A recent government consultation proposes that landlords may soon be required to update their Energy Performance Certificates (EPCs) every time a tenancy is renewed, even if the tenant remains the same.

Current EPC Rules vs. Proposed Changes

Under the existing system, EPCs remain valid for ten years. A new EPC is only required when:

• A new tenancy begins with different tenants, or
• The property is being sold.

However, the consultation suggests introducing a new trigger point, requiring landlords to update an EPC as soon as it expires—regardless of whether the tenant stays or leaves.

More Frequent EPC Updates

The government argues that this change would bring EPCs in line with other landlord obligations, such as gas safety certificates, which must be renewed annually.

The consultation states:

“We are proposing to introduce for private rental properties a new trigger point where an EPC is required for when the current one expires.”

By maintaining a valid EPC throughout the tenancy, the government claims this would:
✅ Provide tenants with more accurate and up-to-date information about a property’s energy efficiency.
✅ Encourage landlords to make ongoing improvements to meet Minimum Energy Efficiency Standards (MEES).
✅ Support compliance with government policies aimed at improving energy performance in rental properties.

The consultation also suggests closer cooperation between MEES enforcement bodies and EPC enforcement agencies to improve compliance rates.

Why the Government Wants EPCs to Be Valid Throughout a Tenancy

The average private sector tenancy lasts 4.3 years, meaning many tenants may live in homes with expired EPCs. Even for shorter tenancies, an EPC could expire while a tenant is still in residence.

The government believes that requiring an up-to-date EPC at all times will help:

• Keep landlords accountable for improving energy efficiency.
• Ensure tenants have better information about their homes.
• Align EPCs with wider energy efficiency goals, such as the push for all rental properties to achieve at least EPC rating C by 2028 (for new tenancies) or 2030 (for existing tenancies).

Another justification is that more frequent EPC renewals would reflect property upgrades—such as insulation, new windows, or heating improvements—sooner than under the current 10-year system.

What This Means for Landlords: More Costs

The government admits that reducing the EPC validity period will increase costs for landlords, but claims the impact will be minimal.

However, landlords are already facing significant costs to upgrade properties to meet EPC C targets. If the validity period is shortened, landlords could be forced to upgrade more frequently just to stay compliant.

How Could the Government Introduce the Change?

If the policy is adopted, there are several possible implementation methods:

1. Allow existing EPCs to remain valid until expiry, with the new rule applying only to fresh renewals.
2. Immediately invalidate all 10-year EPCs, forcing landlords to renew at once.
3. Introduce a two-year transition period before full enforcement.

What’s Next?

The consultation is ongoing, and further changes may be introduced.