EPC and MEES Regulations: Landlord's Compliance Guide

Energy performance is regulated through two interlocking regimes: the Energy Performance Certificate (EPC) regime, which produces a standardised rating from A to G; and the Minimum Energy Efficiency Standard (MEES), which sets a minimum below which a property cannot lawfully be let. The current minimum is Band E; the target is Band C from 2028 for new tenancies and 2030 for all tenancies. Civil penalties up to £30,000 per breach are being introduced in line with other compliance regimes. This page covers the EPC, the MEES standard, the available exemptions, and the operational practice that produces consistent compliance through the rising-standard timetable.

Two regimes that work together

Energy performance is regulated through two interlocking regimes. The first is the Energy Performance Certificate regime — every property let or sold in England and Wales must have a current EPC produced by an accredited assessor. The second is the Minimum Energy Efficiency Standard (MEES), which sets a minimum EPC band below which a property cannot lawfully be let. EPCs alone are administrative; MEES gives them teeth.

A landlord operating in the private rented sector needs to understand both. The EPC tells you how the property performs; the MEES tells you whether you can lawfully let it at that performance level. Letting a sub-MEES property attracts civil penalties of up to £30,000, and the policy direction is unambiguous: standards are rising, the timetable is set, and properties that perform poorly today will be unlettable within a few years unless improved.

The Energy Performance Certificate

An EPC is a standardised assessment of a building’s energy performance. It rates the building from A (most efficient) to G (least efficient) and includes recommendations for improvement. EPCs were introduced in England and Wales by the Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations 2007, implementing the EU Energy Performance of Buildings Directive.

When an EPC is required

A current EPC is required:

• Whenever a property is sold.
• Whenever a property is let on a new tenancy.
• Whenever a building is constructed.
• Whenever a building undergoes a significant change.

The EPC must be available to the prospective buyer or tenant from the point the property is marketed. For lettings, the EPC must be provided to the tenant before the tenancy starts — best practice is to include it in the pre-tenancy paperwork pack alongside the How to Rent guide and (now) the Government Information Sheet.

How EPCs are produced

An accredited Domestic Energy Assessor (DEA) inspects the property and enters details about its construction, glazing, heating, hot water, ventilation, and lighting into government-approved software (RdSAP — Reduced data Standard Assessment Procedure). The software produces the rating and recommendations. The assessor lodges the EPC on the central register and provides a copy to the client.

Cost is typically £50-£120 for a residential EPC. The assessment takes 30-60 minutes for a typical property.

How long an EPC lasts

EPCs are valid for 10 years from the date of issue. A property let in 2018 with a 2018 EPC needs a new EPC by 2028. The 10-year period applies regardless of whether the property is let, vacant, or sold during that time.

A new EPC can be commissioned at any time — typically when:

• The current EPC is approaching expiry.
• Improvements have been made and the landlord wants to update the rating (particularly relevant where MEES compliance is at issue).
• A new tenancy is being granted and the existing EPC is over 10 years old.
• A previous EPC was carried out before significant changes (extensions, replacement boiler, insulation upgrades) that would now produce a higher rating.

What the EPC contains

A current-format EPC includes:

• The energy efficiency rating — A to G band and a numerical score (1-100+).
• The environmental impact rating — separate A-G band reflecting CO2 emissions.
• Estimated annual energy use — typical heating, hot water, and lighting costs.
• Recommended improvements — actions that would improve the rating, with estimated costs and savings.
• Property details — floor area, construction, heating system.
• Assessor details — name, accreditation, and contact information.

The recommendations are advisory but increasingly relevant: the MEES regime requires landlords to make improvements where the property is below the minimum standard. EPC recommendations identify the lowest-cost route to compliance.

The Minimum Energy Efficiency Standard (MEES)

MEES was introduced by the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 and became active for new tenancies on 1 April 2018. Since 1 April 2020, MEES has applied to all tenancies, not just new ones.

The current standard

The current MEES requires every privately-rented residential property in England and Wales to have an EPC rating of E or above. Letting a property below E is unlawful, subject to limited exemptions discussed below.

In practice, the E threshold catches a relatively small number of properties — most of the very poorest stock has either been improved or sold to owner-occupiers since the regime began. The target now is rated F and G properties, which were historically common in older terraced housing, period conversions, and rural lettings without mains gas.

The rising-to-C timetable

The government has committed to raising the MEES threshold to Band C. The original timetable proposed:

• Band C for all new tenancies from 2025.
• Band C for all tenancies from 2028.

That timetable has been revised. The current position (subject to further consultation) is:

• Band C for new tenancies from 2028.
• Band C for all tenancies from 2030.

The dates have slipped before and may slip again. But the policy direction is settled — Band C is the destination, not the maximum. Some commentators expect a further tightening to Band B by the mid-2030s, though no formal commitment has been made.

