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Last edited 13 Feb 2025

Brief notes on proposed changes to EPB framework

1 NCM and HEM as context
2 Consultation, and key changes
3 What could be measured
4 When are certificates required?
5 Data
6 Quality and enforcement
7 Air conditioning inspection reports
8 Related articles on Designing Buildings
9 External Links

[edit] NCM and HEM as context

The Standard Assessment Procedure (SAP) first published in 1993, is the accepted National Calculation Methodology (NCM) for assessing the energy performance of dwellings, demonstrating they comply with Part L of the Building Regulations and to produce an Energy Performance Certificate (EPC). The Reduced data SAP (RdSAP) was introduced in 2005, a simpler lower cost version used to assess the energy performance of existing homes and produce an EPCs.

The Simplified Building Energy Model (SBEM), available since since 2006, is the accepted National Calculation Methodology (NCM) for assessing the energy performance of buildings other than dwellings. It is used to demonstrate compliance with Part L of the Building Regulations and for producing Energy Performance Certificates.

As EPCs are based on a modelled energy use, so require complex models to estimate performance hence the need for the current SAP version 10.2, RdSAP 10 and SBEM 6.2. Display Energy Certificates (DECs) look very similar to EPCs but are a record of the actual energy use ogf a building in the previous year, represented as a chart (visually similar to an EPC but very different in content)

The Minimum Energy Éfficiency Standard (MEES), introduced in March 2015 by the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 uses EPC gradings to estimate performance of the existing residential and non residential building stock in the private rental sector and help deliver carbon reduction targets for 2020 and 2050..

In 2021, a consortium of experts led by the BRE were appointed to carry out a multi-year project to develop a replacement for the Standard Assessment Procedure (SAP). In 2023 the consultation on the Home Energy Model: Future Homes Standard assessment was published as the new methodology to be used to demonstrate new dwellings comply with the Future Homes Standard. The Home Energy Model (HEM) intended to be the primary tool used to demonstrate compliance during the building design and planning stages of a home, replacing SAP and RdSAP, and used as the basis for calculating EPCs for new buildings as well as existing buildings later by 2026.

In 2025 the labour government, continues support for existing approaches to revising methodologies, in its consultation 'Reforms to the Energy Performance of Buildings regime' saying that it 'expects that new and/or amended metrics will be introduced for domestic buildings with the Home Energy Model (rather than updates to SAP/RdSAP). An EPC methodology for the Home Energy Model is currently under development and will be consulted on in 2025. Any changes to the metrics for non-domestic buildings will be implemented through updates to the National Calculation Methodology for non-domestic buildings.'

Also in 2025 MHCLG published short guidance 'Energy calculation as a service (ECaaS): Access the Home Energy Model' which provides an API to the Home Energy Model so that users can produce software, and a basic frontend to validate building designs. It is a methodology for predicting the energy performance of buildings, for various future statutory purposes including, but not limited to, calculating compliance with the Future Homes Standard (FHS). The guidance states that 'the service will become the only valid means to confirm compliance with Part L of the Building Regulations when referring to the Future Homes Standard. For other users, the underlying software libraries are open source and can be used to conduct calculations for non-statutory purposes.'

[edit] Consultation, and key changes

In December 2024 the UK government published a consultation seeking views on the reform of the Energy Performance of Buildings (EPB) framework, for England and Wales (Scotland and now Northern Ireland being devolved matters). The consultation is published by MHCLG and DESNZ and closes 26 February 2025, which covers:

Improving regulations, applicability, quality, and data usage of domestic and non-domestic buildings
updating EPC metrics and refining requirements for both EPCs and DECs
improving data management protocols and strengthening quality control
revising air conditioning inspection reports (ACIRs)

Some key changes being considered include:

Headline EPC metrics to cover fabric efficiency, heating system, readiness to smart tech and energy cost with others metrics secondary. DECs remain as are with a carbon focus, perhaps with other metrics added later. Possible future EPC metrics; climate resilience, health and wellbeing, biodiversity, water efficiency.
Changing EPC requirement from 10 to anything as low a every 2 years. DEC from 10 to 7 years (250-1,000m²) and from 7 to 5 years (1,000m (recommendation report).
Requirement for private landlords to keep EPC renewed even under same tenancy. For HMOs to require EPCs and EPC requirements for short-term rental properties.
Whilst existing exemptions under Minimum Energy Efficiency Standards for historic buildings will remain, the EPC requirements will also extend to historic buildings.

Responses can be submitted by completing an online survey on Citizen Space. Below is a brief summary of the consultation, for further details visit the consultation site here.

[edit] What could be measured

For domestic properties the Energy Efficiency Rating (EER) is currently the headline metric, calculated using modelled energy costs per m2 based on standardised heating patterns, temperatures, and fixed fuel price assumptions. For non-domestic certificates the Environmental Impact Rating (EIR) is the headline metric, using modelled carbon dioxide emissions per m2. The consultation acknowledges flaws in EER and EIR, including fuel costs and carbon factors.

The consultation proposes the use of multiple metrics for EPCs, with a focus on the first four listed below:

Fabric performance: assess thermal performance of the envelope, for well-insulated, energy-efficient spaces.
Heating system: info on efficiency and environmental impact of heating source and adopting of cleaner tech.
Energy cost: understanding implications of energy efficiency, making informed decisions about improvements.
Smart readiness: assessing potential to integrate smart tech, optimising consumption and smart tariffs.

With the second four metrics being provided as secondary information.

Carbon: an estimate of the carbon emissions arising from the energy used in the building.
Energy use: insights into overall energy consumption and identifying areas for energy efficiency improvements
Heating system: info on efficiency and environmental impact of heating source and adopting of cleaner tech.
Smart readiness: assessing potential to integrate smart tech, optimising consumption and smart tariffs.

In the future other metrics may also be considered such as a building’s resilience to climate change impacts and its adaptation measures. Additionally, metrics concerning occupant health, wellbeing, biodiversity, and water efficiency could be evaluated. The data shown on EPCs could be incorporated with actual energy use data which could provide feedback to occupants on how their behaviour is influencing their energy consumption, as well as highlighting any discrepancies between the predicted performance and actual performance.

Whilst for non-domestic Display Energy Certificates (DECs) the headline Environmental Impact Rating (EIR) metric, using modelled carbon dioxide emissions per m2 is considered to be appropriate. The consultation asks questions regarding the above EPC metrics separately for domestic and for non-domestic buildings.

[edit] When are certificates required?

[edit] Reducing the validity periods for EPCs and DECs

Current validity periods for EPCs are 10 years, renewal only required when a property is built, sold, or leased, so many are EPCs outdated. the consultation asks what should be proposed as a shorter validity period: Less than 2, 2, 5, 7 or 10 years. Suggesting this would provide more accurate, up-to-date data on building energy efficiency, benefiting buyers, tenants, and policymakers. The change would mostly impact private rented sector landlords, it could enhance property desirability and compliance with regulations. The government favours keeping existing EPCs valid until expiration while applying any new validity period to future EPCs, ensuring a smoother transition with minimal disruption.

Currently, public buildings with a floor area over 250m² must have a DEC and recommendation report. For buildings up to 1,000m², the DEC is valid for 10 years, while for those larger than 1,000m², the DEC is valid for one year and the report for 7 years. The proposal is to reduce validity periods of DECs and DEC recommendation reports. For buildings between 250-1,000m², from 10 years to 7 years, and for buildings over 1,000m², from 7 years to 5 years.

[edit] Tenancy period EPCs

The government aims to upgrade five million homes and reduce fuel poverty by 2030. Currently, in both private and social rental sectors, a new EPC is only required when re-letting, not when tenants renew leases. This results in many properties lacking valid EPCs, especially in the Social Rented Sector, where tenancy lengths often exceed the EPC’s 10-year validity. Requiring an EPC at expiry would provide up-to-date information, improve compliance with regulations like MEES, and help landlords maintain property desirability. The government proposes making EPC renewal mandatory upon expiration in the private rental sector to enhance energy efficiency and enforcement.

[edit] Sale or rent

The government proposes amending regulations to require an EPC before marketing a property for sale or rent, removing the current 28-day allowance. As the EPC market is now reliable, this change would ensure buyers and renters have essential energy information upfront, improving transparency and making enforcement clearer and more effective.

[edit] Houses in multiple occupation

The government proposes requiring a valid EPC for an entire HMO when renting a single room, aligning it with other private rental properties under MEES regulations. This change would improve transparency, ensure compliance, and provide tenants with clearer energy efficiency information. A 24-month transition period would allow landlords time to obtain EPCs and meet MEES requirements. The move aims to lower fuel costs, enhance tenant comfort, and protect vulnerable residents. If EPC validity throughout tenancy is mandated, HMOs would require one from the first to the final letting, ensuring ongoing compliance and informed decision-making for tenants.

