The Warm Homes Plan & MEES for privately rented homes – EPC C by 2030

On the 21 January 2026, the government published its long-awaited Warm Homes Plan (WHP). This was a key measure in Labour's manifesto. The WHP covers a lot of ground, setting out a detailed package of measures which are focussed on upgrading homes to reduce emissions, adapt to climate change and lower household costs. A new Warm Homes Agency has been announced to support the delivery of the WHP. The document sets out the government’s plans for heat networks, as well as including a focus on the jobs and skills needed to support delivery of the measures.

Also included in the WHP is a confirmation that in relation to Minimum Energy Efficiency Standards (MEES) and privately rented homes in England and Wales, ‘landlords will need to upgrade their properties to meet EPC Band C across two metrics by October 2030, unless their property has a valid exemption’.

The government consulted on its proposals in relation to MEES for privately rented homes in February 2025, in a consultation entitled ‘Improving the energy performance of privately rented homes: 2025 update’ (the ‘2025 Consultation’); and alongside the announcement in the WHP, it has published a response to this consultation. The government has also published a partial response to the consultation on Reforms to the Energy Performance of Buildings regime which was published in December 2024. The two consultations are closely linked, with the outcome of the consultation in relation to MEES for privately rented homes dependent on the outcome of the consultation on EPC reforms and the proposed changes to the EPC metrics. We look at both consultation responses below.

Given previous government announcements, the headline requirement that privately rented homes in England & Wales will need to meet equivalent of EPC C by 2030 is not a surprise move. However, landlords will welcome the certainty and there is some useful policy detail (including changes to some of the measures proposed in the 2025 Consultation) confirmed in the responses.

So, what does the consultation response to the Reforms to the Energy Performance of Buildings regime say in relation to EPCs?

It is worth highlighting that the ‘Reforms to the Energy Performance of Buildings’ consultation covers both domestic and commercial EPCs, whereas the 2025 Consultation covers the domestic private rented sector only.

What EPCs measure...

• In relation to domestic EPCs, the consultation response states that the government will:
  • Replace the existing single cost metric with four new headline metrics: energy cost, fabric performance, heating system and smart readiness. The government views that moving away from a single headline rating and providing a broader range of metrics ‘will allow for a more comprehensive assessment of a building’s energy performance, providing owners and occupiers with a wider range of retrofit options’. The response also notes that these additional metrics are expected to increase ‘the effectiveness of EPCs for older properties’.
  • Introduce two secondary metrics, in addition to the four headline metrics. These are an energy demand metric and a carbon-based metric.
  • Retain the legacy Energy Efficiency Rating (EER) to support the transition to the new style EPCs. The response notes that this should ‘enable comparison with current EPCs, and to support ongoing compliance with existing regulatory measures until it is no longer required’.
  • Develop guidance for both consumers and industry to support the new style of EPCs.
• For commercial EPCs, the government states it will maintain the single carbon-based Environmental Impact Rating (EIR) as the headline metric.

When EPCs are required…

The consultation also looked at when EPCs are required. The government has decided on the following:

• The government plans to maintain the 10 year validity period for both reformed and existing EPCs.
• Regulations will be updated so that an EPC is required at the point of marketing a property, rather than the point of sale or rent.
• All heritage buildings will be required to have an EPC.
• The consultation also confirms a valid EPC will be required for ‘a whole HMO when a single room is let’ and for ‘short-term rental properties irrespective of who pays energy bills’.

The government notes it is ‘working to refine the position on requiring a new EPC when an existing one expires for all private rented buildings’.

A partial response

This is a partial response to the consultation. A further response in relation to outstanding points will be published ‘in early 2026’ (this will cover outstanding questions; Display Energy Certificate (DEC) validity periods; EPC and DEC data; managing EPC quality and air conditioning inspection reports (ACIRs)).

In relation to MEES for privately rented homes...

The 2025 Consultation response sets out a summary of the government’s final policy position:

What’s in?

• The response confirms that private rented homes ‘will be required to meet a dual-metric standard set against new EPC metrics’. Landlords will first be required to invest towards installing measures to meet a primary fabric performance standard. The response then notes that once ‘the property meets this standard, or a valid exemption is registered, the landlord must then invest towards installing measures to meet a secondary standard set against either the smart readiness metric or the heating system metric, the choice of which will be down to the discretion of the landlord’. The response is clear it is a dual approach – even if an exemption is registered for the fabric performance standard, a landlord must still meet the secondary standard, unless further exemptions apply.

