The aim is to set the approach for driving improvements across all tenures, however, it has been cited the private rented sector has the highest rate of fuel poverty.
The proposals include using new EPC metrics for the higher standard, setting out a preferred implementation timeline, and seeking views on the maximum amount landlords would have to spend before registering an exemption. The existing exemptions regime and whether the standards should apply to short-term lets also form part of the consultation.
View the Improving the Energy Performance of Privately Rented Homesmore consultation →
This consultation and the proposals to extend the Minimum Energy Efficiency Standards for the private rented sector in England and Wales have long been anticipated. However, Minister Miliband must realise it's not about fighting landlords and people on climate change; it’s about creating realistic and achievable energy efficiency targets that acknowledge the challenges our housing sector faces in adapting and making the necessary improvements affordably.
Landlords are part of the solution, but the UK Government must listen and support them as housing providers. Failure to do so alongside adequate and sustained grant funding, will only mean that property will not be available to rent, and tenants lose out when there is huge demand for rented property across the country.
Letting agents and online property platforms
Landlords are required to obtain an EPC before placing a property on the market. In addition, the landlord or letting agent must show the EPC to anyone renting a property. In the 2020 consultation, it was proposed to introduce a specific requirement on letting agents and online platforms not advertise or let properties that do not comply with the PRS Regulations.
However, the UK Government’s preferred position is to keep a requirement on lettings agents and online property platforms to only advertise and let properties compliant with the PRS Regulations under review. With the proposed development of the PRS database in England likely to improve the ability of letting agents and online property platforms to check for compliance, this requirement will be reconsidered in due course.
A specific question aimed at letting agents in the proposals is if the preferred position is to keep a potential requirement on letting agents and online property platforms under review whilst the PRS Database is being developed for properties in England.
Improving the Energy Performance of Privately Rented Homes in England and Wales consultation proposals include
- To set higher minimum energy efficiency standards using new metrics as proposed in the Reforms to the Energy Performance of Buildings Regime consultation, following an approach that prioritises fabric improvements.
- Should landlords be required to spend up to a maximum of £15,000 per property on improvements to meet the standard, after which they could register a 10-year exemption to continue to let the property if it does not reach the standard?
- Should the higher standard apply to new tenancies from 2028 and that all tenancies be required to be compliant by 2030, or to have registered a suitable exemption?
- Privately rented homes that achieve a score of band C against existing EPCs, before new EPCs are introduced, would be considered compliant with the higher standard until those EPCs expire.
- Whether to introduce an affordability exemption that lowers the cost cap to £10,000 for some properties and how this could be implemented.
- Whether to increase the scope of the PRS Regulations to include short-term lets to ensure a consistent standard between privately rented homes and short-term lets.
- What regulatory measures could be used to drive the installation of smart meters in privately rented homes?
- Whether there are other instances in which exemptions should apply under the existing exemptions regine.
More affordable energy-efficient measures
The Fuel Poverty Strategy seeks views on retaining the existing statutory fuel poverty target and priorities for an updated policy plan to alleviate fuel poverty over the next five years. It also wants to know how fuel poverty is measured, including whether to introduce broader energy affordability measures. The consultation is also looking at the future of the fuel poverty target, including what an alternative or successor target could look like, and importantly, about strategic enablers to support the delivery of the strategy, including how schemes consider sustainability, cost-effectiveness and vulnerability to cold homes.
Read the Review of the Fuel Poverty Strategy consultation →
Propertymark’s warnings
Our continued evidence has shown that there are many properties in the UK for which attaining an EPC C is not achievable given current technology — Grade II listed buildings or homes with solid walls are a common example. Furthermore, the cost of improving homes as a proportion of the property value can sometimes be staggering, as discussed in our recent Lagging Behind report.
Data from the Buildings Research Establishment (BRE) showed that, in 2020, 21% of housing stock in the UK was built pre-1919, with the highest proportion of housing over 100 years old in Wales (at 26%).3 In our latest survey, we asked letting agents whether they had any landlords who would struggle to improve their properties to meet the EPC C target. 93 per cent reported that they did.
Without providing landlords and homeowners with incentives and access to sustained funding, it is unlikely that energy efficiency targets for the private rented sector and a reduction in emissions across the property sector will be met within the timeframe proposed.
Further evidence to support realistic proposals
Propertymark has been directly approached as a stakeholder by Dr Miatta Fahbulleh MP, Minister for Energy Consumers to contribute to the proposals. We want to see more energy-efficient homes, but new rules and requirements must be realistic and achievable.
We will respond after surveying members who understand the tenures they manage, the mix of types of landlords and the number of properties they have to ascertain and provide a measured view if any of the proposals are achievable.
Since Ed Miliband came into office in July 2024, we have been in contact with officials to discuss the UK Government’s manifesto promises and we will continue to engage, provide evidence, and help to shape realistic and reachable legislation.
