingly expensive is because some landlords are not keeping up with inflation therefore over time the gap between income and the required expense of maintenance grows ever wider.

    I review rents on an annual basis and make adjustments accordingly looking at the CPI, RPI, Inflation rate and prevailing market conditions and aim to find a reasonable price point.

    In reality tenants have an annual (Small) rent increase, it is something they are used to, its not painful because its small and they stay put because they know that moving will be either the same rent or more elsewhere.

    The reality is that if for any reason a LL needs to evict, they will face exactly the same battle whether they had fixed the rent for 10 years or made annual increases and the courts will not view you any more favourably regardless of your rent policy.

    • I review and increase my rents each year, but an investment of £10k will have a payback time of over 30 years without taking into account any of the other increasing costs!

      • Oh I totally agree…

        I was more addressing some comments from LL’s where they say they haven’t raised rents for several years. To me this is an unsustainable business model and must impact the capacity to make improvements of any sort including EPC’s if incomes are allowed to diminish over time.

        I did highlight that it was only PART of the problem.

        My own remedy has been to sell underperforming properties and re-invest in modern properties that either already meet EPC C targets or are close to and will be easy to cross the line into EPC C.
        I don’t try to fix difficult properties I’ve sold the, leaving them for other people to sort out.

    • You are confusing maintenance spending with capital expenditure. The epc improvements, by definition, are capital items. And with very few exceptions, are expensive and achieve little by way of energy savings. Marginal increases in rent clearly will help but you still have a large capital outlay.
      If it wasn’t for the costs of selling and buying I would do exactly what you did and sell the older properties as achieving a C rating is near impossible.
      What a moronic Government we have!

  8. I have 6 properties, 5 x EPC E and 1 x EPC D.

    It will require too much spend with negligible return to lift these to EPC C so I will be evicting the tenants and getting out of the PRS.

    It’s all a joke.

    • Totally agree… You could sell and re-invest in modern places but like many LL’s me included I’m looking to reduce my PRS investments. The risk-reward scales are no longer favourable.

  9. As a long standing Landlord of multiple properties I have – as with many others – had many impositions placed on me over the years, many in the name of “driving up the quality of the private rented sector homes” or “eradicating rogue Landlords” etc. As with majority of Landlords I try to provide good quality, safe properties at a reasonable rental figure to both private tenants and also DSS/Homeless tenants.
    In regard to the imposition of the EPC minimum rating of “C”, those who are proposing such impositions in the name of “bringing the properties owned by private Landlords up to the same level as privately owned properties” are clearly out of touch with the realities. Below I cite a few reasons why this is;

    I am not aware of any of the properties in the general vicinity of any of my properties that have energy saving measures in place that are better than those associated with my properties – modern condensing boiler, UPVC DG, high levels of loft insulation, LED lighting and the like, therefore it is highly unlikely that their EPC rating are any better than those associated with my properties.

    On close inspection of recent – renewed – EPC’s, I noted several anomalies, the principal one being that the EPC’s had totally ignored loft and/or roof insulation that had been installed. When I asked the Assessor why he had not taken the insulation into account his response was that, “The guidelines for Assessors is that inspections should be non invasive which also includes non inspection of roof voids”. There were other anomalies in regard to the content of EPC’s for individual properties where, clearly the Assessor had failed to note or notice things such as controls, thermostats, etc. Clearly such facets have a considerable impact on the final rating for which, if the proposed imposition of a minimum of a “C” rating is put in place, Landlords will ultimately be financially penalised all as a result of the guidelines issued to Assessors and/or the incompetence of the Assessors.

    It is undoubtedly correct to state that many MP’s and others associated with Government are also investors in property and are also Landlords, indeed, I can think of several such people, however, unlike the majority of us Landlords, such people generally invest in new or refurbished modern properties and, only let their properties – generally via agents – to the top end of the market and charge “top dollar” for the rents. The rest of us who generally own older style but refurbished properties – generally early 1900’s solid stone construction – and who are charging a reasonable level of rent will, even with all other energy measures being at a good standard will struggle to improve the ratings to a “C”, partly as a result of the above stated reasons and also due to the basic construction of the properties. The result will be a great deal of expenditure on external or internal wall insulation which will undoubtedly drive up rents.

    Governments and their advisers really do need to stop and – just for once – think about the impact that their proposed impositions will have. Sadly I somehow doubt whether they will do so.

