EPC changes

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Posted on 01 October 2025

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Labour’s EPC Rating Proposal: Energy Efficiency, Empty Properties, and Industry Collaboration

Labour’s commitment to ensuring that both private and social rental properties meet a minimum Energy Performance Certificate (EPC) rating of ‘C’ by 2030 is a positive and long-awaited step towards improving energy efficiency in the housing sector.

The government has further promised that a consultation will take place on the details of these regulations by the end of the year, offering hope that they will provide further clarity on how the new regulations will be implemented. However, for these regulations to be truly effective, and to avoid unintended consequences, involving the real estate sector in their design and execution will be an essential step. A collaborative approach should minimise disruption, ensure that landlords are equipped to comply with the new requirements, and alleviate any concerns about an exodus of landlords from the rental market.

For years, the real estate industry has been grappling with uncertainty with regard to energy efficiency standards. Previous administrations  explored the possibility of introducing a minimum EPC ‘C’ target for new tenancies by 2025, and expanding this to all tenancies by 2028. However, these plans were shelved when the consultation process stalled, and the subsequent government chose not to pursue the matter. Now, despite the new government’s declared commitment to achieving a minimum EPC ‘C’ rating for properties by 2030, the essential details are still missing. The promised consultation process will be a step in the right direction, but the timeline provided suggests that more specific details may not materialise until much later, meaning that the industry is still facing considerable uncertainty.

This lack of transparency has been particularly challenging for the housing sector, as there is a significant backlog of properties that will require major upgrades in order to meet the new standard. It has been argued that the proposed phased implementation should provide sufficient space for landlords to plan and finance the necessary improvements to their properties. However, the scope of the regulations and whether these will be sufficient to meet broader climate goals remains unclear. There are concerns that additional targets may be set in the future, and that the private rental sector may be subject to more stringent requirements further down the line.

The British Property Federation (BPF) has long supported higher energy efficiency standards in homes, as a means of reducing occupiers' bills and to help combat climate change. At the recent Labour Party Conference, Ed Miliband, Secretary of State for Energy Security and Net Zero, pointed out that setting a minimum EPC rating of ‘C’ for rental properties could lift a million households out of fuel poverty. While this is a laudable goal, it’s important to recognise that improved energy efficiency alone will not necessarily guarantee lower energy bills. Addressing the disparity between gas and electricity prices will also be necessary to ensure that increased energy efficiency translates to lower household costs.

The Committee on Climate Change has recommended removing policy costs from electricity prices to help accelerate the electrification of the grid and make low-carbon heating alternatives like heat pumps more affordable. If this doesn't happen, again, there is a real risk that improvements in energy efficiency could result in increased costs for occupiers, rather than savings.

Alongside the proposed policy shifts, the Department for Energy Security and Net Zero has committed to consulting on proposals to improve the EPC rating system itself. Whilst this has been greeted with general approval,  any changes to the EPC rating methodology would have to be finalised well ahead of the new regulations coming into force. Otherwise, landlords might find that they have invested money in improvements to their properties, only to discover that the EPC rating amendments will now require additional work. There is therefore a real risk that landlords will delay upgrading their properties; preferring to 'wait and see' if there are any further changes prior to committing any more funds. This would seriously undermine the effectiveness of the regulations.

The Challenge of Empty Properties

The role of empty properties is often overlooked in the housing market. With the new energy efficiency regulations set to impact the rental sector, addressing the issue of empty homes is becoming increasingly urgent. Research has consistently shown that empty properties are a significant problem in the UK, with hundreds of thousands of homes lying vacant for extended periods. According to the Ministry of Housing, Communities, and Local Government (MHCLG), over 200,000 homes have been empty for six months or more across England, Scotland, and Wales. These vacant properties constitute an underutilised resource, and introducing the added pressure of new energy efficiency regulations could either incentivise would be developers or discourage them from tackling them in the first place.

Landlords can also be hesitant when it comes to investing in and upgrading empty properties, particularly if they’re unsure of the financial return. Empty homes are often difficult to rent out, and the additional financial burden of making them compliant with the new EPC ‘C’ requirement, could further discourage landlords from bringing them back onto the market. Without appropriate incentives, landlords may choose to leave these properties untouched, worsening the existing housing crisis, and placing an even greater strain on supply in the rental market.

If the government is to address this issue, landlords will require incentives for bringing their empty homes up to the required standard, rather than allowing them to fall into disuse. This could take the form of grants, tax incentives, or low-interest loans, to assist with the cost of undertaking energy efficiency improvements. Local authorities could also play a role by prioritising the retrofitting of empty properties through targeted programmes. If the government is serious about tackling the UK's housing shortage, addressing empty properties will play a crucial part.

The Intersection of Energy Efficiency and Accessibility

As we focus on upgrading homes to become more energy efficient, it’s important not to overlook the growing need for inclusive, accessible design. This is especially true in the context of neurodiversity. The British Standard Institution (BSI) has published its own guidelines 'Design for the Mind. Neurodiversity & the Built Environment - PAS 6463' on designing spaces that will meet the needs of neurodiverse individuals, including people with autism or sensory processing disorders. While energy efficient homes will benefit all tenants, incorporating neurodiversity-focused design elements will make homes more inclusive, ensuring that they are comfortable for a wider range of individuals.

Lighting, for example, can have a significant impact on the comfort of a neurodiverse person. In one case a hospital was obliged to replace energy-efficient bulbs due to their negative effect on autistic patients. Considerations of this kind should all be integrated into the retrofitting of homes to meet new energy standards, to guarantee that all tenants will benefit both from energy efficiency and accessibility.

Adoption of these guidelines could extend beyond the private rented sector, influencing public spaces, such as airports, schools, and hospitals, and creating a more inclusive environment for all. If these principles are adopted more widely, particularly in the housing sector, they could help to break down barriers for neurodiverse people, enhancing the quality of their lives and improving societal outcomes.

Looking Ahead: Industry Collaboration and Policy Action

As the government continues to move forward with its commitment to higher energy efficiency standards, the role of the real estate sector in helping to shape and implement these regulations cannot be overstated. With empty properties already posing a challenge for the housing market,  clear and actionable policies will be essential, to encourage landlords to bring their properties up to the required standards and to ensure that the pressure to do so doesn't place an unnecessary burden on them. 

In addition to the technical aspects of energy efficiency, policymakers will have to consider the broader impact of the new regulations on housing supply. They will need to work alongside industry stakeholders, to ensure that energy efficiency improvements are made without driving landlords out of the market or leaving properties vacant for long periods.

To conclude, while the Labour government’s commitment to raising the EPC ratings on rental properties can be seen as a positive step forward, the policy will require careful, well considered implementation, taking into account the challenges of upgrading empty properties and the increasing requirement for accessible, inclusive design. If these concerns can be fully addressed we can look forward to a future where all homes are energy-efficient, affordable, and accessible, benefiting both residents and the communities around them.

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