In this update, we look at proposed changes to energy performance certificates (EPCs) in social housing in England and Wales.
Energy performance certificate reform in social housing
Where are we now?
In England and Wales, EPCs are needed when homes are let or sold.
Private rented sector landlords can't rent out homes (or continue to rent them out) if they have an EPC rating of F or G. These properties are considered "sub-standard". But English registered providers of social housing and Welsh registered social landlords (Housing Associations) are specifically excluded from those rules if they are letting out "social housing" (defined as social or affordable rented and shared ownership properties).
No energy efficiency standards are currently in force for social housing in England.
The Welsh Housing Quality Standard 2023 requires EPC C by 31 March 2030.
What is changing?
In early December 2024, we saw the launch of a consultation on reforming the Energy Performance of Buildings regime in England and Wales, which includes EPCs. Our colleagues Julie Middlemass and Charlotte Scrivens have looked at what the changes might mean, particularly to the metrics and contents of an EPC. That consultation closes on 26 February 2025.
Some of the themes currently under discussion in the social housing sector are:
- by changing the metrics and content of an EPC, and the expectation that a tenant could have an EPC updated throughout the life of a tenancy (the consultation says that the average social rented tenancy is 12.2 years), more information will be readily available. Will this lead to "Green/Warm Rents" (ie. higher rents for green homes)?
- some have expressed concern that the cost of implementing the new proposals could impact on Housing Associations' decarbonisation programmes. The social housing sector has the aspirational aim to get its stock to EPC C by 2030, taken from the Clean Growth Strategy and picked up in the Heat and Buildings Strategy. It is an aspiration that the sector takes very seriously
The private rented sector 'EPC C by 2030' consultation issued on 7 February 2025 said energy efficiency standards would be introduced to the social rented sector in England as part of a review of the Decent Homes Standard. It indicated the long-awaited consultation on the updated Standard would take place in Spring 2025.
Next steps
Please get in touch with one of our key contacts or your usual AG Social, Sustainable and Green Finance team contact if you would like to discuss.
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