EPC Requirements for Landlords: MEES and Exemptions

Privately rented property covered by the MEES Regulations must have a valid EPC rated band E or above, unless a valid exemption is registered. That has applied to all tenancies, not just new ones, since April 2020, and the maximum penalty is currently £5,000 per property in total.

Government has since set out an aim of band C by 2030, alongside a proposed £30,000 maximum penalty, with the enabling legislation aimed at 2027. None of that is law yet — but it is a reasonable planning horizon for landlords deciding what to do with a property currently sitting at D or E. For how the current position compares with what has been proposed, see our MEES timeline for landlords.

Current legal requirements at a glance

The obligation attaches to the act of letting, granting, renewing, or continuing a tenancy. A statutory periodic tenancy (rolling over after a fixed term) is treated as a continuation of the existing tenancy for MEES purposes.

Local authority enforcement in London has intensified since 2023. Tower Hamlets, Newham, Hackney, and Southwark have run active compliance campaigns. Enforcement details are published on a public database, reputational risk is real alongside the financial penalties.

Step 1, Know your portfolio's current ratings

Check the government EPC register (find-energy-certificate.service.gov.uk) for every property. Flags requiring immediate action:

• