TL;DR
The EPC C requirement landlords must meet falls on a single date: 1 October 2030. The previously planned 2028 split for new tenancies was scrapped in January 2026 under the Warm Homes Plan, replaced with one unified deadline and a £10,000 cost cap per property. Around 52% of England and Wales private rented sector stock currently sits below C, so most London landlords have measurable work to plan. Penalties for non-compliance reach £30,000 per property per breach, enforced by local Trading Standards. This guide covers the timeline, the cap, the new Home Energy Model, the eight exemption categories, and what to do in 2026.
The EPC C requirement landlords face: a single 2030 date
The headline is simple. From 1 October 2030, every privately rented property in England and Wales must hold a valid Energy Performance Certificate (EPC) rated C or above. There is no longer a split between new tenancies and existing tenancies — the staggered model was abandoned in January 2026. One deadline. One rating threshold. One cap on what landlords are required to spend.
The EPC C requirement landlords now plan around replaces a confused set of earlier proposals. The current Minimum Energy Efficiency Standards (MEES), in force since April 2018, set the floor at E. Around 52% of England and Wales private rented stock currently sits below C, which is why the Warm Homes Plan timeline matters: most properties will need at least one measurable upgrade before the deadline.
For London landlords specifically, the picture is harder than the national average. Older terraced stock, conservation area constraints, and tight floor plates make some upgrades disproportionately expensive — which is exactly why the £10,000 cost cap, and the rules on what counts toward it, matter.
What changed in January 2026
On 21 January 2026, the Department for Energy Security and Net Zero (DESNZ) published the Warm Homes Plan consultation response. It formalised three shifts that landlords need to read carefully.
First, the 2028 / 2030 split was scrapped. The earlier plan would have required EPC C for new tenancies from 2028, with existing tenancies catching up by 2030. That split is gone. Every property hits 1 October 2030 together.
Second, the cost cap was reduced. Earlier consultations had floated £15,000 per property. The final position is £10,000.
Third, the blanket heritage exemption was removed. Listed buildings and properties in conservation areas were previously assumed to be exempt. They are now in scope, though specific exemption categories still apply (see below).
Short-term lets — Airbnb-style holiday lets that don’t operate under a standard residential tenancy — remain outside the regime. Long-term assured periodic tenancies (the new default since the Renters’ Rights Act 2025 main commencement on 1 May 2026) are the target.
How the £10,000 cost cap works
The £10,000 figure is the maximum a landlord is required to spend on an individual property to reach EPC C. If you have spent £10,000 on qualifying measures and the property still hasn’t reached C, you can register a cost-cap exemption on the public PRS Exemptions Register.
Three details that catch landlords out:
Lower cap for cheaper properties. Properties with a market value below £100,000 face a cap of 10% of property value, not the flat £10,000. A £75,000 property in a low-value area caps at £7,500.
Expenditure from 1 October 2025 counts. Any qualifying upgrade installed from that date can be claimed against the cap. Receipts, invoices, and the post-upgrade EPC are all required evidence.
The cap is per property, not per portfolio. A landlord with five properties has £10,000 of headroom on each.
What counts as “qualifying” tracks the EPC’s improvement recommendations list — loft and cavity wall insulation, low-energy lighting, hot water cylinder insulation, draughtproofing, double glazing, and heat pump installation. Work outside the recommendations list doesn’t count toward the cap.
Industry estimates put the average upgrade cost between £6,100 and £8,000, with the government’s own modelled figure around £5,400. Most London properties land at or above the upper end of that range because labour and access costs run higher.
The Home Energy Model: what’s replacing SAP
Alongside the timeline change, the underlying assessment methodology is being replaced. The current Standard Assessment Procedure (SAP) was built in the 1990s and has been criticised for failing to reflect real-world energy use. The replacement is the Home Energy Model (HEM), scheduled to come into force in late 2029.
HEM moves to a dual-metric system. The primary metric is Fabric Performance — a measure of how well the building envelope retains heat, covering insulation, glazing, and airtightness. This is not optional. Every property is assessed on it.
The secondary metric is the landlord’s choice. Either a Heating System rating (how efficient the heat source is) or a Smart Readiness score (how well the property can integrate with smart controls and time-of-use tariffs). Landlords pick whichever makes more sense for the property and the tenant profile.
For planning purposes, the practical implication is this: properties assessed under SAP near the C/D boundary may shift either direction under HEM. Do not assume a current SAP “C” automatically remains a HEM “C” in 2030. An updated assessment is worth budgeting for in 2029.
The average residential EPC currently costs around £85. HEM assessments are expected to come in slightly higher because of the additional fabric measurements required, though final pricing wasn’t fixed at the time of writing.
Exemptions: who escapes the requirement
Eight exemption categories remain on the PRS Exemptions Register. Exemptions are not automatic. They must be registered, with supporting evidence, before the deadline bites — retrospective exemption is not available.
The eight categories:
- Cost cap exemption — £10,000 spent (or 10% for low-value properties) without reaching C.
- All relevant improvements made — every recommendation on the EPC has been installed and the property still doesn’t reach C.
- Consent exemption — tenant, lender, or freeholder consent for upgrades refused in writing.
- Wall insulation exemption — wall insulation specifically would damage the property fabric (expert evidence required).
- Devaluation exemption — independent surveyor confirms upgrades would reduce property value by more than 5%.
- New landlord temporary exemption — 6 months from becoming the landlord (e.g., inheritance, repossession).
- Listed building exemption — narrower than before; only where specific measures would unacceptably alter character.
