The EPC reformation in England and Wales – changes on the horizon

The EPB framework was established under the Energy Performance of Buildings (England and Wales) Regulations 2012 and is one of the key legislative tools promoting carbon reduction in building stock and promoting energy efficiency improvements in commercial and domestic properties across England and Wales, forming part of the wider objective of reaching net-zero emissions by 2050.

The proposed reforms would impact energy performance certificates (“EPCs”), display energy certificates and air conditioning inspection reports.

Reform to EPCs is significant, as they form the basis for energy efficiency targets, regulatory requirements for minimum energy efficiency standards (“MEES”), and funding criteria. The proposals include:

• Multiple metrics– at present, whilst EPCs display various metrics about environmental performance, there is a “headline” metric (an Energy Efficiency Rating modelled on energy costs per sq m for domestic property; an Environmental Impact Rating modelled on carbon dioxide emissions per sq m for commercial property) expressed in the familiar A – G scale. The Government has acknowledged that these headline metrics are flawed (as they can be significantly influenced by factors outside the building owner’s control). Under the proposals, multiple metrics would be used to provide a wider range of better quality performance data to ultimately give a better representation of a building’s energy performance:
  • Fabric performance - assessing the thermal performance of the building’s envelope
  • Energy cost –the financial implications of the building’s energy efficiency and potential improvements
  • Heating system - information on the efficiency and environmental impact of the building’s heating source
  • Smart readiness - assessing the building’s potential to integrate smart technologies that can optimise energy consumption

• (The above would form four headline metrics for domestic property)

  • Carbon – the carbon emissions from the energy used in the building (this would remain the headline metric for commercial property, although this may change over time)
  • Energy use – showing overall energy consumption and identifying areas for energy efficiency improvements

These changes are anticipated to be introduced in the second half of 2026. At present, there is no suggestion that changes to EPC metrics would invalidate existing EPCs which could continue to be used to demonstrate compliance with regulatory requirements.

The Government has also left the door open for additional updates in the future, including metrics to show a building’s resilience to climate change impacts, occupant health and wellbeing, biodiversity, and water efficiency.

• Reducing EPC validity period - the current 10-year EPC validity period could be reduced (by over 8 years has even been suggested!) The Government’s preference is that all existing EPCs would remain valid for their existing validity period, and any reduced validity period would only apply to new EPCs.
• Requiring a valid EPC throughout a tenancy – the Government has recognised that, because EPCs only need to be produced in limited circumstances, there are often instances of EPCs not needing to be renewed when they expire (and which brings properties outside the scope of the MEES regime, for example). To address this, a new EPC would need to be commissioned for a let property when the existing EPC expires (which would mean more properties are subject to MEES).
• Listed buildings – the Government appears to acknowledge that EPB Regulation 5(1)(a) is, at best, confusing. Under the changes, all heritage buildings would be required to have an EPC. This would bring listed buildings within the scope of MEES (although exemptions may be available).
• Compliance and penalties - given the limited evidence on compliance with the energy efficiency regimes, there may be changes to the relevant enforcement agency’s access to data, and increased penalties (which have remained stagnant since their introduction in 2007).

The Government is expected to release its response to the consultation in mid-2025, so watch this space. Also look out for our next article which will consider changes to MEES for private rented homes.

Authored by Adam Balfour.