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Government panned for missing out landlords in new EPC enforcement

The government has been slammed for missing out landlords in proposals to enforce new energy efficiency regulations.

Propertymark - the trade group representing letting agents - has given its formal response to a consultation triggered by the government about the Energy Performance of Privately Rented Homes in England and Wales measure. 

This would require all new tenancies from April 2025 and all existing tenancies from April 2028 to meet band C or higher on an Energy Performance Certificate.


One of the ways the government wants this to be enforced is through portals such as Rightmove and Zoopla, which the government says should not list properties failing to meet the EPC standards. 

But Propertymark says one big loophole is that private landlords cannot advertise directly on property portals. Propertymark goes on to say in its response: “So based on the consultation document which states that around 43 per cent of landlords use a letting agent to either let or let and manage a property for them, this means the UK government is focusing a large proportion of it is future enforcement activity and compliance on less than half of the sector.”

Propertymark is also critical of another aspect of the government’s enforcement strategy for the new EPC requirements - relying on hard-pressed local councils.

“We do not believe that local authorities have the capacity required to enforce standards in the private rented sector. There are not enough resources and enforcement is not a high enough priority for councils. To this end, the proposed introduction of a private rental sector property compliance and exemptions database should not be implemented at the expense of local authorities prioritising enforcement” it says. 

Other concerns raised buy Propertymark revolve around these issues: 


Are The Proposals Achievable? Propertymark says: “The target is unrealistic and it is impractical to improve many properties based on the construction type and age. For instance, Wales has the oldest private rented dwelling stock in the UK, with 43 per cent built before 1919. Furthermore, too large a proportion of existing privately rented stock requires significant improvements to meet the C rating, which would reduce the amount of housing stock available to rent.”

Too Much Too Quick? The organisation tells government: “For the private rented sector in England and Wales, it is only a year since rules came into force to ensure all private rented tenancies meet EPC Band E, but the UK government has now proposed going to Band C within five years.”

Better Incentives Required: “Under the Green Homes Grant scheme, the UK government funds up to two-thirds of the cost of home improvements up to £5,000. However, landlords must redeem the voucher and ensure improvements are completed by 31 March 2022. Furthermore, the scheme is only applicable to landlords in England and not Wales. The UK government must provide better funding options for the private rented sector.”

The Covid Effect: Propertymark says two long-term effects may make even existing agreed deadlines difficult: “Firstly, landlords will continue to be impacted financially with extreme COVID-19 related arrears still yet to be recovered. Secondly, difficulty for the sector to comply with new and existing legislation, which includes access to the property to carry out maintenance work, renovation, checks or make energy efficiency improvements.”

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  • George Dawes

    The whole EPC things is ridiculous and pointless

    I've never had a tenant ask about it ever , most have never heard of it or care


    Agreed. Many stay on standard energy tariffs so energy costs seem irrelevant to them.


    EPC isn't about reducing energy bills or because tenants might ask about this. It's about the climate emergency and global warming. But it's the wrong way of dealing with this. It makes no sense for tenanted properties to require EPC but not owner-occupied properties. There has to be a much better way of dealing with the emergency in terms of properties. Taking no action at all is not an option in the climate emergency. So any ideas please?


    David Wirth. Climate emergency? You are funny some times 🤣



    I don't doubt we're experiencing global warming but I do doubt that the green lobby's schemes will successfully impact it.

    Targeting rental properties and not other properties, promoting green grants, demonising all diesel engines and nuclear energy etc. won't help at all.

    It's yet another cynical attack on private landlords who own a small minority of energy consuming properties.

    The only way to achieve change is by market forces, so if they're serious they need to put everyone potentially into fuel poverty so the cost benefit analysis drives us to be more efficient in our consumption and choices of energy and energy saving schemes.

    I would then install new gas boilers, fit new radiators and insulate behind them and in the loft etc. but I wouldn't buy electric heating, heat pumps or an electric car. I get around 60 mpg from a Euro 6 diesel 4×4 which has a permit to drive into the centre of Paris and other French cities as France accepts its pollution levels beat most petrol cars. France also understands the benefits of Nuclear Power, unlike the green lobby.

    For those who couldn't afford to change things, they would simply have to change their levels of consumption, which also helps to achieve the same aims as expensive actions to improve a highly subjective epic rating.

    No doubt the lefties will complain that the poor have a right to poison us all and shouldn't be priced out from doing so!


    Agreeing with David again on the fact no obligation for Owner Occupiers to do this. If everyone was targeted at say D much more realistic & achievable

  • Andrew McCausland

    I am wholeheartedly behind the Zero Carbon 2050 target and improving home insulation is a big part of this. However, there are a number of problems associated with the EPR C 2025 plan:

    1. The governments own estimate is that it will cost an average of £4,700 PER RENTAL PROPERTY to achieve the target in England. This means that the true cost for owners of older housing stock will be much higher.

