Reforms to the Energy Performance of Buildings regime

## Partial response We have published a a partial response to the Reforms to the Energy Performance of Buildings regime consultation. It confirms plans to introduce four new headline metrics on new-style domestic EPCs, the retention of the existing headline metric on non-domestic EPCs, and updates on buildings where EPCs will be required following reform, subject to parliamentary approvals. A further response covering the remaining parts of the consultation will be published in 2026. Government is committed to reforming the Energy Performance of Buildings regime to provide a system which: * provides homeowners and tenants with accurate information about the energy performance of their homes to allow them to make informed investment and purchase decisions * provides accurate information to determine eligibility for schemes and measure progress against government targets * provides an information tool to support a range of actions including reducing carbon emissions, tackling fuel poverty, improving decency and the Warm Homes Plan * reflects the needs of wider users of EPCs beyond homeowners and tenants, such as suppliers of energy efficiency products and services, as well as lenders To achieve this, the consultation includes proposed reforms to enhance the regime in 5 critical areas: * updating what EPCs measure through additional metrics * updating when energy certificates are required by refining the rules for obtaining EPCs and DECs * managing energy certificate quality * improving the accessibility of building performance data * strengthening the quality of air conditioning inspection reports --- ## Scope of the consultation ### Topic of this consultation This consultation seeks views on the reform of the Energy Performance of Buildings (EPB) framework. It covers the following areas: * clarifying and consolidating regulations, and focusing on improving the applicability, quality, and data usage of energy certificates in domestic and non-domestic buildings * updating EPC metrics * refining requirements for Energy Performance Certificates (EPCs) and Display Energy Certificates (DECs) * improving data management protocols and strengthening quality control * revising air conditioning inspection reports (ACIRs) ### Geographical scope This consultation covers England and Wales. Responsibility for energy certificates in Scotland is devolved to the Scottish Parliament, and responsibility in Northern Ireland is transferred to the Northern Ireland Assembly. The UK government works closely with the other devolved administrations to oversee the operation of the energy performance of buildings legislation across the UK, given that there is shared common technical infrastructure (calculation methodology software and systems for registering certificates), and given that energy assessors (and their accreditation schemes) operate across the UK internal market. #### Northern Ireland The Energy Performance of Buildings (Certificates and Inspections) Regulations (Northern Ireland) 2008 applies in Northern Ireland and the systems there rely on and operate mutually with the regime in England and Wales. Therefore, it is likely that outcomes from this consultation will apply equally in Northern Ireland, subject to any relevant ministerial approvals and additional local policy development. #### Scotland The Scottish Government has similar objectives to those set out by the UK government in chapters 1 to 3 of this consultation, and has already consulted during 2021 and 2023 on its own proposals for reform of the EPC rating system and validity periods. It will respond shortly to its 2023 consultation to give its final decisions on these reforms in Scotland. The Scottish Government also has a common interest with the UK government on the issues raised in chapters 4 and 5 of this consultation – on how EPC data is lodged and reported on the EPC Register; and on how quality assurance of EPC assessors can be improved across the UK internal market. The UK and Scottish Governments will work jointly to consider our approach to policy making in this area across the UK, following the responses received to this part of the consultation. Assessors issuing ACIRs also operate across the UK internal market, and the Scottish Government will be working jointly with the UK government to consider its approach to policy making in this area, following the responses received to chapter 6 of this consultation. #### Wales Whilst the UK government holds the responsibility for EPC, DEC and ACIRs in both England and Wales, there are devolved matters in Wales, including the Building Regulations and standards for social housing, that use the EPC regime in support of their own objectives. The UK government will work with the Welsh Government where transitional arrangements arise from these proposals. ### Impact assessment A consultation stage impact assessment is published alongside this document. ## Basic information ### Bodies responsible for the consultation Ministry of Housing, Communities and Local Government and Department for Energy Security and Net Zero. ### Duration This consultation is scheduled to last for 12 weeks from 4 December 2024 to 26 February 2025. ### Enquiries For any enquiries about the consultation please contact: energyperformanceofbuildingsregulations@communities.gov.uk ### How to respond You may respond by completing an online survey on [Citizen Space](https://consult.communities.gov.uk/energy-performance-of-buildings/consultation-on-reforms-to-epb). We strongly encourage responses via the online survey. Using the online survey greatly assists our analysis of the responses, enabling more efficient and effective consideration of the issues raised. If it is not possible for you to use the online survey, you can respond through email. If you are responding in this way, please make it clear which questions you are responding to. Email responses should be sent to: energyperformanceofbuildingsregulations@communities.gov.uk Responses can be sent by post to: Energy Performance of Buildings Reforms consultation Building Systems and Insights Directorate Ministry of Housing, Communities and Local Government Fry Building 2 Marsham Street London SW1P 4DF ### About you This consultation seeks views from a diverse range of stakeholders. When responding to this consultation please specify: Question 1. Are you responding as/on behalf of (select all that apply): * Member of the public * Builder/Developer * An accredited energy assessor * Estate agent * Insurance company * Environmental organisation * Financial institutions * Energy efficiency service providers * Building Control Approved Inspector/Registered Building Control Approver * Competent Persons Scheme Operator * Designer/Engineer/Surveyor * Architect * Energy sector * Local authority * Housing Association * Manufacturer/Supply chain * National representative or trade body * Professional body or institution * Property Management * Research/Academic organisation * Other Question 2. If you are responding as a member of the public/a building professional, what region are you responding from? [drop down list of England regions and other] Question 3. If you are responding as a member of the public, are you a [checklist: private tenant, housing association/local authority housing tenant, private landlord, homeowner and other] Question 4. If you are responding on behalf of a business/organisation, what is the name of your business/organisation? [free text] Question 5. If you are responding on behalf of a business/organisation, where is your business/organisation based/registered? [drop down list of England regions and other] Question 6. When you respond it would be useful if you can confirm whether you are replying as an individual or submitting an official response on behalf of an organisation and include: * your name * your position (if applicable) * the name of organisation (if applicable) * an address (including post-code) * an email address * a contact telephone number Your personal data is being collected so that we can contact you regarding your