• All tenancies within scope of the regulations must be compliant with the standard by 1 October 2030. The response states that there will not be an earlier compliance date for new tenancies. This is a departure from the proposal in the 2025 Consultation, which indicated that the new MEES requirement would apply to new tenancies from 2028 and all tenancies from 2030. Given there has been so much delay and uncertainty in relation to the policy, landlords are likely to welcome the later compliance date for new tenancies (particularly as the detail on what the requirements for EPC C will be under the new EPC metrics has not yet been confirmed).

• Private rented homes that score a C or higher against the Energy Efficiency Rating (EER) displayed on existing or new EPCs before 1 October 2029 will be considered compliant with the higher standard until this EPC expires or is replaced. The response notes that Landlords of privately rented homes that do not meet this standard by 1 October 2029 ‘will need to take action to improve their property to meet the standard set against new EPC metrics before 1 October 2030’. They will be required to commission a new EPC that displays the new metrics. This is ‘to ensure the action they take is informed by the recommendations under these new EPCs’. Once the recommended works have been undertaken, they will need to commission a post-retrofit EPC before 1 October 2030 to demonstrate compliance. The response notes that reasonable EPC assessment costs (which will be ‘set out by government’) will count towards the cost cap.

• Landlords will be required to invest up to a maximum of £10,000 per property on improvements to meet the standard (the ‘cost cap’). After which they can register a 10-year exemption to continue to let the property if it does not reach the standard. The policy notes that landlords will be able to count spending towards the cost cap on relevant energy efficiency measures that have been installed since 1 October 2025. Third party funding will also count – including funding from government schemes (except funding from the boiler upgrade scheme).

  Again, this is a departure from the government’s position in the 2025 Consultation. The 2025 Consultation proposed that landlords should be required to invest a maximum of £15,000 inclusive of VAT per property. Interestingly, the impact assessment published alongside the government response estimates that the average per-property spend required to meet the standard will be £5,400. The 2025 Consultation had a slightly higher estimate at ‘between £6,100 and £6,800 worth of investment’.

  The government notes that as it is going ahead with a lower cost cap, it has decided that the cost cap will ‘undergo a review every five years, to take into consideration inflation to the cost of purchasing and installing measures, as well as other potential factors that could affect the impacts of the policy’. However, the response confirms that the first review will not take place until after the compliance date of 1 October 2030.

  • In relation to other exemptions:

    • A ‘Negative impacts’ exemption will be introduced. This will be for ‘circumstances in which landlords can demonstrate installing a measure would negatively impact the fabric or structure of the building’. The consultation notes that this combines two existing exemptions, the ‘Devaluation’ exemption and the ‘Wall insulation’ exemption
    • A ‘Solid wall insulation’ exemption will be introduced.
    • A ‘Property Value Adjustment’ exemption’ will be introduced for properties valued below £100,000, whereby these properties will be subject to a lower maximum spend requirement equivalent to 10% of the property’s value.
    • The existing ‘High-cost’ and ‘Third-party consent’ exemptions will remain and the ‘New landlord’ exemption will be simplified. The ‘All Relevant Improvements Made’ exemption will also be retained.

    The government will also ‘explore the possibility and logistics of a portfolio approach exemption whereby landlords with larger portfolios could, instead of assigning a cost cap to individual properties, multiply the cost cap by the amount of properties they have (up to a set amount) and utilise this total across their properties in to meet the higher standard’.

  • Local authorities will be able to issue a maximum penalty of £30,000 per breach for each property found non-compliant. Fines may also be issued if, for example, landlords have provided false or misleading information to the PRS MEES Exemptions Register. The government notes it will publish detailed guidance on fines and enforcement.

    The Renters’ Rights Act 2025 will introduced a PRS database. The government’s implementation timetable for the Renters’ Rights Act envisages a phased introduction of the PRS database. Stage one is expected from ‘late 2026’ and stage two in 2028. The response notes that the PRS database will enable local authorities to identify which properties in their area are let in the PRS. Compliance can then be checked via the Energy Performance of Buildings Register and the PRS MEES Exemptions Register.

What’s not (for now…)?

The government notes that ‘at this time’ the following measures are not being taken forward:

• Short-term lets will not be required to comply with PRS MEES but this will remain ‘under review’. When talking about short term lets this is focussed on the nature of occupation (eg a holiday let which is not the occupier’s primary residence) rather than the length of term.
• A requirement for lettings agents and online property platforms to only advertise compliant properties will not be implemented at this time.