    2. The green homes grant only runs until March 2022 under the current plan. This is simply not enough time for owners to get the works done in normal times.

    3. These are not normal times. LL's rental income has been hit by the effects of Covid and government has made no efforts to support LL, either via rent support or by allowing evictions.

    4. There are simply not enough retrofit insulation fitters able to carry out the works needed to hit the 2025 target - that is the 2025 target, never mind the GHG March 2022 target for financial support.

    I never liked harping from the side lines, slagging off ideas without offering alternatives. I believe the ambition is a great one, but I would suggest a few changes to the existing plans:

    a. Extend the green homes grant timescale to 2025 now. This will encourage more fitters to get involved, knowing there is longer term work available.

    b. Make the GHG process much simpler for the fitters and make sure they get paid quicker. You don't have to change the requirements for them to be Trustmark registered and PAS2030 qualified - just improve the back office function as it is far too slow at the moment.

    c. Either increase the funding available to LL (and homeowners) to complete insulation works or create a tax incentive to get the work done.

    d. Change adult education training to include retrofit insulation qualifications within the scope of funded courses. This will allow more fitters to enter the industry, create jobs and progress the roll out of energy saving measures at a faster pace. It will also introduce more competition into the industry, offering more choice and drive down prices for consumers.


    nutter alert

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    The green homes deal was a complete non starter, getting Victorian terraced houses up to band C just isn't going to happen, I've got one that is still just an F, as it would cost around £14k to get it up to an E I've got an exemption on it, so what's going to happen when we get this minimum C come into force, are all these properties going to get exemptions also, are we just going to carry on and rent them illegally, do we tidy them up and sell them to home owners, or do we get the demolition boys in and build ugly new rabbit hutches in their place.

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    I fully agree with the points in the article as in- too much too soon, the ability to shift old housing stock into a C from a D from an E takes very expensive measures such as solar pv, external or internal wall insulation etc costing multi £1000s per property (I've done some already and it ain't cheap!) Also agree- too much too soon when had hell on earth safely accessing properties over the last year for EICR requirements with covid- nightmare that isn't over yet with this 2nd massive covid peak. The funding for grants for energy performance measures is a joke and so far applications I put in in September haven't been 'vouchered' by the government yet.

    By the way have we forgotten about the white paper to outlaw gas boilers for heating by 2033? Thats a massive corker and needs to be factored in the epc planning now before taking any measures (landlords will need deep pockets!). So clarification on the whole package 'holistically' is necessary not a 'bit at a time' approach.

    In regard to the above comments I have found the same- in 28 years of landlording with 38 properties since the epc scheme came in (2007ish?) an epc has never been an issue asked for or raised by a tenant.

    However that still doesn't alter the fact we have to stop pumping megatons of carbon dioxide into the atmosphere for climate change and environmental reasons nothing to do with benefitting tenants heating costs. We have signed up to the Paris agreement which obligates us too.

    What we need is breathing space and a sensible timescale with proper assistance- like it or not these measures are necessary and at some point soon will go forward regardless of the arguments surrounding 'tenants don't care.' Sorry but thats the harsh reality


    another nutter alert--co2 is a trace gas mostly from eg volcanos--and co2 is essential for life. positive feedback system

  • Matthew Payne

    David is right EPCs are nothing to do with tenants, its all about our conmmitments on GHGs at Kyoto, Doha, Paris, and 40% of our emmisisons in the cold UK come from heating drafty Victorian property. We are in a massive rush politically and ecologically to become carbon neutral, hence banning petrol cars etc. We only have about 30 years, hence they are rushing the EER C rating forward.

    The trigger for an EPC requirement is not rented or owner occupied, it is marketing in advance of a proposed property transaction whether to sell or to let. The only properties that wont have an EPC at all will be the ones that have never been to the sales or lettings market since 2008. The Q perhaps, why hasnt the government given a deadline for owner occupied properties to get an EPC even if they havent been to the sales market? The same could be said for second homes I suppose that have never been let.


    Too many votes to lose in forcing all owner occupiers to do this, and the outcry would expose epc ratings for the sham they actually are.

    Better to screw private landlords who have no allies in government and tenants who don't even realise they're being screwed and will pay in the long run.

    I wonder how much the insulation companies have donated to get such schemes promoted and avoid prosecution for the Grenfell Tower deaths?


    no committments--just old pals acts

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    Hell I have just refurbished my personal property and the best that could achieve was a D , uplifted from F and that cost thousands. No tenants will live in better standard houses than home owners.
    The green grant is of no use as it’s in two sections, heat pumps are not the best thing since sliced bread, they are expensive to operate and install. Because I have good quality new boilers I can’t access the scheme, two off my properties would benefit from new UPVC double glazing but I can’t access that via the green scheme. It’s a joke.