    • I would contact the head office of the EPC assessor because whenever EPC’s are done for me I try to be present and they always measure the insulation. They don’t need to go inside the loft just a decent torch to see around and they can measure the thickness by the loft hatch.

      For the sake of 60 quid or so it might be worth getting a second EPC with a different company especially if its borderline D to C for example.

      • Totally agree with your input in regard to ensuring that I am present for any and all EPC’s undertaken in the future Dave, just to make certain that they do not overlook any of the measures that are in place. That said, it is incorrect for this to be necessary to ensure that the EPC is a true assessment of the “energy performance” of a property and only goes to demonstrate that, people who are undertaking such checks should have a proven background in buildings and/or their construction and/or building services generally.

  10. I had an EPC done on one of my rentals last year, it was rated D. As I was looking on the EPC register I saw that the neighbour had just had a new EPC so I compared the details on his with mine. The only differences was he had 100% energy efficient lightbulbs and I had 86%. I had 70mm more insulation in the loft than him. His was rated a B, I will be using his assassor for my next EPC.

    • Attaining a B…
      I have found to be impossible so far and all my properties are built after 1998 have 270+mm Insulation, 100% LED’s all boilers are less than 10 years old, mostly combi’s and have TRV’s etc.

      If I buy a property that is a bit run down then during the initial refurb I replace the radiators at the same time as the boiler, fit LED’s and upgrade the insulation if required never and got to B yet!!!!

      We all need to use that assessor I think 😊

  11. The EPC system is full of flaws, some outlined by other contributors. I had an assessor tell me that replacement of a 1960s back boiler with a modern gas combi would not necessarily improve the EPC rating! I changed it anyway, because it was obviously the right thing to do. I have had recommendations with payback periods running to over a hundred years, which would’ve cost a fortune and been highly inconvenient, which were obviously really stupid investments. I had a recommendation to install cavity wall insulation. When the cavity wall guy showed up it took under a minute to figure out it had already been done. The EPCs are riddled with errors like this, they are inconsistent, follow incomprehensible methodology and nearly always make some daft recommendations.

  12. I should add that I have zero confidence in the logic of replacing perfectly good gas boilers with those heat pump monstrosities. They cost a fortune in £, but also in carbon emissions, and then you have the environmental cost of scrapping the older boiler.

    • Most Heat pumps also require over-size radiators so there is every likelihood that the existing radiators will have to go too…. All told the only thing that will remain in place will be the copper pipes.

      • I understand that modern-ish houses with 10mm pipe will also need to have these replaced with 15mm pipes so the whole process is incredibly destructive! Plus you will need a top up source of heat in the winter & to re-install the hot water tank you took out!

  13. re EPC, I find that the newer method which includes orientation of the property w r t sunshine more real and accurate. Also cavity wall insulation can be verified by the ‘bore holes’ in the building without certification. I live in a property where the back faces due south with minimum shade. My heating bills are at least 40% lower than a shaded east/west property. If it’s a sunny winters day, I don’t need heat unless it’s sub-zero outside, and with that getting more and more rare, my heating bills are falling. Only Issue with climate change is too much heat in summer, but blinds and closing the doorsduring the day, have worked wonders for the very hot days this year; – no fans or air conditioning needed. Also cellars help to keep a property warm, as cellat temperatures are usually around +12 all year round.

  14. I bought a beautiful grade II listed ‘modern’ studio flat, built circa 1980, and after decorating it and changing the lightbulbs to LED ones, had it assessed as it was demanded it for letting. Even if I’d wanted to there was nothing else I could have done to the property to ‘improve’ it to a higher grade. (I’m aware that for selling a listed property an EPC is not required.) The EPC certificate, grade D, said the property ‘needed double glazing’ – it already had it and wall insulation. The property is very warm as a result of its exterior slate covered dormer construction! I challenged the assessor who blamed it on the ‘algorithm’. There is a very real problem of ghettoisation with the current EPC system which disproportionately affects leasehold block properties because ‘improvements’ are often reliant on the freeholder. There are two main issues for me. A) The assessors have immense power and any previously unqualified individual can ‘train’ to be one and then added to the register. “City & Guilds Level 3 Diploma in Domestic Energy Assessment will be completed in a week.” B) The main benefactors of the present EPC system are house builders but there is no guarantee that a new property will receive a grade C or above certificate.

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