response and for statistical purposes, an essential part of the consultation process. We may also use it to contact you about related matters. Please see the privacy notice in Annex A for further information on how we use this data. ## Foreword Our government is committed to a sustainable future for our built environment and recognises the need to reform the Energy Performance of Buildings (EPB) Regime to help achieve this. These reforms are integral to creating a regime that supports people in better understanding and managing the energy performance of their buildings whilst achieving key national goals, including reaching net-zero emissions by 2050, alleviating fuel poverty, and enhancing building standards across the country. Established under the Energy Performance of Buildings (England and Wales) Regulations 2012, the EPB Framework serves as a foundational tool for promoting carbon reduction across the UK’s building stock, encouraging energy efficiency improvements in existing homes and commercial properties alike. This joint consultation, led by the Ministry of Housing, Communities and Local Government (MHCLG) and supported by the Department for Energy Security and Net Zero (DESNZ), marks a pivotal step toward these goals. The consultation outlines proposed reforms to enhance the building energy performance regime in five critical areas: updating EPC metrics, refining requirements for Energy Performance Certificates (EPCs) and Display Energy Certificates (DECs), improving data management protocols, strengthening quality control, and revising Air Conditioning Inspection Reports (ACIRs). In addition, MHCLG will lead a comprehensive programme of research to better understand user needs and preferences in order to present EPCs in a way that aligns with climate objectives and consumer expectations. This research will help create a robust, well-rounded perspective on building performance that aligns with both our environmental targets and the interests of our citizens. Our departments have been closely collaborating to advance these essential government objectives, fully aligned with our Mission to accelerate action to Net Zero. Through this partnership, we are committed to achieving real, measurable improvements that will strengthen our efforts to create a sustainable future through reforms to the Energy Performance of Buildings Regime. The EPC reform consultation offers an exciting opportunity to engage meaningfully with our stakeholders, whose insights will help shape the path forward for the EPB Regime. We look forward to working with partners across various sectors to ensure these reforms deliver maximum impact. This joint effort represents our unwavering dedication to achieving a sustainable, low-carbon future, and we are confident these proposed reforms will bring lasting benefits for generations to come. Baroness Taylor of Stevenage Lords Minister for Housing and Local Government Miatta Fahnbulleh MP Minister for Energy Consumers ## 1. Overview of proposed reforms ### Context The Energy Performance of Buildings (EPB) regime was introduced in phases from 2007, with the goal of improving the energy efficiency of buildings, reducing their carbon emissions and lessening the impact of climate change. Relevant legislation is the Energy Performance of Buildings (England and Wales) Regulations 2012 (“EPB Regulations”). The regulations require that: * energy performance certificates (EPCs) are produced for certain domestic dwellings and non-domestic premises * display energy certificates (DECs) are produced for public buildings * air conditioning inspection reports (ACIRs) are carried out for systems above a certain size Certification and reporting provide numerous benefits, including: * enabling prospective buyers and tenants to compare a modelled assessment of energy costs and carbon emissions of different properties * providing information on the current performance of different building elements and services with recommendations for cost-effective improvements and signposting to other sources of advice * supporting policy makers with information on the energy performance of the existing building stock and how this changes over time The EPC has become a key measurement tool for assessing the performance of our buildings and is now widely used beyond its original scope. For example, EPC ratings are used as the basis for energy efficiency targets, for regulatory requirements such as minimum energy efficiency standards (MEES) for the private rented sector (PRS) and as an eligibility requirement for funding, such as in the Warm Homes: Social Housing Fund (WH:SHF). The EPC will remain an important tool for delivering the Warm Homes Plan, which aims to save families money and contribute to the UK meeting its climate targets, including by setting new PRS standards for homes by 2030. According to the government’s [most recent statistics](https://assets.publishing.service.gov.uk/media/65c0d15863a23d0013c821e9/2022-final-greenhouse-gas-emissions-statistical-release.pdf), buildings account for around 20% of the UK’s total greenhouse gas emissions. In order to meet the government’s net zero commitments, a significant shift in the way domestic and non-domestic buildings use energy needs to occur. Additionally, according to the [Commons Library](https://commonslibrary.parliament.uk/research-briefings/cbp-8730/) it is estimated that 13% of households in England (25% in Scotland, 14% in Wales, 24% in Northern Ireland) are classed as fuel poor. Improving the energy performance of buildings can contribute significantly to lowering energy bills for households, whilst decreasing the carbon output of the UK’s buildings and reducing overall energy demand. The Warm Homes Plan will contribute to this target by upgrading five million homes by the end of this parliament. The EPC acts as an enabling tool supporting actions across a range of areas working to improve the energy performance of buildings. This includes supporting lenders with information to assist with finance for energy efficiency improvement; allowing businesses to provide innovative products and services based on accurate building data and allowing government grants to be targeted to where it is most needed. The Energy Act 2023, which came into force in October 2023, provides the primary powers required to enable amendments to the EPB Regulations, and therefore represents a new opportunity for government to make these regulations smarter, more efficient and better suited to the UK. ### Vision for a reformed EPB framework While we have already made progress in improving the overall EPB Framework, there is more work to do and wider reform is needed to improve EPCs, DECs and ACIRs. This includes updating the Framework to reflect modern policy objectives, updating regulations to make them work better for businesses, and making sure the system works for UK markets. An EPC system that provides a wider range of higher quality building performance data, in a clear and accessible form, will mean that people using EPCs are better able to meet their own goals. The benefits will be seen, not only in improved EPCs themselves, but also in areas such as improved value for money of government grants; improved targeting of private and consumer finance; and improved quality of effectiveness of regulations. Since their introduction, the policy landscape around energy has changed greatly with new priorities including: * Clean Power by 2030 and accelerating net zero: boosting energy independence, saving families money, creating jobs, driving delivery across Whitehall and delivering on our mission. * Warm Homes Plan: Making a step change in progress in home decarbonisation this parliament to cut people’s bills, decarbonise the buildings sector, and slash fuel poverty. * A lower cost, fairer deal for consumers: Lowering bills, spreading costs more progressively, and protecting consumers. As a result, we need to make changes to the EPB Framework to ensure that it is fit for purpose in this new policy landscape. This means using powers in the Energy Act to reform the regulations, including