[edit] Short-term rental properties

The government proposes requiring a valid EPC for all short-term rental properties at the point of letting, regardless of who pays energy costs. This updates current guidance, aligning EPC rules with DCMS’s definition under the Levelling Up and Regeneration Act 2023. The change aims to improve transparency and energy efficiency compliance.

[edit] Heritage buildings

The government proposes requiring all heritage buildings to have an EPC to provide owners with energy performance recommendations while preserving their architectural integrity. While current regulations exempt heritage buildings from certain energy requirements if they would alter the building’s character, this change aims to ensure energy efficiency without compromising historical value. EPC recommendations will be tailored to heritage properties, with guidance to avoid inappropriate measures. Existing exemptions under Minimum Energy Efficiency Standards (MEES) will remain, and the government plans to consult on planning policies and listed building consents to support energy improvements. Industry groups will help refine the approach for these buildings.

[edit] DEC requirements and validity periods

The government is assessing the effectiveness of Display Energy Certificates (DECs) in raising public awareness of energy usage in public authority buildings. Currently, public buildings with a floor area over 250m² must have a DEC and recommendation report. For buildings up to 1,000m², the DEC is valid for 10 years, while for those larger than 1,000m², the DEC is valid for one year and the report for 7 years. The government is seeking feedback on how DECs have influenced energy performance improvements and is considering whether alternative approaches could be more effective in encouraging energy efficiency in these buildings.

The government proposes reducing the validity periods of Display Energy Certificates (DECs) and DEC recommendation reports. For buildings between 250-1,000m², the DEC validity would be reduced from 10 years to 7 years, and for buildings over 1,000m², the validity of DEC recommendation reports would be reduced from 7 years to 5 years. Feedback is being sought on appropriate validity periods for these certificates and reports.

[edit] Data

The data collected during EPC, DEC, and ACIR assessments is stored on the EPB Register for at least 20 years. While this growing resource could support net-zero targets, current data collection rules and processes lead to outdated information, limiting its ability to effectively drive carbon reduction efforts in buildings.

[edit] Cancelled or not for issue certificates

The government proposes removing cancelled or not-for-issue certificates from the EPB Register after two years, addressing the contradiction with the Technology Code of Practice (TCoP), which advises retaining data only as long as necessary. This change would align the Register with TCoP, reduce operational costs, and lessen carbon impact while allowing schemes to conduct audits using separate records.

[edit] Removing opt-out from the EPB regulations

The government proposes removing the option for building owners to opt-out their EPCs from public access on the EPB Register. Currently, opted-out certificates are excluded from the public address search but can still be accessed using Report Reference Numbers, which contradicts the opt-out concept. This limits prospective buyers, tenants, and enforcement bodies from accessing essential energy performance data, potentially hindering access to government schemes. While owners could still opt-out of bulk data releases through Open Data Communities, EPCs would remain available for government purposes and statistical releases in anonymised form. The change aims to improve transparency and access to relevant energy information.

[edit] Data sharing

The government proposes removing the general prohibition on sharing EPB Register data to allow broader use of the dataset, which includes over 27 million energy assessments. Currently, data is limited in scope, updated monthly, and not suitable for in-depth research. Allowing the Secretary of State discretion to share data, while complying with data protection rules, would enhance the utility of the dataset to inform policies, support enforcement, and encourage energy performance improvements. The move aims to promote research, drive energy efficiency uptake, and facilitate the use of data for a wider range of government initiatives.

[edit] Using existing data in EPC assessments

The government proposes allowing older data from previous assessments to be used for minor upgrades in energy efficiency, such as loft insulation or smart thermostats, to reduce costs and administrative burdens. For newer buildings, EPCs are based on detailed design and specification data, while older buildings rely on non-invasive surveys and assumptions. However, to ensure accuracy, the reliability of pre-existing data is crucial, as minor changes over time can impact energy performance. A blended approach would use previous data for minor improvements while emphasizing reassessments for significant upgrades to balance practicality with accuracy.

