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The Ministry of Housing, Communities and Local Government and the Department for Energy Security and Net Zero have opened a consultation to discuss reforms to the energy performance of buildings.  

The Government in its consultation has made it clear that it considers understanding and managing the energy performance of buildings to be key to reaching its goals of net zero emissions by 2050, alleviating fuel poverty and enhancing building standards across the country.  

The Energy Performance of Buildings Regime was introduced from 2007.  The government wishes to reform the energy performance building framework to:

  • provide accurate information about the energy performance of homes, to allow homeowners and tenants, including potential homeowners, to make informed investments and decisions;
  • provide accurate information to determine whether or not any homeowners/tenants are eligible for schemes and to measure any progress against Government targets;
  • provide information to support a range of actions, including reducing carbon emissions, tackling fuel poverty, improving decency and the warm homes plan; and
  • enhance the use of Energy Performance Certificates (EPCs) to other bodies such as suppliers of energy efficiency products and services, lenders, not just limited to homeowners and tenants.

What are the main changes being proposed by the Government?

Multiple metrics on EPCs

The Government wants to understand the potential range of metrics that could be used in EPCs to provide a more complete representation of building energy performance including energy cost, carbon, energy use, fabric performance, heating system and smart readiness.

Reducing the validity period of EPCs

One of the main aims of the consultation is to consider reducing the validity period on EPCs. EPCs are currently valid for ten years. The Government believes that reducing the validity period of EPCs could allow building upgrades to be captured more frequently.  

Ensuring a valid EPC is present throughout a tenancy period

The Government also proposes that a valid EPC is present throughout the tenancy period.  In both the private and social rented sectors, currently when an EPC expires, a new EPC is only required when a property is re let and not when the same tenant renews or extends their lease. The Government has highlighted that whilst the average private rented sector tenancy is below the validity period of ten years for an EPC, the average social housing tenancy lasts longer than the validity period.  This new proposed change would ensure that a valid EPC is present for all tenants throughout their tenancy. 

Marketing properties with an EPC

The Government also proposes that current regulations are amended to ensure a property is not marketed for sale or let without a valid EPC. The Government believes that this will allow any prospective homeowners or tenants to have up to date information when they are making any decisions or enquiries.  

Requirement to have an EPC for HMOs

In respect of houses in multiple occupations (HMO), the Government has proposed that a valid EPC is required for an entire HMO when a single room is let. Currently, the guidance is that an EPC is only required when an entire property is rented out.  The Government now proposes that an EPC will have to be in place at the point of marketing for the first letting of an individual room, up to and including the date that the final letting comes to an end. 

EPCs for short-term lets

In respect of short-term rental properties, for example holiday lets, there are no specific requirements set out in the energy performance building regulations. Currently, an EPC is only required for properties rented out as a furnished holiday let for four months or more in any 12 month period and if occupiers are responsible for meeting the energy costs for the property.  

The Government is proposing ensuring a specific requirement for short term rental properties to have a valid EPC at the point of being let, irrespective of whether the occupier is responsible for meeting the energy costs.  

EPCs for heritage buildings

In respect of heritage buildings, an EPC is not required if compliance with minimum energy performance requirements would alter the character or appearance of the building. The Government is proposing that all heritage buildings should have an EPC.  The Government advises that it will ensure any EPC recommendations for heritage buildings would be tailored to the nature of the building. 

Changes to Display Energy Certificates for public buildings

Buildings frequently visited by the public which have a floor area of over 250m2 are required to have a Display Energy Certificate (DEC) and a DEC recommendation report.  

The Government is proposing to reduce the validity period of DECs and DEC recommendation reports. Currently, the validity period of DECs and DEC reports for buildings between 250m2 to 1,000m2 is ten years, and the Government proposes to change this to seven years. In respect of buildings over 1,000 m2, the current validity period is one year for the DEC and seven years for the DEC report, which the government proposes to change to five years.

The consultation is open until 26 February 2025 and further information can be found here.