undertaking a review to clarify and consolidate existing regulations in order to make them easier for businesses and individuals to comply with. Our vision is for a reformed EPB Framework which: * provides homeowners and tenants with accurate information about the energy performance of their homes to allow them to make informed investment and purchase decisions * provides accurate information to determine eligibility for schemes and measure progress against government targets * provides an information tool to support a range of actions including reducing carbon emissions, tackling fuel poverty, improving decency and the Warm Homes Plan * reflects the needs of wider users of EPCs beyond homeowners and tenants, such as suppliers of energy efficiency products and services, as well as lenders Taken together, these actions will mean the EPB Framework can deliver a more efficient and effective energy certificate system that works for all stakeholders, including landlords and tenants. We also envision the reformed Framework having several benefits specifically for businesses. For example, better quality data will be particularly beneficial for businesses or landlords who own a large number of homes or buildings, allowing them to better compare the impact of actions across their estates. Improving consumer trust in, and the overall reliability of energy certificates will hopefully increase the number of energy efficiency recommendations undertaken, helping to build demand and supply chains in this industry. We also know that EPCs are increasingly being used in Environmental, Social and Governance (ESG) reporting and investing, with a growing number of companies wanting to ensure their investments are environmentally responsible. Improving EPCs will allow companies to have more confidence in their potential investments. The following chapters set out the changes we think are needed to achieve this vision. ## 2. What EPCs measure This chapter sets out the government’s thinking, and seeks views, on a set of proposed metrics for assessing the energy performance of buildings, to be displayed on future EPCs. It is anticipated that any changes to the EPC metrics will be introduced in the second half of 2026. Further details concerning these proposed metrics are set out in the [Technical Annex](https://www.gov.uk/government/consultations/reforms-to-the-energy-performance-of-buildings-regime/technical-annex-for-chapter-2-what-epcs-measure) to this document. ### Context While EPCs display various metrics about a building’s energy performance, the headline metric serves as the primary indicator of its overall energy efficiency. For domestic buildings, the Energy Efficiency Rating (EER) is the headline metric, calculated using modelled energy costs per square metre based on standardised heating patterns, temperatures, and fixed fuel price assumptions. For non-domestic certificates, modelled carbon dioxide emissions per square metre form the basis of the Environmental Impact Rating (EIR) headline metric. These metrics are calculated using information gathered during a physical inspection of an existing building or from drawings and specifications for a new build. These headline metrics are expressed as an A-G scale ratings (A+-G for non-domestic), alongside recommended retrofit measures to improve the rating. They serve as the basis for regulatory targets and inform retrofit investment decisions by public and private entities. Both the current EER and EIR metrics have flaws. The EER is based on assumptions about fuel costs, which can rapidly become outdated as relative fuel prices fluctuate and lead to unintended outcomes. For instance, installing a heat pump could reduce the EER due to the higher relative cost of electricity compared to gas, despite heat pumps being an efficient low-carbon heating solution. The EIR can give an incomplete picture of energy performance in the context of grid decarbonisation. A building may see an improvement in its EIR rating as the carbon-intensity of electricity generation falls towards zero in line with the government’s clean power mission, even if no action has been taken to improve its performance. Ultimately, both metrics are influenced by factors beyond the building owner’s control: energy costs and the carbon intensity of the grid. The government recognises the current metrics may not provide a sufficiently rounded picture of performance and could better support government priorities such as delivering net zero by 2050, tackling fuel poverty, and improving decency. The government acknowledges concerns raised about the current metrics including by the [Climate Change Committee (CCC)](https://www.theccc.org.uk/publication/letter-reform-of-domestic-epc-rating-metrics-to-lee-rowley-mp/) and has taken careful account of their views and recommendations in the proposals set out in this chapter. The government has also taken into account the [recent consultation by the Scottish Government](https://www.gov.scot/publications/energy-performance-certificate-epc-reform-consultation/) on reforms of the EPC system in Scotland and recommendations in recent reports from a range of stakeholders. Any changes to EPC metrics will need to be reflected in the relevant approved assessment methodologies for EPCs. Currently these are Standard Assessment Procedure (SAP) 10.2 for new dwellings, Reduced Data SAP (RdSAP) 2012 for existing dwellings, and the National Calculation Methodology (NCM) for non-domestic buildings. SAP and RdSAP are planned to be replaced by the [Home Energy Model (HEM)](https://www.gov.uk/government/consultations/home-energy-model-replacement-for-the-standard-assessment-procedure-sap) in future and an EPC methodology for the HEM is currently under development. Any revised EPC metrics for dwellings will be introduced with the transition to HEM in the second half of 2026. We intend to consult on a Home Energy Model methodology for producing EPCs in 2025. ### Objectives The government wants EPC metrics to be helpful for everyone, including homeowners, tenants, landlords, and building owners. EPCs should provide information that is easy to understand about the energy performance of a building and how it compares with other buildings, and how to improve it to lower fuel bills and reduce carbon emissions. Additionally, EPCs should support the government’s wider goals, such as achieving net zero emissions, encouraging the use of low carbon heating systems, and reducing fuel poverty. By presenting this information in a clearer, more accessible way, the government aims to make EPCs more useful, complete and understandable for everyone. ### Clear performance benchmarks EPC metrics should provide clear benchmarks of performance that can be used to aid decision making, set policy targets and establish regulatory requirements, such as minimum energy efficiency standards for rental properties. Furthermore, EPCs can provide valuable information about the energy performance of the entire building stock in the country. ### Proposal for multiple metrics The government is proposing using multiple metrics on EPCs to provide a more complete representation of building energy performance. A single headline metric, like the current EER, is proving to be insufficient to meet the diverse needs of users and policy objectives. In this consultation, the government wants to understand the potential of a range of metrics that could be used in EPCs. The government has considered the following potential metrics: * Energy cost: helping individuals understand the financial implications of a building’s energy efficiency and make informed decisions about potential improvements * Carbon: an estimate of the carbon emissions arising from the energy used in the building * Energy use: offering insights into overall energy consumption and identifying areas for energy efficiency improvements * Fabric performance: assessing the thermal performance of a building’s envelope and promoting the importance of well-insulated, comfortable, and energy-efficient spaces * Heating system: providing information on the efficiency and environmental impact of