[edit] Quality and enforcement

[edit] Context

The government is working to improve trust in the accuracy and reliability of EPCs to enhance their effectiveness in reducing carbon emissions. This includes replacing the Standard Assessment Procedure (SAP) with the Home Energy Model (HEM), collaborating with Accreditation Schemes to address poor assessor performance, and strengthening training and skill requirements. The consultation seeks feedback on further measures to improve EPC quality, ensuring trustworthiness, reliability, and accuracy.

[edit] Energy assessor training, standards and accreditation

60% of Call for Evidence respondents believed variations in EPC ratings were due to assessors incorrectly inputting data, with 37% attributing this to insufficient assessor expertise. To address this, the government proposes giving Schemes more control over training, or even sole responsibility, to ensure higher standards. The quality of training will be scrutinized, and CPD will be enhanced to ensure assessors’ competence. Targeted training will focus on common assessment errors, with potential specialism courses, such as for heritage buildings, to improve accuracy. This aims to reduce EPC assessment errors and enhance data reliability on the EPB Register.

[edit] Assessor fraud

Inaccurate EPC assessments can result from fraud or manipulation, as EPC ratings influence government policies, funding, and penalties. This creates financial incentives for dishonest practices. MHCLG oversees policy, while Schemes manage quality assurance and fraud prevention. Schemes must audit 2% of lodgements annually and employ smart auditing to detect errors, using a risk-based approach to identify suspicious assessments. In cases of suspected fraud, Schemes are required to report findings to relevant authorities, ensuring safeguards are in place to protect the integrity of the EPC regime.

[edit] Improved EPC compliance and enforcement

Responses to the Call for Evidence highlight concerns about compliance with EPB Regulation requirements. Low compliance may result from viewing the requirements as a mere formality, limited awareness (especially for non-domestic properties and ACIRs), or deliberate non-compliance due to weak penalties. Data suggests 95% compliance for owner-occupiers, but lower rates for non-domestic lettings (53%) and DECs (83%). Compliance in the private rented sector (PRS) has improved due to the Minimum Energy Efficiency Standards (MEES), with 94% of PRS properties now meeting Band E or higher, though this estimate depends on the availability of EPC data.

To improve compliance with EPB regulations, a differentiated approach by sector is proposed. This includes:

Collaborating with Local Weights and Measures Authorities (LWMAs) to improve guidance for enforcement and relevant parties.

[edit] Enhancing LWMAs' access to EPB data to support enforcement activities.

Working with estate and letting agents to promote the benefits of EPCs and encourage compliance. Estate agents will also be required to ensure an EPC is commissioned before marketing a property, improving overall compliance.

80% of respondents in the Call for Evidence believed EPC enforcement is minimal, citing resource and commitment issues in Local Weights and Measures Authorities (LWMAs). Enforcement responsibility for EPCs lies with LWMAs and local authorities (LAs). However, low enforcement activity is due to resource limitations, low prioritisation, and difficulties monitoring compliance. Past funding for toolkits and studies highlighted issues with data access and suggested integrating MEES and EPC enforcement for better coordination.

[edit] Penalties

LWMAs can issue penalty charge notices for breaches of EPB Regulations, with fines currently set at £200 for domestic EPCs, 12.5% of the rateable value for non-domestic EPCs (with a minimum of £500 and maximum of £5,000), £1,000 for DECs, and £300 for ACIRs. These penalties haven't changed since 2007, and the government is considering raising them to reflect inflation. The government does not propose altering the percentage of rateable value for non-domestic EPC penalties but is considering adjustments to the minimum and maximum penalty amounts.

The government is considering extending the six-month timescale for issuing penalty charge notices, as stated in Regulation 36(2). The proposed change aligns with precedents set by other government policies, such as the Building Safety Act 2022, which allows a 12-month window for issuing compliance notices for building regulation breaches. Additionally, penalty notices under MEES regulations can be issued up to 18 months after a breach.

[edit] Enforcement authority responsibilities

The government is considering whether the current allocation of enforcement responsibility to Local Weights and Measures Authorities (LWMAs) is appropriate, given their broader consumer protection roles. The split enforcement between EPC (top-tier authority) and MEES (lower-tier authority) in two-tier areas can lead to coordination challenges. Although no immediate changes to formal enforcement responsibilities are proposed, the government is exploring ways to improve enforcement efficiency through delegation of functions, support from National Trading Standards, and potential joint working across authorities. The government welcomes views on the allocation of responsibilities and evidence supporting potential changes.