A landlord planning capital expenditure on a property today should aim for Band C as a minimum. Improvements made now to reach Band C protect the property’s lettability through 2028, 2030, and beyond. Improvements that only reach Band E will need further investment within a few years.

What “Band C” actually means

The numerical ranges:

• Band A: 92-100+
• Band B: 81-91
• Band C: 69-80
• Band D: 55-68
• Band E: 39-54
• Band F: 21-38
• Band G: 1-20

A property at Band E (say, a score of 50) needs to reach 69 to achieve Band C — an improvement of 19 points. The cost of that improvement varies enormously depending on the property’s starting position. Common improvements and their typical impact:

• Loft insulation (top up to 270mm): 5-10 points.
• Cavity wall insulation: 10-15 points.
• Boiler upgrade (modern condensing): 5-10 points.
• Double or triple glazing throughout: 5-15 points.
• Solid wall insulation (internal or external): 15-30 points.
• Solar PV installation: 10-20 points.
• Air source heat pump: 5-15 points (depending on starting position).

A typical 1930s semi-detached house at Band E might reach Band C with cavity wall insulation, loft insulation top-up, a new boiler, and double glazing — total cost £8,000-£15,000 depending on property and existing condition.

A 1960s solid-wall property at Band F faces a more substantial challenge — typically £20,000-£40,000 of works to reach Band C, including external or internal wall insulation that may compromise the property’s appearance or floorspace.

Exemptions from MEES

A small number of exemptions allow a sub-MEES property to be let lawfully. Each exemption must be registered on the central PRS Exemptions Register before it can be relied on:

All relevant improvements made

The most common exemption: the landlord has made all “relevant” improvements that can be made within the cost cap. The cost cap is currently £3,500 (including VAT) for the entire property. Where the EPC recommendations require improvements totalling more than £3,500, the landlord must do the improvements that fit within the cap and can then register the exemption for the rest.

Important: the £3,500 cap is being raised — the government has consulted on raising it to £10,000 in line with the Band C target. Landlords who registered exemptions under the £3,500 cap will need to revisit them when the new cap takes effect.

Wall insulation exemption

Where the only available improvement is solid wall insulation, and where a qualified expert (typically an architect, surveyor, or insulation specialist) has confirmed that the insulation would damage the property or its surroundings, the landlord can register an exemption.

Third-party consent exemption

Where improvements require consent from a third party (a freeholder, a planning authority, a tenant) and that consent has been refused or made conditional on terms the landlord cannot reasonably accept, an exemption is available.

Devaluation exemption

Where a chartered surveyor has reported that improvements would reduce the property’s market value by more than 5%, an exemption is available.

New landlord exemption

A landlord who has only recently acquired a property has 6 months to register an exemption while they bring the property up to standard. This is a temporary protection rather than a permanent exemption.

Exemption registration

Every exemption must be registered on the PRS Exemptions Register before the property is let. Unregistered exemptions are not valid; a landlord relying on an unregistered “exemption” is non-compliant.

Exemptions last 5 years and must be renewed if the underlying circumstances continue. They are property-specific — selling the property does not transfer the exemption.

Penalties for breach

Local authorities enforce MEES through civil penalties:

• Letting a sub-standard property for less than 3 months: up to £2,000 per breach.
• Letting a sub-standard property for 3+ months: up to £4,000 per breach.
• Failing to comply with a compliance notice: up to £2,000 per breach.
• Providing false or misleading information: up to £1,000.
• Maximum penalty per property in a single round: £5,000 (under current rules — being raised to £30,000 in line with other compliance penalties).

In addition to the financial penalty, the local authority can publish details of the breach on the publicly-accessible PRS Exemptions Register — naming and shaming landlords with persistent compliance failures.

Operational best practice

A landlord operating professionally on energy performance:

1. Knows the EPC band of every property. Maintains a portfolio-wide log including current EPC band, EPC expiry date, and any planned or required improvements.

2. Aims for Band C or better in any new property acquisition. Avoid acquiring sub-MEES properties without a clear improvement plan and budget.

3. Programmes improvements during voids. The cheapest time to do energy efficiency works is between tenancies — the property is empty, no disruption to tenants, and contractors can work freely.

4. Updates the EPC after improvements. Improvements only count for MEES compliance once a new EPC has been issued reflecting them. Don’t do the works and forget the new EPC.

5. Registers exemptions properly. Where an exemption is genuinely available, register it on the PRS Exemptions Register before the property is let. Unregistered exemptions are worthless.

6. Plans for the rising standard. The Band C target for 2028/2030 is the planning horizon. Capital expenditure today should aim at Band C. Properties reachable to Band C with reasonable expenditure are worth keeping; properties that cannot reach Band C without uneconomic expenditure may be candidates for sale.

Authoritative sources

• Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 — the MEES regime.
• Find an EPC (gov.uk) — central EPC register.
• PRS Exemptions Register — exemption registration.
• Government MEES landlord guidance.