Government Publishes Response to the Consultation on Raising Energy Efficiency Standards in the Private Rented Sector

The Government has now issued its formal response to the consultation Improving the energy performance of privately rented homes (‘the Consultation’), which ran from 7 February to 2 May 2025. The Consultation sought views on proposals to amend the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015  (‘PRS Regulations’) to implement higher minimum energy efficiency standards (‘MEES’) in the domestic private rented sector (‘PRS’) in England and Wales with a long‑term aim of ensuring the sector reaches the equivalent of EPC Band C by 2030. 

The full Government response is available here: Improving the energy performance of privately rented homes - Government response 

The response confirms the direction of travel for PRS energy performance, setting out the trajectory towards significantly higher standards and the Government has reaffirmed its intention that “Private landlords of all tenancies will be required to comply with the higher standard by 1 October 2030.”

Current position

Currently, since 2020, privately rented homes in England and Wales have been required to meet a minimum standard of EPC E, unless a valid exemption applies. Landlords are required to invest up to £3,500 per property to meet this standard. 

Responses to the Consultation

Some key themes from the 1,920 responses to the Consultation included:

• Increased regulatory burden
• Increased costs passed through to tenants by way of rent increases
• Complexity of compliance
• Enforcement issues
• Difficulties in upgrading older properties
• Query over short terms lets (this remains under review)
• Questions over consumer protection and the standard of work completed 

Government’s response

The Government confirms it will pursue amendments to the PRS Regulations to introduce higher MEES using new metrics to be introduced to EPCs as set out in the Reforms to the Energy Performance of Buildings regime consultation.

Under this approach, private rented homes will need to meet two standards:

• a primary standard based on the building’s fabric; and
• a secondary standard based on either the heating system metric or the smart readiness metric.

Landlords will be free to choose which secondary metric to apply, giving flexibility to retain existing heating systems or adopt alternative technologies such as solar or smart controls. The Government’s view is that this dual‑metric approach preserves tenant bill savings and carbon reductions at a level comparable to the existing EPC C proposal, while avoiding the situation where landlords are penalised for installing low‑carbon heating such as heat pumps.

Landlords will be required to invest up to £10,000 per property on relevant energy efficiency improvements to bring the property up to standard. Where improvements costing up to this limit still do not bring the home to the required standard, the landlord may register an exemption lasting ten years and continue to let the property during that time. When an exemption expires, the landlord must again carry out energy‑efficiency works to attempt to meet the standard. The £10,000 limit is the maximum investment expected from a landlord over a ten‑year period. The cost of commissioning EPCs will count towards the £10,000 cap.

The Government’s impact assessment suggests that the average spend per property will be approximately £5,400, meaning many properties will not require the full cost‑cap expenditure.

Timelines and Transitional Arrangements (subject to parliamentary approval)

Legislative changes will require parliamentary approval. The Government intends to secure new primary powers and then bring forward a statutory instrument to update the PRS Regulations:

• From October 2026 - The Government will aim to deliver new EPCs. (They have recognised the timeline is ambitious and will work with industry to build a shared implementation plan and test assumptions). There will be further consultations.
• 2027 - Legislation to raise minimum energy efficiency standards for privately rented homes comes into force.
• 2029 - Government publishes updated guidance on the higher standard.
• 2030 - By 1 October 2030, all tenancies must meet the higher standard set against new metrics unless the landlord has made use of a valid exemption. Local authorities will begin enforcing the PRS Regulations and appropriate guidance will be provided to help all parties understand the requirements.

Landlords in the PRS will be required to continue to comply with the existing minimum standard of EPC E up until the time they are required to comply with the higher standard (1 October 2030).  

The Government also intends to recognise early action. Homes that achieve EPC C or above (measured using the legacy EPC Energy Efficiency Rating) before 1 October 2029 will be treated as compliant until the current EPC expires. Properties that do not reach C by that date will be required to commission a new EPC prior to completing improvements works, to comply with the standard set against new EPC metrics. Landlords will also be required to commission an EPC after they have concluded installing the relevant measures to meet the standard to demonstrate compliance.

The cost of commissioning these EPCs will count towards the £10,000 cap.

Exemptions Framework 

The PRS Regulations will continue to allow exemptions where certain measures are not viable, but the Government plans to expand and clarify the list. The future exemptions are expected to include:

• high‑cost exemption
• all‑relevant‑improvements‑made exemption
• cost‑cap exemption
• property value adjustment exemption
• solid wall insulation exemption
• negative impacts exemption
• third‑party consent exemption
• new‑landlord exemption

(Full detail of these exemptions can be found within the response)

Most exemptions will remain valid for five years, but some, including the cost‑cap and property value adjustment exemptions, will last for ten. The Government is also exploring a portfolio‑wide cost‑cap option for larger landlords.

Enforcement and the PRS Database

Local authorities will remain responsible for enforcing the PRS Regulations. Under powers linked to the Renters’ Rights Act, the Government will establish a national PRS Database, requiring landlords to register the properties they let. Local authorities will use the Energy Performance of Buildings Register and the PRS MEES Exemptions Register to check whether properties are compliant with the PRS Regulations. Fines of up to £30,000 per property per breach will be available for non-compliance with the PRS Regulations. 

What about the social housing sector?

As a reminder, a separate consultation was carried out for the social housing sector between 2 July and 12 September 2025. The Government has published only a summary of responses at this stage, emphasising that the document is intended as an executive summary and is not intended to replace the full Government response (which will be published shortly). The summary can be found here: Improving the energy efficiency of socially rented homes in England - Summary of consultation responses 

For more information, please contact Baljit Basra or Nina Dhadwal.