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Compliance & energy

EPC C: the upgrade order that actually pays back.

Higher energy standards for rented homes are on the way. Here is what is law today, what is still a proposal, and where to spend first if you want the best return per pound.

Apr 21, 2026 9 min read Proposed
Energy efficiency upgrades to a home
Key takeaways

The short version

  • Today, a property generally needs at least EPC E to be let, with limited exemptions.
  • A higher minimum of EPC C has been proposed for rented homes, but the final standard and dates are not yet settled.
  • Treat the timeline as "coming, not confirmed", and plan rather than rush.
  • Insulation and draught-proofing usually give the best return per pound.
  • Get a fresh EPC with recommendations before spending anything.

Energy efficiency is the compliance topic landlords ask about most nervously, partly because the headlines have run ahead of the law. So let us separate what is actually required today from what is proposed for the future, because the right response to each is different.

01 · NowWhat is law today

Under the Minimum Energy Efficiency Standards, a rented home in England and Wales generally needs an Energy Performance Certificate rating of at least E to be lawfully let, unless a valid exemption is registered. That is the current legal floor, and it has been in place for several years.

If your property is already EPC D or above, you meet today's requirement. If it is F or G, you should address that now, regardless of any future changes.

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Check your certificate first

Every EPC lists recommended improvements and their estimated impact. It is the cheapest piece of planning advice you will get, start there before committing to any work.

02 · ComingWhat is proposed

The government has proposed raising the minimum standard for rented homes to EPC C, phased in over the coming years, with new tenancies expected to be caught before existing ones. This direction of travel has been consulted on and signalled repeatedly.

Important: the precise standard, the exact dates, and the detail of any cost cap or exemptions are not yet finalised in law. Treat EPC C as a near-certain direction rather than a fixed deadline, and confirm the current position on gov.uk before making decisions based on a specific year. We will update this article as the rules are confirmed.

03 · StrategyThe upgrade order

If you are going to spend on efficiency, the order matters. The aim is to do the things that move the EPC rating most per pound first, and leave the expensive, low-impact measures until last (or never). As a general sequence:

  • Get an up-to-date EPC and read its recommendations.
  • Do the cheap, high-impact fabric measures: insulation and draught-proofing.
  • Upgrade lighting to low-energy throughout.
  • Improve heating controls before replacing the heating system itself.
  • Consider larger measures last, once the easy gains are banked.

04 · FabricFabric first

"Fabric first" is the principle that you insulate and seal the building before you spend on new heating or generation. A well-insulated home with a modest heating system usually outperforms a draughty one with an expensive boiler, for both the rating and the tenant's bills.

In a typical older terrace, that often means loft insulation, cavity wall insulation where the construction allows, and proper draught-proofing of doors and windows. These tend to be the lowest-cost, highest-return measures available, which is exactly why they come first.

"Heat the home, not the street. Almost every cost-effective EPC gain starts with stopping warmth escaping."

City Flats property team

05 · ApproachPlan, don't panic

The worst response to an unconfirmed deadline is an expensive, rushed retrofit. The best is a plan: know your current rating, know which recommended measures would lift it, and stage the work so you are ready well before any new standard bites, without overpaying because you left it to the last minute.

For the properties we manage, we keep an EPC and an improvement plan on file for each one, so when the rules are confirmed there is no scramble, just the next item on a list we already have.

Not sure where your property stands?

We will map your EPC plan.

We review your certificate, identify the highest-return upgrades, and stage them sensibly, so you are ready for whatever standard lands.

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