Energy building

On 4 December 2024 the government launched a consultation on reforms to the energy performance of buildings regime. The topics covered included:

• improving the applicability, quality and data usage of energy performance certificates in domestic and non-domestic buildings
• refining requirements for energy performance certificates and display energy certificates, and
• updating the metrics of energy performance certificates.

The consultation provided an opportunity for the property industry to give its views on reform of the legislative position on the energy performance of buildings. The consultation applies to England and Wales and closed on 26 February 2025.

Proposal for multiple EPC metrics

The government is proposing, especially for domestic buildings, using multiple metrics on energy performance certificates (EPCs) to provide a more complete representation of energy performance. A single headline metric, like the current energy efficiency rating for domestic buildings, is proving to be insufficient to meet the diverse needs of users and policy objectives.

For domestic EPCs (broadly meaning EPC for residential property), the proposal is for four headline metrics — fabric performance, heating system, smart readiness, and energy cost — with other metrics provided as secondary information.

For non-domestic EPCs (broadly meaning EPC for commercial property), the government is proposing that the carbon metric (an estimate of the carbon emissions arising from the energy used in the building) is maintained as the single headline metric. Non-domestic EPCs are already carbon-focused, and the government aims to maintain some consistency in the short term, particularly considering any regulations that they underpin, such as the minimum energy efficiency standards (MEES). The government is interested in gathering views on whether a carbon-based metric should be retained as a headline rating for non-domestic buildings.

It is anticipated that any changes to the EPC metrics will be introduced in the second half of 2026.

EPCs and DECs requirements

The consultation asks whether the validity period of EPCs (currently, 10 years) should be reduced. Among the reasons for the reduction is to ensure that EPCs more accurately reflect the current state of a property. If, ultimately, the validity period is changed, 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.

For private rented buildings, the consultation proposes that the expiry of a current EPC is a new trigger point for the requirement for a new EPC. Requiring a new EPC for rented buildings when the existing one expires would ensure that most new lease renewals would be potentially subject to MEES.

An amendment is proposed that a building should not be marketed for sale or letting without an EPC. The current position is to allow a maximum of 28 days following the marketing for the EPC to be produced.

The proposal is that all heritage buildings (those officially protected as part of a designated environment or because of their special architectural or historical merit) must have an EPC. However, EPC recommendations would be tailored appropriately to consider the nature of the buildings. Where MEES applies, the government will work to ensure owners of heritage buildings are not mandated to install unsuitable measures.

The government is considering reducing the validity period of display energy certificates (DECs) and DEC recommendation reports from 10 years to seven years for buildings between 250m² to 1,000m², and the validity period of DEC recommendation reports from seven years to five years for buildings over 1,000m².

The government proposes that the option to opt-out EPCs from the EPC register should be removed, to ensure that EPCs are available to all prospective buyers, tenants and enforcement bodies through the public address search function on the register.

However, the consultation does not propose any changes to the substandard ratings under the MEES regulations. Nor does it refer to the previous significant consultation on substandard ratings from 2021, Important new government consultations on energy efficiency. The current government has previously mentioned the possibility of residential property in England having to achieve a minimum EPC rating of band C by the end of 2030 – this consultation does not deal with these proposals.

Penalties and enforcement

The government proposes an increase in the penalties for breaches of the requirements of the EPC regulations, with one possibility being the doubling of penalties (for a non-domestic EPC, the maximum penalty would increase from £5,000 to £10,000). Increasing the six-month timescale for fines to be imposed is also being considered.

The government will work with local authorities on how to ensure more effective enforcement of the regulations.

Air conditioning inspection reports

Air conditioning inspection reports (ACIRs) are mandatory inspections, carried out by accredited air conditioning energy assessors at regular intervals not exceeding five years, for all air conditioning systems with an effective rated output of more than 12kW, including those that control ventilation, humidity and air cleanliness. The consultation includes proposals to both improve the format of ACIRs and their compliance regime.

Further information about MEES is available from the MEES Insight Hub and the Interactive MEES Flowchart PDF.