a building’s heating source and encouraging the adoption of cleaner heating technologies * Smart readiness: assessing a building’s potential to integrate smart technologies that can optimise energy consumption and the ability of consumers to benefit from cheaper smart tariffs The government is interested in how such an approach will help support the goal of improving the energy performance of buildings across the country, ultimately benefiting individuals by reducing their energy costs and contributing to wide ranging policy initiatives. The utility of different metrics may differ between domestic and non-domestic buildings, given differences in the way that energy is used in these buildings. When considering the potential of proposed metrics, the government would be interested in views about their suitability and usefulness for both domestic and non-domestic buildings. The government is proposing that domestic EPCs use four headline metrics; ‘fabric performance’, ‘heating system’, ‘smart readiness’ and ‘energy cost’ as headline metrics, with other metrics provided as secondary information. These metrics together convey the key, complementary aspects of building energy performance, allowing the user to distinguish where the home performs more or less well. Supporting people to keep their energy bills low has always been a key purpose of EPCs and the energy cost metric will provide this information. A well performing home, should have a good level of insulation to ensure a high level of thermal comfort and a low overall energy demand intensity, which a fabric performance metric can demonstrate. It should also be efficiently heated using low-carbon energy sources, which can be demonstrated via a heating system metric. Where possible, if a home can generate its own electricity and be able to be flexible with its energy use it can minimise its impact on the electricity grid, and a smart readiness metric can demonstrate how able a property is to achieve this. The government is proposing the carbon metric is maintained as the single headline metric on non-domestic EPCs at this time. Non-domestic EPCs are already carbon focused and are in line with our net zero objectives. As a consequence, we aim to maintain some consistency in the short term, particularly in light of any regulations which they underpin, such as minimum energy efficiency standards. We may consider adding new primary or secondary metrics over time where appropriate. As such, we welcome views on whether the proposed new metrics may also be suitable for non-domestic buildings at a future stage. ### Presentation of metrics Using multiple complementary metrics as the government proposes marks a significant change from the current system of a single metric rating and considering the impact on EPC users will be important in the final design of the EPC. It will be important for the new metrics to be presented clearly on EPCs to provide clarity, enable comparisons, offer improvement guidance, support compliance, and incentivise energy efficiency. To ensure our homes and buildings support our journey towards net zero, EPCs need clear and actionable energy performance information. EPCs are provided through the government run ‘Find an energy certificate’ service and is responsible for designing the layout of the existing EPC and maintaining the service in line with the principles for a clear and accessible government digital service. In order to develop the most effective presentation of new EPC metrics, government will undertake a programme of research into user needs and preferences which will guide our decisions on how to make the EPC information clear and impactful. Government will consider how best to present information about the metrics to enable users to benchmark the performance of their building against others, how to understand their compliance with regulations that use EPCs, and support decision making when considering energy efficiency retrofit options. This will ensure that the end users needs are placed at the heart of the reformed EPC presentation. In line with our standard practice all changes to the EPC layout and presentation will involve user testing with a wide range of stakeholders to ensure a broad range of views are taken into account. ### Other metrics As government priorities change over time, it is likely that EPC metrics may need to change again in future to support and reflect this. Energy Performance Certificates (EPCs) could potentially expand beyond measuring energy efficiency to include other aspects of building performance. For instance, EPCs might incorporate metrics related to a building’s resilience to climate change impacts and its adaptation measures. Additionally, metrics concerning occupant health, wellbeing, biodiversity, and water efficiency could be evaluated. The data shown on EPCs could be incorporated with actual energy use data which could provide feedback to occupants on how their behaviour is influencing their energy consumption, as well as highlighting any discrepancies between the predicted performance of a building during design versus in operation. However, at this time we wish to focus on the reforms proposed above, rather than expanding the scope of this consultation. Further information on each metric being considered is given below in this chapter, and in the accompanying [Technical Annex](https://www.gov.uk/government/consultations/reforms-to-the-energy-performance-of-buildings-regime/technical-annex-for-chapter-2-what-epcs-measure) to this document. ### Energy cost Reducing energy bills is a key driver for energy efficiency improvements in buildings. The Energy Efficiency Rating (EER) for domestic EPCs is a measure of the calculated costs of energy used per floor area, providing a comprehensive metric that reflects the impact of all aspects of regulated energy performance on costs per floor area. As a result, the EER has been used as the basis for several government policies, including the domestic minimum energy efficiency standards (MEES) for the private rented sector (PRS) and the fuel poverty target in England. However, using a cost-based metric like EER presents several challenges: * Assumptions of fuel prices used to calculate the EER can quickly become outdated, as they are usually only updated alongside new versions of the SAP methodology. The prices currently used for existing dwellings were fixed in 2014, which does not accurately reflect the current energy price landscape or available tariffs. * Updating price assumptions could cause dwellings to move between EPC bands despite no actual changes in the energy performance of the building. * A cost-based metric may not incentivise switching from fossil fuel heating to low-carbon alternatives because of the effects of the relationship between fuel prices incorporated within the methodology. Despite these challenges, the government recognises the importance of users understanding their building’s predicted energy costs and the measures they can take to reduce them. This would also enable better-targeted support to tackle fuel poverty. Additionally, the EER is currently the basis for existing and proposed regulatory targets, and a clear transition will be needed if the EER is no longer used as the headline metric to ensure that duty holders are clear about compliance requirements. The government considers that there should continue to be a calculation of predicted costs of the energy used in the building and that a metric based on this should continue to be shown prominently on the certificate. However, the government does not believe that a cost-based metric should be the sole, headline metric to determine EPC ratings for domestic buildings and welcomes views on this. In designing any new cost-based metric, the government will be mindful of the balance between using a stable price basis for consistency over time and accuracy. For non-domestic EPCs, the EER is not currently displayed, and the government is interested in views on whether a cost-based metric should be included in the future. #### Question 1 To what extent do you agree or disagree