- Short-term lease exemption — leases under 6 months or over 99 years sit outside MEES entirely.
Most exemptions are valid for 5 years, after which they must be reviewed and re-registered. The listed building exemption can run to 10 years in some cases. The Register is public, so landlords applying for an exemption should expect their entry to be visible to tenants and prospective tenants.
Penalties and enforcement
Trading Standards officers at each local authority enforce MEES. Under the Warm Homes Plan settlement, penalties for missing the EPC C requirement landlords now face reach up to £30,000 per property per breach.
The penalty bands depend on the duration and nature of the breach:
| Breach | Indicative penalty |
|---|---|
| Renting non-compliant property less than 3 months | Up to £5,000 |
| Renting non-compliant property 3 months or more | Up to £10,000 |
| Renting non-compliant property combined with false or misleading Register entry | Up to £15,000 |
| Repeat or aggravated breach | Up to £30,000 |
Local Trading Standards can also issue Publication Penalties — publishing the offending landlord’s details on a public register for up to 12 months. Reputational damage stacks with the financial penalty.
There is no central enforcement body. Each council enforces in its own area, which means London landlords with portfolios across multiple boroughs face different enforcement appetites. Some boroughs (Camden, Hackney, Southwark) have actively pursued MEES breaches under the existing E-rating regime; others remain reactive. Expect that contrast to sharpen after 1 October 2030.
What London landlords should do in 2026
Planning early matters because the EPC C requirement landlords face — unlike many regulatory changes — has no transition period. 1 October 2030 is a hard date. Four steps make sense regardless of portfolio size.
Pull the EPC for every property and check the rating. Free at gov.uk/find-energy-certificate. If the rating is D or below, the property is in scope. EPCs are valid for 10 years from issue, so a 2018 certificate is still current — but a property that scraped a D in 2018 will not automatically reach C.
Commission an improvement assessment. A surveyor can model which measures will move the property from D to C most efficiently. This is not the same as a new EPC — it is a planning exercise. Most independent surveyors charge £150-£300 for this work.
Phase the work to 2030. Spreading upgrades across four years lets you batch with re-tenancies or void periods, which keeps costs and disruption down. It also gives time to apply for available grants — the Boiler Upgrade Scheme and ECO4 currently subsidise heat pumps and insulation. Spending from 1 October 2025 already counts toward the cap, so receipts kept now are not wasted.
Keep evidence. Receipts, invoices, EPC certificates dated after 1 October 2025, and surveyor recommendations. If the property doesn’t reach C by 2030 despite £10,000 spent, the cost-cap exemption requires this paper trail.
Running alongside the EPC are parallel compliance obligations — gas safety renews annually, EICR costs in London sit between £170 and £240 and renew every 5 years, and EPCs themselves stay valid for 10 years from issue. Many landlords bundle the three renewals together for efficiency. Click Inventories provides an EPC, EICR, and Gas Safety Certificate bundle covering all three in a single visit, and the EICR validity rules interact with EPC renewals in ways worth planning around.
For wider context on parallel compliance obligations — gas safety, EICRs, deposit protection, Right to Rent, and the new RRA regime — see the London landlord compliance guide.
FAQ
What is the EPC C requirement landlords face from 2030?
From 1 October 2030, every privately rented property in England and Wales must hold a valid EPC rated C or above. The previous staggered approach (2028 for new tenancies, 2030 for existing) was scrapped in January 2026 under the Warm Homes Plan. All properties hit the same deadline.
Does the requirement apply in Scotland and Northern Ireland?
No. The 1 October 2030 EPC C deadline applies to England and Wales only. Scotland is running a parallel timetable under separate legislation. Northern Ireland has not yet adopted equivalent measures.
What if I’ve already spent the £10,000 cap and still can’t reach C?
You register a cost-cap exemption on the PRS Exemptions Register with full evidence — invoices, EPC certificates dated after 1 October 2025, surveyor reports. The exemption is valid for 5 years, after which it must be reviewed. Retrospective exemption is not available, so you must register before 1 October 2030.
What if my property is listed or in a conservation area?
The blanket heritage exemption was removed in January 2026. Listed buildings and conservation area properties are now in scope. Specific measures that would unacceptably alter the building’s character can still qualify for a listed building exemption, but this requires expert evidence and is narrower than the previous protection.
Will my SAP rating automatically become my HEM rating in 2030?
No. The Home Energy Model replaces SAP from late 2029 and uses a different methodology — Fabric Performance plus a landlord-chosen secondary metric. A property at the C/D boundary under SAP may move either direction under HEM. Budget for a fresh assessment in 2029.
What happens if I miss the deadline?
Local Trading Standards can issue civil penalties of up to £30,000 per property per breach. Continuing to let a non-compliant property compounds the penalty over time. Publication Penalties — naming the landlord on a public register for up to 12 months — can apply alongside the financial penalty.
Are short-term Airbnb lets affected?
No. Short-term lets that don’t operate under a standard residential tenancy fall outside MEES. The target is long-term private rented sector tenancies, now converted to assured periodic tenancies under the Renters’ Rights Act 2025.
Citations
- DESNZ — Warm Homes Plan consultation response, 21 January 2026
- Gov.uk — Domestic Private Rented Property MEES — landlord guidance
- Gov.uk — Find an Energy Performance Certificate
- Gov.uk / DESNZ — PRS Exemptions Register
- DESNZ — Home Energy Model methodology consultation
- Gov.uk — Boiler Upgrade Scheme
- AIIC — Association of Independent Inventory Clerks
By the Click Inventories Team
