In this article
- Fact-check: unresolved
- What is the law today, and what is only proposed?
- What does the "C before 1 October 2029" rule mean?
- Why does the delay to EPC reform matter?
- Should I get a new EPC now, or wait?
- Do I need a new EPC if mine expires during a tenancy?
- What exemptions are planned under the 2030 standard?
- What does a landlord risk if a property falls below the standard?
- What should a landlord do now?
- Keeping EPC dates in one place
Fact-check: unresolved
- SEO Description omitted "or is replaced" (flagged on the re-check). Corrected after the re-check to "…until it expires or is replaced…", but the correction has not been re-verified by the fact-checker. All body content passed the re-check.
Under the government's January 2026 response on privately rented homes, a property with an EPC showing an Energy Efficiency Rating of C or above before 1 October 2029 will be treated as compliant with the 2030 standard until that EPC expires or is replaced. This is confirmed policy, not yet law: today's legal minimum remains EPC E.
This article is for general information purposes only and does not constitute legal advice. Landlords should seek independent legal advice for their specific circumstances. It describes the position in England.
What is the law today, and what is only proposed?
The legal minimum today is EPC band E. Under the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, a landlord cannot let, or continue to let, a covered property rated below E unless a valid exemption is registered. The higher 2030 standard has been announced but still needs new legislation, which the government aims to bring into force in 2027, subject to Parliamentary approval.
| Point | Law today | Confirmed policy for 2030 (not yet law) |
|---|---|---|
| Minimum standard | EPC E | EPC C, measured on the new EPC metrics |
| Compliance date | In force since 1 April 2020 for existing tenancies | 1 October 2030 for all tenancies in scope |
| Cost cap | £3,500 including VAT | £10,000 per property |
| Spend that counts | Relevant improvements towards E | Relevant measures installed since 1 October 2025 |
| Maximum penalty | £5,000 per property in total | Up to £30,000 per breach for each property |
| Scope | England and Wales | England and Wales |
Covered property, meaning a property let on an assured, regulated or domestic agricultural tenancy that is legally required to have an EPC, is the test that government guidance uses for whether the 2015 Regulations apply. Landlords must keep meeting EPC E until the higher standard takes over. The wider picture on ratings, exemptions and the current cap is in our EPC guide for landlords.
What does the "C before 1 October 2029" rule mean?
It means the timing of an EPC now matters as much as its rating. The government response states that private rented homes scoring C or higher on the Energy Efficiency Rating before 1 October 2029 "will be considered compliant with the higher standard", and that this lasts until that EPC expires or is replaced.
An EPC is valid for ten years. The government's partial response on EPC reform says existing EPCs will retain their ten year validity once reformed certificates are introduced. On the current policy, a C rated EPC therefore carries a property beyond 2030 for the rest of its ten years.
Worked example. A flat receives an EPC rated C in March 2029. On the policy as announced, it is treated as meeting the new standard until March 2039, unless the EPC is replaced earlier. A neighbouring flat that reaches C only in November 2029 does not get that benefit, and will be assessed against the new metrics instead.
| EPC position | What the January 2026 response says happens |
|---|---|
| Rated C or above on an EPC dated before 1 October 2029 | Treated as compliant until that EPC expires or is replaced |
| Rated D or below before 1 October 2029 | New EPC showing the new metrics needed before works, then a post-works EPC before 1 October 2030 |
| C rated EPC expires after 1 October 2029 | Protection ends, and the property must then meet the new standard; when a replacement EPC will be required is still to be confirmed |
The detail will sit in the regulations, which have not yet been laid. Landlords are advised to treat the table as the direction of travel, not a final rule.
Why does the delay to EPC reform matter?
Reformed EPCs, built on the Home Energy Model and showing new metrics, will not arrive before the second half of 2027. The government updated the EPC reform consultation on 9 March 2026 to move the launch from October 2026 to the second half of 2027. Until then, every new EPC uses the current methodology and shows the familiar Energy Efficiency Rating. The government response adds that the Energy Efficiency Rating will remain as a legacy metric and be displayed on reformed EPCs for a period of time, which is how a 1 October 2029 cut-off can run past the 2027 launch.
That leaves a window for landlords who are close to band C. A property that reaches C on today's rating, and holds an EPC dated before 1 October 2029 showing that rating, is on the policy as announced outside the new metric test until that certificate expires or is replaced. The regulations will confirm exactly which date on the certificate counts.
Under the 2030 standard itself, landlords will first need to meet a primary fabric performance standard, then a secondary standard set against either the heating system metric or the smart readiness metric. The exact threshold that counts as "C" on those metrics will only be confirmed once the Home Energy Model methodology is finalised. Nobody can yet say precisely what a property will need to achieve under the new test.
Should I get a new EPC now, or wait?
That depends on where the property sits today. There is no single right answer, and the points below describe considerations, not obligations.
- Already rated C or above, EPC still valid past 2030: on the announced policy, a fresh EPC is unlikely to help. The response says compliance lasts until the EPC expires "or is replaced", so a new assessment that scores lower could cost the benefit. Landlords are advised to think carefully before commissioning a new EPC on a property that already holds a valid C.
- Rated C or above, EPC expiring before 2030: a new EPC dated before 1 October 2029 may extend the protection, provided the property still rates C on the assessment.
