The planned £10,000 EPC cap: what landlords should keep on file

Further to the previous LandlordZONE article – Tom Entwistle's 9 May – The next big challenge for buy-to-let landlords is setting out the core property file you need for your EPC planning.

My EPC Upgrade provide here some more important information.

You cannot simply claim cash back from a £10,000 EPC cap. If you spend up to £10,000 on energy improvements and your rental property still fails to reach EPC band C, you need to register a cost cap exemption claim on the PRS Exemptions Register

The information provided in this article is for general information purposes only. The content should not be relied upon as legal advice. While we try to keep the information up to date and correct, laws change frequently. Always consult a qualified professional advisor before making decisions or not.

The devil is in the detail

Documentary evidence is vital if your claim is to be successful.

EPCs, invoices, certificates, approvals, completion notices and warranties. These documents should show unequivocally what was installed, why this option was chosen and whether permission or funding affected the job.

A landlord might finish an insulation job with an invoice that says only, 'insulation works'. The invoice records the cost but by no means sufficient detail for your claim.  You need the location (property details), what’s involved in the installation and the product details. It also says nothing about the recommendation behind the job.

Put 1 October 2025 in your diary

The government's January response says spending from that date on relevant measures recommended on the property's EPC, or by a 'relevant expert', is intended to count towards the proposed £10,000 cap. 

The response doesn't define 'relevant expert'; later regulations and guidance will need to confirm this. Parliament has not yet approved the legislative changes. Don’t assume an invoice – or any other invoice – marked simply, for example, 'insulation works', will be enough.

What applies now

The government aims to bring amended regulations into force in 2027, subject to parliamentary approval. All in-scope tenancies would then need to meet the new C-grade standard, using reformed EPC metrics, by 1 October 2030. Detailed landlord guidance and the final metric calculations are yet to come.

Landlords must continue to follow the rules in force now. In England and Wales, properties covered by the domestic minimum energy efficiency standard generally need an EPC rating of E or above, or a registered exemption. Under the current rules, a landlord may need to spend up to £3,500, including VAT, on qualifying improvements.

Keep detailed records to show how you achieved compliance today. Keep the information already published about the 2030 proposal in mind but regularly check the GOV.UK website before acting on the 2030 proposal.

Records to keep after each job

Keep the written recommendation for works with your quote and invoices and save your payment records in the same file. 

Every document and invoice should identify the property and the contractor, along with the certificate or approval required for that measure.

Keep a written record of why you chose the specific works and contractor while the decision is fresh in your mind. A note such as 'loft insulation was done first because the EPC recommended it, and no consent was required'. This is far better to rely on for your claim than some vague recollection later. You need to justify everything.

Keep the grant application, award letter and proof of the amount a funder paid. A bank statement won't show the funder's contribution or conditions. Current rules allow third-party funding to cover all or part of the work, with the landlord paying any required balance. The proposed 2030 cap would include other third-party funding but exclude Boiler Upgrade Scheme grants.

A contractor's quote does not show that permission was obtained. For a leasehold flat, save the request sent to the freeholder and the full reply, including any conditions. Keep any planning advice, permission or listed building consent in the same file. If the decision changes the job, add the revised recommendation as well.

Photographs are important when later work will hide what was installed. Ask the contractor to label them with the address and date rather than leaving them in an unmarked message thread.

Record the EPC report number, lodgement date and expiry date. Check the public register before relying on a saved PDF because a later assessment may now be the current certificate.

Five years later, you may have to explain why the work was not done. A spreadsheet cell marked 'consent refused' will not be enough. Keep both the request and the reply from the freeholder, lender or other decision-maker. If consent came with conditions you could not reasonably meet, keep the evidence, their wording. File the exchange with the exemption-register entry and its expiry date.

A council can issue a compliance notice asking for the EPC, tenancy agreement and improvement records. For all future jobs, list the documents you expect in the quote or scope, then collect them before you sign off any work.

Sources include GOV.UK landlord guidance as at August 2026, the January 2026 government response and the exemption evidence requirements.

Here’s a useful checklist

EPC upgrade records: property checklist

For domestic rented property in England and Wales. Keep a separate file for each property and use the same address or internal reference on every item. Skip anything that doesn't apply to that property.

Property record

☐  Property address and internal reference

☐  Current EPC report number, lodgement date and expiry date

☐  Previous EPCs and exemption records

☐  EPC recommendation or other report used to decide the work

☐  Dated note explaining why the measure was selected, deferred or changed

For each job

☐  Itemised quote, invoice and payment record

☐  Installer details, completion record and any certificate required for the work

☐  Freeholder, tenant, lender or other consent request and response

☐  Planning, listed-building, conservation or building-control record

☐  Dated photographs of work that will be hidden

☐  Warranty and maintenance information

☐  Grant or funding offer, amount, conditions and payment record

Before sign-off

☐  The file identifies the measure, installer, completion date and amount paid

☐  Any required consent or permission is recorded with its conditions

☐  The public EPC register and PRS Exemptions Register have been checked

☐  The next review date is recorded.

Sources checked on 20 August 2026: GOV.UK landlord guidance; exemption evidence requirements; and the "Find an energy certificate" service. General information, not legal or technical advice.

Article content supplied by Amritan Walia, My EPC Upgrade

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