that information using an energy cost metric should be displayed on EPCs? Please select one option for each building type. Domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree Non-domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning, and provide any evidence to support your view. ### Fabric performance Fabric performance is a crucial aspect of a building’s energy efficiency, as it refers to the thermal properties of the building and its ability to maintain a different temperature from its surroundings. The level of insulation, window quality, and the quality of construction or retrofit all contribute to a building’s fabric performance, which in turn determines the typical demand for space heating and cooling. Improving fabric performance can also help enhance the efficiency of heating systems, particularly heat pumps. Including a fabric metric as a headline metric on EPCs would offer several key benefits: * A fabric metric could provide a clear basis for identifying and prioritising improvements to the building’s thermal properties. This would enable building owners and occupants to make informed decisions about upgrading insulation, windows, or other elements of the building fabric to enhance energy efficiency. * By prominently featuring a fabric metric on EPCs, building owners and occupants would be encouraged to take action to improve the building’s thermal performance. * A fabric metric could serve as a proxy for thermal comfort. Better thermal comfort means homes will feel warmer in winter and more comfortable for residents, enhancing their overall well-being and satisfaction with their living environment. There are several methodologies available to measure the fabric performance of buildings. The [Fabric Energy Efficiency Standard (FEES)](https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1133079/Approved_Document_L__Conservation_of_fuel_and_power__Volume_1_Dwellings__2021_edition_incorporating_2023_amendments.pdf) is a compliance target in Building Regulations for new homes, estimating the home’s heating and cooling energy demand, independently of the actual heating system employed. The FEES considers energy which would be used for cooling during warm periods as well as energy used for heat in cold periods. An alternative fabric metric is the Heat Loss Parameter (HLP) or Heat Transfer Coefficient (HTC). This widely recognised figure can be estimated through co-heating tests and other on-site measurement techniques. However, unlike FEES, the HLP/HTC does not factor in the impact of solar gains or potential cooling demand, thus providing a more partial view of overall thermal performance. The government considers that FEES may be better suited for assessing a building’s resilience to future climate impacts and ensuring energy efficiency across varying seasonal conditions. #### Question 2 To what extent do you agree or disagree that information derived from a fabric performance metric should be displayed on EPCs? Please select one option for each building type. Domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree Non-domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning and provide any evidence to support your view. #### Question 3 When evaluating the fabric performance of buildings, which methodology do you think should inform the basis of calculating a fabric metric? Please select one option for each building type. Domestic buildings * No preference * Don’t know * FEES * HLP/HTC * Other Non-domestic buildings * No preference * Don’t know * FEES * HLP/HTC * Other If you wish, please explain your reasoning and provide any evidence to support your view. ### Heating system A heating type metric ranks different heating systems based on their technology or type, aiming to incentivise the transition to efficient low-carbon options like heat pumps over more energy intensive direct electric heating or carbon intensive fossil fuels. By clearly distinguishing systems and highlighting both their environmental impact and efficiency, a heating metric could provide straightforward guidance for achieving net zero emissions in buildings. The key aims are twofold: encouraging low carbon heating adoption and offering a simple, understandable tool for informed decision-making. Beyond carbon intensity, the metric could consider factors such as overall system efficiency, fuel availability, and sustainability. The metric’s usefulness lies in its ability to shift users towards environmentally friendly heating solutions through clear rankings and guidance. It offers a simple reference for homeowners, builders, and policymakers, while supplementary information can indicate a building’s readiness for low carbon heating upgrades, facilitating cost-effective transitions. #### Design of a heating system metric The way the heating system metric is designed is crucial for effectively encouraging the switch to more efficient and low-carbon heating systems. The metric needs to clearly rank different heating system types based on their environmental impact, efficiency, and how well they align with achieving net zero emissions goals. A well-designed metric will provide a straightforward ranking (explicit or implicit), placing efficient low-carbon options like heat pumps at the top, energy intensive but potentially low carbon electric systems like direct electric heating in the middle, and fossil fuel systems at the bottom. Additionally, the metric’s design should look at more than just carbon emissions alone. By considering factors such as the overall efficiency of the system, fuel availability, and sustainability, the metric can give a more comprehensive evaluation of heating systems. The government thinks it is important that the metric can distinguish between the efficiency levels of systems within the same category. For example, a more efficient heat pump should be ranked higher than a less efficient heat pump unit. This allows the metric to provide a more nuanced ranking beyond just broad categories of heating system types. Factoring in system efficiency in this way would incentivise installation of high-performing low-carbon options. #### Question 4 To what extent do you agree or disagree that information based on a heating system metric should be displayed on EPCs ? Please select one option for each building type. Domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree Non-domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning and provide any evidence to support your view. #### Question 5 What are your views on the design principles and the scope for a Heating System metric? Please provide evidence where possible. ### Smart readiness The [Smart Systems and Flexibility Plan](https://www.gov.uk/government/publications/transitioning-to-a-net-zero-energy-system-smart-systems-and-flexibility-plan-2021) sets out a vision for a smarter and more flexible energy system, which is better able to manage the expected increase in demand for low-carbon electricity. Smart meters, intelligent appliances like EV charging points, Solar PV battery storage, and heat pumps, along with smart tariffs and services, will enable and encourage users to adapt their consumption patterns to match periods of cheap, abundant low-carbon electricity supply. These services may often operate automatically, programmed to meet user needs by storing cheaper renewable energy in batteries for use during pricier peak periods, optimising consumption to leverage low-carbon sources when most available and cost-effective. * a smart readiness metric could help users understand their building’s potential to optimise energy usage and reduce demand during peak periods through smart technologies like meters, appliances, storage systems, and time-of-use pricing * it could support building users to increase self-consumption of any on-site renewable generation so reducing grid reliance and maximizing value of distributed energy resources * incorporating a smart readiness metric that includes microgeneration self-use and the buildings potential to participate in demand response activities would complement the proposed fabric and heating system