- Rated D, with low cost improvements available: carrying out the works and obtaining a C rated EPC before 1 October 2029 is the route the policy rewards. Spend on relevant measures installed since 1 October 2025 is set to count towards the future £10,000 cap.
- Rated E or below, with major work needed: on the current policy, the property will need a new metric EPC before works and a post-retrofit EPC before 1 October 2030. The response states that reasonable EPC assessment costs, as set out by government, will count towards the £10,000 cap.
Any property's current EPC can be looked up on the government's Find an energy certificate service, which shows the rating, the date of the certificate and the date it is valid until. Our certificate calendar for landlords sets out how EPC renewal fits around the gas and electrical cycles.
Do I need a new EPC if mine expires during a tenancy?
Usually not, on the current rules. The Energy Performance of Buildings (England and Wales) Regulations 2012 require an EPC mainly when a property is sold, let or marketed, and government guidance states the 2015 Regulations apply to properties legally required to have an EPC.
This is the area most likely to change. In its partial response on EPC reform, the government says it is "working to refine the position" on requiring a new EPC when an existing one expires for private rentals, and that it will confirm whether valid EPCs will be required throughout private rented tenancies in a later response. Landlords relying on an expired EPC are advised to watch for that decision.
What exemptions are planned under the 2030 standard?
The response keeps an exemptions system, registered on the PRS Exemptions Register, and adds new routes. Most exemptions are planned to last five years, with the longer ones noted below.
| Exemption | Planned effect | Planned duration |
|---|---|---|
| Cost cap | Applies once £10,000 is spent and the next measure would exceed it | 10 years |
| Property Value Adjustment | For properties valued below £100,000, the cap is 10% of the property's value | 10 years |
| Negative impacts | Combines the devaluation and wall insulation exemptions | 10 years |
| High cost and third party consent | Retained unchanged from the current regime | Typically 5 years |
| All relevant improvements made | Retained where no further improvements are possible | Typically 5 years |
| New landlord | Grace period for landlords buying a property with tenants in place | 6 months |
Registering false or misleading information on the register is already a penalty offence of up to £1,000 under the current regime, and the response says false or misleading exemption information will remain subject to a penalty. Evidence behind an exemption, such as quotes, surveys and EPCs, is worth keeping for as long as the exemption runs. Our record retention guide covers how long to hold each document.
What does a landlord risk if a property falls below the standard?
Today, a local authority may impose a financial penalty of up to £2,000 for letting a non-compliant property for less than three months, and up to £4,000 for three months or more, with a maximum of £5,000 per property in total, according to GOV.UK landlord guidance. Publication on the register can be imposed as well as, or instead of, a fine.
Under the 2030 policy, the government intends local authorities to be able to issue a penalty of up to £30,000 per breach for each non-compliant property. That figure depends on the new legislation, and the amount in any case will be for the authority to decide. The EPC is one of the core documents in our list of every certificate a landlord needs in England.
What should a landlord do now?
- List every property with its current EPC rating, certificate number, certificate date and expiry date.
- Mark any property rated C or above whose EPC expires before 1 October 2029, and diarise a renewal decision.
- For properties rated D, get advice on low cost measures that could reach C before 1 October 2029.
- Keep invoices and dates for every energy measure installed since 1 October 2025, as they may count towards the future cap.
- Avoid commissioning a fresh EPC on a property with a valid C rating without first weighing the risk of a lower score.
- Check any existing exemption on the PRS Exemptions Register and note when it ends.
- Watch for the draft regulations and the confirmed launch date for reformed EPCs.
Keeping EPC dates in one place
Once the 1 October 2029 cut-off applies, an EPC's certificate date and expiry date become planning data, not just paperwork. The LLCR platform records EPCs alongside gas and electrical certificates as part of its compliance tracking. An uploaded EPC can be read automatically for its dates, and email reminders go out 30 days and 7 days before expiry, so a renewal decision on a C rated property is made deliberately rather than by default.
Not sure which of your properties hold an EPC that will matter in 2030? The free LLCR compliance checker takes a few minutes and shows where each property stands today.
Frequently asked questions
Will my current EPC still be valid in 2030?
An EPC is valid for ten years, and the government has said existing EPCs will keep that ten year validity when reformed EPCs arrive. Under the January 2026 government response, a privately rented home with an EPC showing an Energy Efficiency Rating of C or above before 1 October 2029 is to be treated as meeting the 2030 standard until that EPC expires or is replaced. This is policy that still needs regulations, so it is not yet law.
Do I need a new EPC when my EPC expires during a tenancy?
Under the current regulations, the EPC duty is triggered mainly when a property is marketed for sale or let, so an EPC that expires part way through a tenancy does not usually have to be renewed straight away. The government has said it is still refining whether a valid EPC will be required throughout private tenancies, and it will confirm the position in a later response. Landlords are advised to watch for that decision rather than assume the current position will last.
How can I keep track of EPC expiry dates across several properties?
The simplest approach is to record, for each property, the EPC certificate number, its rating, the date of the certificate and the date it expires, and to set a reminder well before expiry. With the 1 October 2029 cut-off approaching, the date of an EPC now matters as much as its rating. The LLCR platform can read the dates from an uploaded EPC and send email reminders before it expires, so the renewal decision is made deliberately rather than by accident.
This article is provided for informational purposes only and does not constitute legal advice. LLCR is a compliance management platform, not a law firm. For advice specific to your situation, consult a qualified solicitor.
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