In January 2026, the government published its response to the private rented sector energy efficiency consultation and confirmed a single compliance deadline: all privately rented properties in England and Wales must achieve a minimum EPC rating equivalent to band C by 1 October 2030. The earlier proposal to require properties on new tenancies to meet the standard by 2028 was dropped. There is now one date for every landlord to plan around.
For Nottingham landlords, where a significant proportion of the housing stock pre-dates cavity wall construction and where HMO licensing has driven intensive use of older terraced properties, this deadline carries real weight. Here is what the confirmed details mean in practice.
What Has Been Confirmed
The government’s January 2026 Warm Homes Plan set out the following key points for private landlords:
The compliance deadline is 1 October 2030 and applies to all tenancies, including existing ones. There is no phased approach by tenancy type. The minimum standard is the equivalent of EPC C, though as explained below, how that standard is measured is changing.
The spending cap has been set at £10,000 per property, reduced from the previously proposed £15,000. This is the maximum a landlord is required to spend to achieve compliance. Where a property is valued below £100,000, the cap is instead 10% of the property’s value. Qualifying expenditure incurred from 1 October 2025 counts towards the cap, which means landlords who have already begun energy efficiency work in the past year can factor those costs in.
The maximum penalty for non-compliance is £30,000 per property, per breach — considerably higher than the previous maximum of £5,000. Where the standard cannot be met within the cost cap, an exemption can be registered on the PRS Exemptions Register. Exemptions last for 10 years.
The government estimates average improvement costs at approximately £5,400 per property. For straightforward cases, compliance need not approach the cap. But for solid-wall properties, pre-1919 housing stock, and certain non-standard constructions, the costs are likely to be at the higher end.
A Changing Assessment Framework
Here is where it becomes more complex: the EPC system itself is being overhauled. The current system uses an Energy Efficiency Rating as its headline metric. The replacement framework, known as the Home Energy Model (HEM), will introduce new assessment metrics from October
2026. Under HEM, the compliance assessment will be based on two elements: a primary Fabric Performance metric (the quality of the building’s insulation and envelope) alongside a secondary metric relating to either heating system efficiency or smart readiness.
The band boundaries under these new metrics are still being finalised. New-style EPC assessments will launch from October 2026, running alongside the existing system. The current EPC format will be discontinued from October 2029.
This creates a specific practical implication for landlords. Properties that currently hold a valid EPC C under the existing rating system before 1 October 2029 will be treated as compliant until that EPC expires (EPCs are valid for 10 years). This is the “grandparenting” provision. For landlords whose properties are borderline under the current system, securing a compliant EPC before October 2029 under the existing metrics is the safer strategy, because the new metrics may assess those same properties differently.
If a property has not achieved EPC C by 1 October 2029 under the old system, it will need to be assessed under the new HEM framework and meet the new metrics by 1 October 2030.
Why Nottingham Landlords Should Act Early
The scale of the task nationally is significant. An estimated 2.5 to 2.9 million rental properties in England and Wales currently fall below EPC C. Research from Hamptons suggests that at the current rate of improvement, all rental properties would not meet the standard until 2042. To hit the 2030 target, approximately 340,000 properties per year need to make improvements. That figure does not yet account for the change in assessment methodology.
What this means practically is that retrofit capacity — qualified assessors, approved contractors, and installation teams — will become increasingly constrained as the deadline approaches. Landlords who move early will have better access to competitively priced trades. Those who wait until 2029 or 2030 will face a market where demand far exceeds supply, with costs likely to reflect that.
For Nottingham specifically, the older terraced housing stock that makes up a significant proportion of the city’s HMO and buy-to-let supply tends to be more energy-intensive than newer builds. Properties in postcodes like NG7 and NG3, which attract high yields partly because of lower purchase prices, are often the ones that require the most work to reach EPC C.
Early action has a further financial benefit: improvements made from 1 October 2025 count towards the £10,000 spending cap. A landlord who commissions loft insulation and cavity wall insulation this year is already building their compliance position and their cost-cap record.
The government has also indicated that low-interest loans will be made available to landlords to fund improvement works as part of the broader Warm Homes Plan. The details on these financial products are still to be confirmed, but the direction is clear.
Practical Steps For Landlords Now
The immediate priority is to audit your portfolio’s current EPC position. For any property at E or below, the requirement to take action is not prospective — the current MEES rules have required a minimum EPC E since 2018. For properties sitting at D or borderline C under the current system, the question is whether to commission improvements now under the existing metrics or wait for the new HEM framework.
The government’s “fabric first” approach — prioritising insulation, draught proofing, and glazing improvements before addressing heating systems — is a reasonable framework for most properties. Loft insulation, cavity wall insulation, and window upgrades tend to offer the most cost-effective rating improvements, and these fabric improvements will count under both the current and new assessment systems.
As a general principle, landlords who commission a new EPC under the current system before October 2029 and achieve band C will be protected until that certificate expires. This gives a window of action that should not be left until the last moment.
At Slater and Brandley, we work with Nottingham landlords to ensure properties remain legally compliant and well-managed ahead of regulatory deadlines. If you have questions about how the 2030 EPC requirement affects your property or portfolio, our team is happy to discuss it. Get in touch today.
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