metrics The design of any potential smart readiness metric is critical to ensure it effectively captures the key aspects of a building’s ability to integrate with a flexible energy system. The metric should provide a comprehensive assessment that is both informative and actionable for stakeholders, including building owners, operators, and policymakers. The government would welcome views on the potential definition, scope, and design principles of a smart readiness metric: * how should a smart readiness metric be defined, and what relevant characteristics of the building and appliances should be considered? * should the metric focus solely on smart building systems, or should it also include smart domestic appliances? * how can we distinguish between different tiers of smart readiness, associating them with specific functionalities and technologies to create a practical framework for evaluation? #### Question 6 To what extent do you agree or disagree that information based on a smart readiness metric should be displayed on EPCs? Please select one option for each building type. Domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree Non-domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree #### Question 7 What are your views on the definition, design principles and the scope for a smart readiness metric? Please provide evidence where possible. ### Energy use Energy use metrics can provide an informative view of a building’s performance. Depending on the type of energy use metric chosen, they can be less influenced by external factors compared to cost-based metrics such as the EER. They focus on the predicted energy consumed within the building, making them a more reliable indicator of a building’s efficiency. EPCs currently provide information based on a dwelling’s predicted energy needs for space heating, hot water, lighting and pumps and fans, as well as an estimate of the dwelling’s primary energy use. Displaying an energy use metric on EPCs would offer several benefits: * It would help users understand the building’s predicted energy consumption and identify areas for improvement. * Energy use metrics can allow for easy comparison of energy performance between different buildings. This benchmarking can help owners and occupants understand how their building’s energy consumption compares to similar properties. * It would provide a consistent measure of building performance, as energy use is less affected by external factors such as fluctuations in energy prices or changes in the electricity grid mix. Energy use metrics can provide a direct, reliable, and easily understandable way to assess and compare the energy efficiency of buildings and help users make informed decisions about improving energy performance. When considering energy use metrics for EPCs, it is important to understand the different types of metrics available and their implications for assessing building performance. Some examples of energy use metrics include: Primary energy use: * measures the total energy contained in the raw natural resources used to generate electricity or heat * accounts for losses and inefficiencies in the conversion and distribution processes for example in the power station generating the electricity * currently displayed on EPCs as kWh/m2 but not as a headline metric * used in Building Regulations for compliance targets Delivered energy (final consumption): * represents the energy delivered to the building to meet its energy demand * typically expressed as the kWh consumption figure reported on energy bills * reflects the actual fuel used in the building, excluding on-site generation * more easily understandable for users and potentially better suited as a headline metric for existing buildings While primary energy use accounts for the overall energy consumption from source to end-use, it can be affected by factors outside the control of building owners, such as changes in the electricity grid mix. Conversely, delivered energy focuses on the energy directly consumed within the building, making it a more straightforward and relevant metric for assessing building performance. While the government recognises the utility of energy use metrics and believes they should continue to be shown on the EPC, we believe that the combination of energy demand, heating efficiency and electricity generation information provided by the proposed headline metrics can convey the same information in a more relevant and informative way. #### Question 8 To what extent do you agree or disagree that information from an energy use metric should be displayed on EPCs? Please select one option for each building type. Domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree Non-domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning and provide any evidence to support your view. #### Question 9 If an energy use metric is to be displayed on Energy Performance Certificates (EPCs), which type of energy use measurement should be used to calculate this metric? Please select one option for each building type. Domestic buildings * No preference * Don’t know * Delivered energy * Primary energy * Other (please specify) Non-domestic buildings * No preference * Don’t know * Delivered energy * Primary energy * Other (please specify) If you wish, please explain your reasoning and provide any evidence to support your view. ### Carbon The current EIR metric on EPCs is based on modelled carbon emissions of the building. As well as providing information about the individual building, a carbon metric provides a way of measuring progress to meeting net zero across the building stock. There are challenges with this metric and the CCC did not include it as one of their recommended headline metric for homes, particularly in the context of a rapidly decarbonising electricity system, although information about the building‘s carbon emissions should still be provided on the EPC. The government acknowledges the importance of providing information about carbon emissions on EPCs. However, it believes that for domestic buildings, a carbon metric like the EIR should not be the primary indicator of building performance. This is because the EIR, in its current form, may not effectively incentivise the actions necessary to achieve net zero emissions in an energy efficient manner. Additionally, as this emissions factors change over time, the rating for a property may change even when no changes have been made to the building itself. The government suggests that other proposed metrics (in particular a heating system metric) could be more effective for driving this action. Currently, the EIR is the headline metric displayed on non-domestic EPCs. The government not currently proposing to change this but is interested in gathering views on whether a carbon-based metric should be retained as a headline rating for non-domestic buildings. #### Question 10 To what extent do you agree or disagree that information from a carbon based metric should be displayed on EPCs? Please select one option for each building type. Domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree Non-domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning and provide any evidence to support your view. ### SMETER methods The government has been considering ways to introduce methods for measuring the thermal performance of homes using smart meter data, weather data and (usually) other data such as internal temperature data. The resulting products have been collectively termed Smart Meter Enabled Thermal Efficiency Ratings ([SMETERs](https://www.gov.uk/guidance/smart-meter-enabled-thermal-efficiency-ratings-smeter-innovation-programme)). Some examples of SMETERs would be the calculated building heat transfer coefficient or standardised heating demand derived from measured data in combination with simple statistical models. SMETER products could support comparisons of the calculated asset heating demand with actual outcomes (based either on user behaviour or standard assumptions). This would help to identify different types of performance issues. Following the development, testing and demonstration