Since 2020, all let properties in England and Wales must achieve EPC band E or higher unless a valid exemption is registered. Government has consulted repeatedly on raising the threshold to band C, which would force major upgrades on roughly 60% of the rented stock. This guide explains the current rules, the proposed changes and what landlords should do now.
The Minimum Energy Efficiency Standards (MEES) Regulations make it unlawful to let a property in England or Wales with an EPC rating below E. The rule applies to all new tenancies since April 2018 and to all existing tenancies since April 2020.
Penalties for non-compliance range from £2,000 to £5,000 per breach, enforced by local authorities. The breach is the act of letting a sub-standard property — not the EPC rating itself — so an unlet F-rated property is fine.
Government has consulted on requiring band C from 2028 for new tenancies and 2030 for all tenancies. The 2024 government deferred the timeline; the 2025 government has reaffirmed band C as the medium-term direction with timetable to be confirmed.
Industry estimates suggest 55-60% of rented homes are currently below band C. Average upgrade cost to reach C is £8,000-£12,000 per property — much higher for older or solid-wall stock.
Five main exemption categories: cost cap reached (£3,500 spent without reaching E), all relevant improvements made but rating not achieved, third-party consent refused (e.g. tenant or planning), wall insulation devalues property by 5%+ (per RICS surveyor), and 6-month new landlord exemption.
Exemptions must be registered on the PRS Exemptions Register and last 5 years before re-application. Unregistered exemptions are no defence to enforcement.
Quickest wins: LED lighting throughout (1-2 points), loft insulation to 270mm (3-5 points), hot water cylinder jacket and pipework lagging (1-3 points). Often enough to get from F to E for under £500.
Bigger lifts to reach C usually require cavity wall insulation (5-10 points), high-efficiency boiler or heat pump (5-15 points), and double or triple glazing (3-5 points). Solar PV adds 5-10 points and can be financed by Smart Export Guarantee income.
Audit all EPCs in the portfolio. Anything F or G must be either upgraded or have an exemption registered before re-letting. Anything D should be planned for upgrade ahead of the band C timeline.
Get a fresh EPC before relying on an old one — assessment methodology has changed several times since 2012 and old EPCs often understate (or overstate) current rating. Many properties improve a band simply by re-assessment with current methodology.
Yes — and to social housing, mixed-use and most short-term lets above 4 months. It doesn't apply to listed buildings if upgrades would unacceptably alter character.
Scotland has its own framework and has consulted on requiring band C from 2028. Northern Ireland has no equivalent regime in 2026.
No — MEES upgrade costs are landlord costs. Some grant schemes (ECO4, GBIS) help with insulation costs in qualifying properties.
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