EPC Reform - Consultation closed

Public feedback on the EPC Reform consultation has now ended – the deadline was February 26th 2025.

We’re expecting the UK Government to respond to this one within 12 months. There’s a tight turnaround time to finalise this, as the new-look EPC will need to be ready to roll out with the new Approved Document Part L, and the new methodology tool for generating EPCs for new houses – the Home Energy Model.

If one cog in this mechanism is delayed, the whole roll-out could be postponed.

All the excitement about EPC Reform was kicking off before I launched this blog, so for the benefit of those who don’t follow me on LinkedIn, here’s a summary of what’s being proposed:

Energy Performance Certificates currently look like this. A new multi-info dashboard is proposed.

For nearly 20 years, Energy Performance Certificates have been a legal requirement for new buildings.

They’re required for both residential and non-residential properties, and are also required when existing buildings are rented to new tenants, or sold completely.

Out of all the documents us assessors produce, the EPC is the most recognised by the public. The A-G energy rating is a clear score on the performance of the building in question.

However, the contents of EPCs are constantly misunderstood, and the data is more frequently being used to for things it wasn’t designed for. For example, planning enforcement and green mortgage applications.

So a refresh will certainly be beneficial, and now's the perfect time to implement a new look, based on cleverer calculations.

Why is now the perfect time? Two reasons.. firstly, the introduction of the Home Energy Model (see above and other posts), but also, because of Brexit...

Until a few years ago, our EPCs had to meet the requirements of the Energy Performance of Buildings Directive - a law controlled by the European Union.

Post Brexit, UK countries now have the freedom to change what the EPC tells us, how it looks, or to scrap it completely!

The idea of getting rid of EPCs isn't as theoretical as it sounds… discussions to that effect took place during the Boris era. We're certainly on more stable ground these days!

So, what’s been proposed in this consultation?

The headline proposal is the plan to scrap the single A-G ranking for dwellings.

There's good logic for changing the metric.. the general public thinks of A-rated homes as the most energy efficient.

But A rated homes are those with the cheapest fuel bills which isn't necessarily the same thing.

Also, the current EPC calculates this value by assuming you use the heating system in a certain way, and sign up to an energy tariff from 2012, and ignores any energy that's used by your cooker, TV, hot tub and electric car.

Instead of giving each home a rating from A-G, the proposal is to present FOUR main metrices...

🔴 Energy costs - Fuel bills are staying on the EPC, but will be calculated very differently to improve accuracy.

🟠 Fabric performance - a rating that only considers insulation levels and the building shell - maybe based on the Fabric Energy Efficiency or Heat Transfer Coefficient.

🟡 The heating system - Is your heating high-efficiency, low-carbon and free from fossil fuels?

🟢 Smart readiness - Does your home have a Smart Meter? What about battery storage? Is it ready to connect to a smarter grid?

⚪ Emissions and energy use metrics will also be included on the EPC, but its proposed these numbers will be shown lower down the page.

The new look EPC will be created by the Home Energy Model, which is replacing SAP in 2026.

We don't yet know how the HEM EPC wrapper will work, but there'll be a separate consultation in 2025 to clarify this.

Meanwhile, for non-domestic buildings, the proposal is to keep things as they are:

🟣 A single rating based on carbon emissions.

This is an interesting choice... I've never understood why residential and commercial buildings are ranked differently. If we're trying to make EPCs easier to understand, shouldn't there be one approach for all?

Expiration dates

Currently, Energy Performance Certificates for buildings are expire after 10 years. It’s suggested the validity period could be reduced.

The logic being that EPCs will be more up to date if they're redone more frequently.

I know this is a controversial opinion, but I don't think EPCs should have an expiry date, at all.

Take my house as an example. I haven't upgraded anything in this house for 10 years. I know the energy performance hasn't changed.

And while it's always nice to have a cup of tea and catch-up with my local Domestic Energy Assessor, I'm sure there are houses more deserving of their visit. ☕ 

So, here's my alternative proposal:

🟢 New EPCs, created with the Home Energy Model, should automatically update their own emission factors and energy prices annually. Yes, ratings will change by themselves, but that's surely a good thing if we want better accuracy?

🟡 EPCs should remain valid, with no expiry date, until building work is carried out on the building.

🟠 At that stage, the registered tradesperson - whether they be glaziers, boiler installers, PV installers or general builders - trigger the current EPC to be marked as outdated.

🔴 The homeowner is then notified that a new EPC is required before selling or renting.

This targeted approach to EPCs would focus on those dwellings which need an updated survey the most. I know I'm in the minority with this opinion, and it's likely that the current expiration will be reduced for all cases, regardless of the condition of the building.

Whatever the UK Government decides, it's certain that EPC Reform is just around the corner, with an official response expected this winter (2025/2006).

I should also point out the above doesn't apply to Scotland, where a separate EPC Reform consultation is being underway as a devolved matter.

I'll post updates on this story as it develops.