of SMETER methods, and growing industry deployment of SMETER products and services, government is currently moving to piloting applications for net zero priority areas while developing approaches to quality assurance, prior to potential widescale introduction of these methods at a national level. Whilst work to date has focussed on the residential sector, the government would also welcome views on the use of SMETER technologies in commercial buildings. #### Question 11 To what extent do you agree or disagree with incorporating smart metering technologies, like SMETERS, into the energy performance assessment framework for buildings? Please select one option for each building type. Domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree Non-domestic buildings * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning and provide any evidence to support your view. ### Transition It is anticipated that any changes to the EPC metrics will be introduced in the second half of 2026. Users will need time to adjust to the new metrics and changes to the metrics may impact on regulatory targets, grant eligibility criteria and the way investments in retrofit are assessed and planned which are currently expressed in terms of meeting specified EER ratings. The government expects that new and/or amended metrics will be introduced for domestic buildings with the [Home Energy Model](https://www.gov.uk/government/consultations/home-energy-model-replacement-for-the-standard-assessment-procedure-sap) (rather than updates to SAP/RdSAP). An EPC methodology for the Home Energy Model is currently under development and will be consulted on in 2025. Any changes to the metrics for non-domestic buildings will be implemented through updates to the National Calculation Methodology for non-domestic buildings. The government recognises the importance of a carefully planned transition over an appropriate time frame. This will aim to ensure that: * The continuity of current heat and buildings policy is maintained, to avoid any hiatus in delivering against decarbonisation targets. * Actions to improve the performance of buildings can continue uninterrupted and that duty holders are clear about how to comply with requirements. * There is continuity for those policies and schemes which use EPCs. * Duty holders can continue to comply and evidence that those who have already met requirements are not penalised under the new metrics. At this stage the government cannot say which metrics may be used for individual future policies, regulations or schemes. That will be a matter for the design of those policies which will be subject to their own consultations. However, the government does not want changes to metrics to penalise duty holders who may have taken action to bring themselves into compliance with future targets or to affect existing compliance. When the new version of the calculation methodology is introduced, all new EPCs will be produced using that new version, including the new metrics. Existing EPCs will continue to display the old metrics. Changes to the metrics will not invalidate existing EPCs, so existing EPCs could still be used to demonstrate compliance with existing regulatory requirements for the period of their validity. This will mean that there will be a progression over time to the new metrics as EPCs using old metrics reach the end of their validity period. Users will need to understand how any new metrics relate to the existing metrics and how ratings between them may compare, for example through some form of equivalence arrangement. It will not be possible to have direct equivalence between all old and new metrics because they will be measuring different things. Nor could it guarantee that an EPC calculation with new metrics would generate the same band as an EER-based calculation. However, it could give users an indication of how a property’s energy performance might be measured in future. Future regulatory targets or scheme benchmarks will need to reflect new metrics once they are introduced. The government anticipates there will be appropriate policy or scheme specific transition periods to enable duty holders to implement any new measures needed to meet any new targets. The government recognises however that some duty holders may have already acted to achieve compliance with future targets based on existing metrics and may have commissioned an EPC on that basis. The government is keen to encourage early action and individual policies will explore options for ‘deemed to satisfy’ arrangements, or ‘carry over’ rights. #### Question 12 Do you have any views on key transition issues? ## 3. When EPCs and DECs are required This chapter sets out proposed changes to when EPCs and DECs are required. These changes aim to improve access to up-to-date energy performance information across a broader range of property types. These include reducing the validity periods for EPCs and DECs, as well as removing flexibilities and exemptions for certain types of buildings. ### Reducing the validity periods for EPCs At present, an EPC is valid for 10 years. However, a valid EPC is currently only required at the point of build, sale, or grant of lease in the rented sectors. Therefore, many EPCs do not actually need to be renewed when their validity period ends. Reducing the validity period of EPCs could allow building upgrades, such as fabric changes, to be captured more frequently. This would provide prospective buyers and tenants with more accurate and up-to-date information to inform decision making which may directly impact their cost of living. An increasing number of energy performance and decarbonisation policies are underpinned by an EPC rating. As net zero policies and low carbon technologies evolve, the details of recommendations provided by EPCs are likely to be developed. Reducing the validity period of EPCs would therefore more accurately inform building owners on how to improve their buildings and ensure that EPCs more accurately reflect the current state of a property. The process of undertaking an EPC can also be a useful prompt for building owners to consider the recommendations for their buildings, contributing to more cost- and carbon-efficient building stock. The average length of occupation for owner occupiers is 16.8 years, compared to 4.3 years in the private rented sector and 12.2 years for social rented tenants ([EHS 2022-23](https://assets.publishing.service.gov.uk/media/657c3ff691864e001308bdba/2022-23_EHS_Headline_Report.pdf)). For non-domestic buildings, we estimate the typical lease length to be 9.4 years (source: Savills based on MSCI data for 2021 covering 54,209 leases). Given the more frequent turnover in the PRS, a reduced validity period would more greatly impact PRS landlords. There may be an information benefit for prospective PRS tenants and policymakers for more current EPCs, and landlords may be able to capture upgrades to their properties more easily, in turn potentially improving desirability in the market and aiding compliance with regulations such as MEES. However, landlords may also incur a very small increase in costs from more regular EPCs. If we are to reduce the validity period of EPCs, we could take several different approaches to this transition. For example, we could allow all existing EPCs to remain valid until the end of their original validity period; when the validity period is reduced, we could make all EPCs with a 10 year validity period invalid; or we could implement a two year transition period where existing validity periods are retained, but at the end of which the new validity period comes into force. The government’s preference is to allow all existing EPCs to remain valid until the end of their existing validity period and apply any new validity period to new EPCs. #### Question 13 What should be the validity period for Energy Performance Certificate (EPC) ratings? * Don’t know * Less than 2 years * 2 years * 5 years * 7 years * 10 years #### Question 14 To what extent do you agree or disagree with the approach for any changes to validity periods to only apply to new