The energy efficiency rule that's law, and the one that still isn't
Two distinct sets of rules govern the energy efficiency of privately rented homes in England and Wales. One has been in force since April 2020 and carries enforceable penalties. The other was set out by government in January 2026 with a firm target date, but has not yet passed through Parliament as legislation. Knowing which is which, and what each requires, is the foundation of any sensible compliance planning.
The rule that is already law: Band E
The Minimum Energy Efficiency Standards Regulations, commonly referred to as MEES, set the legal minimum for domestic private rented properties in England and Wales. Since 1 April 2020, landlords generally cannot let, or continue to let, properties rated F or G unless a valid exemption is registered. This requirement applies regardless of whether the tenancy is new or existing.
A property that has been marketed for sale or let, or modified, in the past ten years will in most cases already be legally required to have an EPC. Where a property falls below Band E, the landlord must either improve it to Band E or register a valid exemption before letting begins. The cost cap for reaching Band E under the current regulations is £3,500 including VAT, and the maximum penalty for non-compliance is £5,000 per property.
The rule that is not yet law: Band C by 2030
In January 2026, the government published its response to its consultation on private rented sector energy standards, as part of the Warm Homes Plan. This confirmed that all landlords, whether signing new tenancy agreements or with sitting tenants, will have until 1 October 2030 to bring their properties to EPC Band C or above, or register an exemption, to legally let them. This replaced an earlier phased proposal that would have required new tenancies to comply from 2028; that earlier 2028 deadline has been dropped in favour of the single 2030 date, and the proposed spending cap has been reduced from £15,000 to £10,000 per property, with a lower cap for homes valued under £100,000.
Several further details have been confirmed alongside the headline date. Spend on relevant energy efficiency improvements will count towards the £10,000 cost cap from 1 October 2025. EPC validity is being extended from five years to ten, so a property that achieves a Band C rating now would be recognised as compliant for the following decade. Landlords who obtain an EPC of C or higher under the current rating methodology before 1 October 2029 can rely on that certificate to demonstrate compliance until it expires, under what government guidance calls a grandparenting clause.
Despite this level of detail, the requirement is not yet enforceable law. The government's own landlord guidance, last updated 5 May 2026, still describes the position as exploring policy design options following the 2026 consultation, with further information to be provided in due course. No secondary legislation amending the MEES Regulations has yet been laid before Parliament, and until it is, there is no penalty regime in force for failing to reach Band C.
The metrics are changing too
Alongside the Band C target, the way EPCs themselves are calculated is being reformed. The current single-score EPC system is due to be replaced by the Home Energy Model, which will assess properties across multiple metrics including fabric performance, heating systems, and smart readiness, rather than one headline rating. The exact thresholds that will define a "Band C" result under this new approach have not yet been confirmed.
The timing of this change has itself shifted. The government originally said changes to the EPC calculation methodology would likely be introduced in the second half of 2026; this has since been postponed by a year, with the revised framework now expected in the second half of 2027. This delay does not affect the 2030 compliance deadline itself — landlords are still expected to comply with the new MEES requirement by October 2030.
What this means for planning
The Band E requirement is in force and non-negotiable. Any property currently rated F or G that is being let without a valid registered exemption is in breach of existing law. That is where immediate action is required.
For properties already at Band E, D, or above, the confirmed policy detail gives landlords a genuine basis for planning even before secondary legislation is laid. Getting a property to Band C under the current methodology before 1 October 2029 locks in compliance under the grandparenting clause for up to ten years, regardless of how the new Home Energy Model later scores that property. Landlords weighing whether to act now or wait should also note that spend from 1 October 2025 already counts toward the future £10,000 cap. The Band C deadline itself, however, remains government policy rather than a legal obligation until the relevant regulations are laid before Parliament.
Talk to our lettings team about your compliance plan