The requirement for properties to meet minimum Energy Performance Certificate (EPC) standards is not new. As we outlined in our earlier update Commercial Property Update – Non-Dom EPC Regulation changes coming 01-04-23 , landlords have been prohibited from letting “sub-standard” properties (those with an EPC rating below E) for some time, with enforcement for existing commercial property lettings commencing on 1 April 2023.
Since then, the government has continued to refine its approach to EPC regulation as part of its wider net-zero strategy. While the most immediate reforms focus on the domestic sector, they signal a clear direction for all property owners and investors.
Key EPC changes and timelines
EPCs are undergoing significant reform to make them more accurate and more useful as a measure of a building’s true energy performance. The emphasis is moving away from headline running costs and towards how efficiently a property is constructed, heated, and future proofed. The government has also confirmed a “fabric first” approach, prioritising improvements such as insulation, windows and building fabric before mechanical or technological solutions.
From 15 June 2025, a new assessment methodology, RdSAP 10, has been introduced for domestic EPCs. This provides a more detailed assessment, including the following points:
- Specific measurements of walls, roofs and floors.
- Assessment of insulation and glazing.
- Greater emphasis on low-carbon heating systems, including heat pumps.
It is expected that by late 2026, the government plans to replace the single cost-based rating with four metrics:
- Fabric performance.
- Heating system efficiency.
- Smart readiness.
- Energy cost.
All private rental properties in England and Wales will be required to achieve a minimum EPC rating of C by 1 October 2030. EPCs issued at a rating of C or above will remain valid for 10 years, providing longer-term compliance certainty once the standard is achieved.
Impact on landlords and property owners
The message for property owners is consistent across both domestic and non-domestic sectors: early assessment and forward planning are essential. Reviewing EPC ratings, understanding improvements and building compliance costs into asset and leasing strategies will reduce risk and protect long-term value.
For domestic rental property, the estimated cost of improving a property to an EPC C rating is expected to be between £6,100 and £6,800. Financial support may be available through schemes such as the Warm Homes: Local Grant, although eligibility and funding levels vary.
As highlighted in our February 2023 update, failure to comply with EPC regulations does not invalidate a lease, but it can expose landlords to significant financial penalties and reputational risk. These enforcement powers remain in place and are likely to expand as standards tighten.
Our property team is able to assist in the acquisition, disposal or leasing of commercial properties. For further information and advice please contact James Southward on 01284 717522 or by email.
For more information on the services offered by Greene & Greene Solicitors please visit www.greene-greene.com and follow on Twitter @GreeneGreeneLaw.
This is only intended to be a summary and not specific legal advice.