EPCs? * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning and provide any evidence to support your view. ### Requiring a valid EPC throughout the tenancy period Currently in both the private and social rental sectors when an EPC expires, a new EPC is only required when a property is re-let and not when the same tenant renews or extends their lease. The government is committed to upgrading five million homes by the end of this parliament. Additionally, it has committed to reducing fuel poverty by ensuring as many fuel poor homes in England as reasonably practical achieve a minimum EER of band C by the end of 2030. While the average tenancy length in the Private Rented Sector (PRS) is currently below the validity period of an EPC (4.3 years), the average tenancy length in the Social Rented Sector (SRS) is longer (12.2 years), and in both tenures there will be many longer-term tenants living in properties without a valid EPC. In addition, even if a tenant is in a property for less than the average period, the EPC for that property could still expire while they were living there. The presence of a valid EPC throughout a tenancy, rather than solely at point of marketing, would ensure landlords and tenants are equipped with accurate and up-to-date information. This could also help improve compliance with government policies and commitments such as MEES and ensure that properties remain attractive to existing and potential tenants. As the Energy Efficiency (Private Rented Property) (England and Wales) Regulations (2015) only applies to private sector properties which are required, or are part of a building which is required, to have a valid EPC, these types of properties (where the EPC has expired, and the same tenant remains in situ) are not covered by the PRS Regulations. Requiring a new EPC for rented buildings when the existing one expires would therefore ensure most new lease renewals are captured within the scope of the PRS Regulations. We are proposing to introduce for private rental properties a new trigger point where an EPC is required for when the current one expires. This measure would also support energy performance improvements in PRS buildings that are subject to MEES. It would be similar to other requirements on landlords throughout tenancies, such as valid building insurance or gas safety certificates, and can be managed through letting agents where appropriate. Close working between MEES enforcement bodies and EPC enforcement bodies can assist with managing overall compliance rates. #### Question 15 To what extent do you agree or disagree that a new EPC should be required when an existing one expires for private rented buildings? * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning and provide any evidence to support your view. ### Marketing a building for sale or rent Current regulations require an EPC to be commissioned prior to a building being marketed for sale or rent but allow a maximum of 28 days following the marketing for the certificate to be produced. These regulations were established around a concern that the inability to obtain an EPC should not hinder the property market. However, the EPC market has matured and has proven able to consistently provide EPCs when required by the property market. We propose an amendment to the regulations to state that a building should not be marketed for sale or let without an EPC. This will ensure that buyers and renters have information available to them at the point of making a purchasing decision whilst making the requirements clearer and easier to enforce. #### Question 16 To what extent do you agree or disagree that the regulations should be amended so that a property must have a valid EPC before it is marketed for sale or rent? * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning and provide any evidence to support your view. ### Houses in multiple occupation We are proposing to extend the scope of EPCs so that a valid one is required for an entire house in multiple occupation (HMO) when a single room within it is rented out, as currently the [guidance](https://www.gov.uk/government/publications/energy-performance-certificates-for-the-construction-sale-and-let-of-dwellings/a-guide-to-energy-performance-certificates-for-the-marketing-sale-and-let-of-dwellings) states that an EPC is not required in this instance, only when the whole house is rented out. The PRS MEES Regulations apply to most domestic rental properties which are required to have an EPC. Mandating EPCs for HMOs when a single room is rented out will ensure that HMOs will need to comply with the requirements set out in the MEES Regulations if they did not have a valid EPC before this point. This would provide consistency across the private rented sector. As a result, we are proposing a 24-month transitional period for any HMO landlords newly brought into the scope of the regulations to obtain a valid EPC. This would also ensure reasonable time to comply with MEES requirements if these were applicable If a requirement to have an EPC throughout the tenancy period is introduced, for HMOs where there are often multiple separate tenancies running concurrently for a single property, this change will require an EPC to be in place at the point of marketing for the first letting, up to and including the date the final letting comes to an end. A valid EPC for an HMO when a room is rented out would ensure that a prospective HMO tenant could make informed decisions based on the energy performance of the building and an indication of potential energy costs. Introducing MEES compliance would also result in lower fuel bills and increased comfort for the tenants within the HMO. As HMOs are disproportionately occupied by vulnerable people, we anticipate that these measures will help ensure that tenants are living in thermally comfortable properties, with reduced costs during a time of high fuel poverty. Current exemptions for MEES, such as the cost cap, would be maintained in order to ensure costs for landlords were viable. #### Question 17 To what extent do you agree or disagree that houses in multiple occupation (HMOs) which don’t already fall under the (Minimum Energy Efficiency Standards) MEES should do so when a room is rented out? * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning and provide any evidence to support your view. #### Question 18 To what extent do you agree or disagree that there should be a transitional period of 24 months to allow HMO landlords to obtain a valid EPC and comply with MEES regulations? * Strongly disagree * Disagree * Neither agree nor disagree * Agree * Strongly agree If you wish, please explain your reasoning and provide any evidence to support your view. ### Short-term rental properties At present the rules for when short-term rental properties require an EPC are set out in the [guidance](https://www.gov.uk/government/publications/energy-performance-certificates-for-the-construction-sale-and-let-of-dwellings/a-guide-to-energy-performance-certificates-for-the-marketing-sale-and-let-of-dwellings) under the rules for holiday lets and there are no specific requirements set out in the EPB regulations themselves. The current guidance states that an EPC is only required for properties rented out as a furnished holiday let, as defined by HMRC, where the building is occupied for the purposes of a holiday as a result of a short term letting arrangement of less than 31 days to each tenant, and is rented out for a combined total of four months or more in any 12 month period, and if the occupier is responsible for meeting the energy costs for the property. We are proposing updating the regulations to provide a specific requirement for short-term rental properties to have a valid EPC at the point of being let. MHCLG is working with DCMS to ensure that the definition of short-term rental property within the regulations aligns with DCMS’s definition of a short-term rental property. This is set out in the Levelling Up and Regeneration Act 2023, (and will be further defined in the context of the registration scheme to be implemented by DCMS for specified short-term