The new ‘EPC C standard’

As noted above, the WHP states landlords will need to upgrade their properties to meet EPC Band C across two metrics by October 2030, unless the property has a valid exemption. This will of course be an ‘EPC C’ under the new form of EPCs with revised metrics (subject to some transitional measures for properties with an unexpired EPC C or above).

When discussing implementation, the response notes that ‘[f]ollowing the planned confirmation of the final policy on new EPCs and how the Home Energy Model (HEM) will calculate new EPC bands, government will be able to confirm how the exact target of C will look on new EPCs’.

On 21 January 2026, the government published a consultation on the Home Energy Model: Energy Performance Certificates. The HEM is the new methodology underpinning EPCs. The consultation is seeking views on how the HEM will be used to carry out EPC assessments. This consultation summarises the four key metrics which will be at the core of the new EPC as follows:

• The Fabric Performance Metric measures a building’s thermal performance.
• The Heating System Metric is an assessment of the technologies in a dwelling which generate heat – for space heating (and cooling), hot water, and cooking.
• The smart readiness metric aims to assess the building’s potential to self-generate energy (usually from solar panels), and to integrate smart technologies that can optimise energy consumption and allow consumer-led flexibility in demand, to enable electricity bill savings
• The energy cost metric will assess the predicted costs of energy use in a building and provides an independent estimate of likely energy bills for buyers and tenants.

It is proposed the all the metrics will be rated in bands A-G apart from the energy cost metric which it is proposed will be shown in terms of an estimated energy bill figure rather than a rating. The consultation closes on 18 March 2026.

Timings

The ‘Reforms to the Energy Performance of Buildings’ consultation response states that the ‘Government is working hard to deliver new EPCs from October 2026. We recognise the timeline is ambitious and want to work with industry to build a shared implementation plan and test our assumptions’.

The response to the 2025 Consultation sets out a detailed timeline. The government is targeting 2027 to bring into force legislation to raise minimum energy efficiency standards for privately rented homes. Landlords will then need to comply with the new requirements by 1 October 2030.

It is also worth noting that the government issued a consultation in July last year proposing that all socially rented homes reach EPC C or equivalent by 2030. The consultation closed on 12 September 2025. In the 2025 Consultation the government states that it is ‘currently considering the responses to this consultation and will publish a government response in due course’.

Update on MEES for socially rented homes: On 28 January 2026 the government published a summary of the consultation responses to the consultation ‘Improving the energy efficiency of socially rented homes in England’. It noted that the 'evidence has been used by government to inform the decisions announced on 28 January 2026 as part of the update on the Decade of Renewal in Social Housing. It is intended as an executive summary and is not intended to replace the full government response which will be published shortly'. Although the full response has not been published, in the policy statement for the new Decent Homes Standard the government sets out its policy on what social housing providers must do to comply with MEES in the social rented sector:

• All new and existing social rented properties must be at an EPC C or equivalent by 1 April 2030, or for a valid exemption to have been registered.

• However, where it is a ‘new’ EPC social housing providers will only be required to achieve EPC band ‘C’, against any one EPC metric by 1 April 2030. Social housing providers will be able to choose from any of the following:

  • fabric performance,
  • smart readiness or
  • heating system

• Social housing providers will be required to meet EPC C using reformed EPCs against a second EPC metric by 1 April 2039 (from the list above) or for a valid exemption to be registered.

  The policy paper notes that social housing providers must always have an in-date EPC that shows they meet the standard required. There will also be some transitional provisions. Details of a £10,000 spend exemption will be set out in the full response.

Related topics for the PRS and SFR markets

Landlords of rented homes should also note the following:

• The Decent Homes Standard is scheduled to be applied to the private residential market from around 2035. There can be a tension between energy efficiency and ventilation so landlords should be considering how to future proof meeting these new energy efficiency related standards with what might become features of the Decent Homes Standards.
• Providing new tenants with a new EPC certificate is a pre-requisite to enable landlords to avail themselves of the right to use grounds for possession (ie to evict tenants) under ASTs. As part of the Renters’ Rights Act, this requirement (for the new Assured Periodic Tenancy regime) has been removed (when it comes into force from 1 May 2026).

What about commercial buildings?

Although progress appears to be being made in relation to MEES for domestic property there is still no update on MEES for commercial property.