  • George Dawes

    Climate emergency ? Man made ? Lol

    SMH .

    Google sun flares , methane from cows backsides , under the sea volcanoes etc , the real natural contributors to so called global warming..Some people are so gullible it’s hilarious . Warming and cooling of the earth are naturally occurring cycles . This twaddle is just another excuse for a tax . Nothing more nothing less.

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    Supposing they find anything wrong with polyurethane foam Insulation, they'll have to pull the whole place apart, its everywhere and stinks when it burns. I don't know how we managed before Central Heating & Insulation, they are now like hatching hens and I don't like to say it but it took the virus to get them to open the windows.


    I agree. When I was young we wore vests, shirts and jumpers inside in winter and only heated the living room. Current youngsters dress as if they're in the tropics but have every room at 23C all day long.

    Put 20% VAT on fuel and 0 on woolly jumpers and reduce energy consumption overnight. Ban wives from touching the thermostat and halve energy consumption until husband is dead.

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    What happens to an existing tenancy when the works required are highly disruptive (assuming affordable)? Do we evict, or are we obliged to temporarily house a complete family elsewhere?

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    EPC, I haven't seen any saving yet, we have cavity wall insulation, double glazing, modern state of the art supposedly efficient condensing Boilers. However the Boilers are 3 times more expensive to purchase and install then more likely to break down. Fleets of plumbers Vans on the road every day in London trying to keep them going causing traffic & pollution themselves, never mind the call out and parts charges again & again. The old cast iron heat exchanger Boilers hardly broke down you might have to get the odd thermocouple maybe every 6/7 years and a child could put it in, now you need a specialist to take the cover off to have a look. They didn't have all those electronics to go wrong, printed circuit boards, flow switches, sensors etc, in fact I know a guy who has an old one 50 years still going, so no cost saving really a lot of break downs and time wasting. The Boiler is now a LL's nightmare, if its a fridge, freezer cooker, washing etc no problem you can usually have it delivered next day and panic over, in my case its picked up & in same day, some progress.


    I have 2 boilers dating back to the mid 90s, still going strong, then there are the ones that I'm replacing at 7 yrs old.

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    I have started a petition onEPCs to help bring to the Govts attention the unfairness of the EPC assessment - if you agree with me please sign. I can't post the link on the website but if you google Govt petitions 559700 it should pop up under the title 'Overhaul current, flawed EPCs so that they are fair, accurate & relevant'.

    Daniela Provvedi

    Done Tricia, I was signature number 27, it's going up slowly.


    Signed as well


    Petition signed.

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    • 23 January 2021 10:09 AM



    Likewise although I was only signature number 25!

    • 23 January 2021 15:04 PM

    Gotta start somewhere.......

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    Yes Robert, now mine = Number 26, it didn't go very well took a dozen attempts, it wouldn't accept my email address as valid, so they are saying I don't know my email address if this is website set up don't expect many signatures. I think technology is a big problem for us or me in particular, it took over our businesses and our lives now used to destroy us. Billion's of £ paid by us to providers, trillions of hours unpaid time spent by us on computers day & night and we wouldn't have all those nonsense Regulations without Computers Council staff or Government Departments would not attempt it if pressing a few buttons didn't do it. However we were able to do everything before for 40 years. They went to University to learn Computers & how to change the format to prevent us from operating, seem a terrible waste of educations, as the next Generation will find out when we are not there and no one able to do actual work & we are not there to live off. working from home is Computers and don't cut it. Now they have another brain wave give everyone that tests positive to virus £500. to stay at home but they are already at home anyway.


    It would be so funny to watch the snowflakes when they get to retirement age.

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    no mmgw

    co2=essential to life

    its a scam to make money

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    Well I suppose trees breathe in carbon dioxide and convert it to oxygen especially when they are leafy so it must be good for them ?.

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    Tricia, thank you for making the effort for setting up Petition about EPC, unfortunately as usual lazy ungrateful LL's sit on their hands and do nothing that's 2.2m of us excluding Wales, Scotland or NI, and expect everything to just fall into their lap, you should have 100k by now.. The last time I looked only 27 persons signed up that's Shameful I don't know why we bother. It was same way when we were campaigning for S21 to be brought-in, vast majority sat back waiting to see what concessions of right we might achieve then happily avail of any advantage it might be to them. Same goes for LL Associations we complain they don't do enough for us but with only 80k members between the 2 biggest ones what can we expect. So if 2.6m LL's in UK paid £5 pa each it would be £13m double what they get now, (at a guess of £75 / £80. per member for 80k members), but currently only 80k LL's to carry the other 2'500'000 LL's that are prepared to do nothing or contribute to anything only sit there let someone else do it.


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