January 2026 EPC Reform Update – What You Need to Know
Overview
On 21st January 2026, the Government published a partial response to its consultation on reforms to the Energy Performance of Buildings (EPB) regime. While this does not introduce immediate legal change, it confirms the direction of travel for EPC reform and provides important reassurance for non-domestic property owners.
Final regulations will follow further consultation and parliamentary approval, with the aim being to tie it in delivery with Scotland’s changes in October.
Non-Domestic EPCs: Key Outcomes
EPC Validity
EPCs remain valid for 10 years.
The Government has not changed the existing validity period in this response.
Headline Metric
Carbon emissions will remain the primary metric for non-domestic EPCs.
This provides continuity for commercial landlords, investors and managing agents.
When EPCs Are Required
The Government is signalling a move towards EPCs being required earlier in the transaction process, prior to commencement of marketing.
This is intended to ensure EPC information is available when decisions are being made.
The government are working to refine the position on requiring a new EPC when an existing one expires for all private rented buildings, to ensure the policy has its intended effect of ensuring the EPC and MEES regulations “interact effectively to place the right requirements on landlords without incurring undue burdens”.
Scope and Clarifications
Greater clarity planned for:
HMOs (whole-building EPCs where rooms are let individually)
Short-term and serviced accommodation
Heritage and listed buildings, with exemptions under review
Non-Domestic EPCs: At a Glance
10-year EPC validity unchanged
Carbon metric retained
Updated regulations for tighter rules on EPCs at marketing
Domestic EPCs: A Brief Summary
Domestic EPCs are expected to change more substantially than non-domestic ones.
Key Changes
Move to a multi-metric EPC by October 2026, with main metrics including:
Fabric performance
Heating system efficiency
Energy costs
Smart readiness
Secondary metrics of Energy Demand and Carbon will also be reported, along with (for a time) the existing EER rating of A-G.
Replacement of SAP with the Home Energy Model
Greater focus on retrofit planning and long-term performance
Domestic MEES Consultation response – Key Points
The Government has also published its response to the Improving the Energy Performance of Privately Rented Sector (PRS) Homes consultation.
Main Proposals
Minimum standard broadly equivalent to EPC C, but using the new metrics
Single compliance deadline: 1 October 2030
Requirement to meet:
A fabric standard
Either heating system or smart readiness standards
Grandparenting Clause: Properties that achieve an EPC C rating against the existing Energy Efficiency Rating (EER) before 1 October 2029 will be considered compliant until that EPC expires or is replaced
Proposed cost cap of £10,000 (average cost is estimated at £5,400, and most third party funding will count towards the total)
10-year exemption where the cost cap is reached
Expanded consideration of exemptions for certain property types
Maximum fine £30,000 per breach
These proposals will be finalised alongside EPC reform, so the two policies should be considered together.
Full resources -
Reforms to the Energy Performance of Buildings regime – partial government response - GOV.UK.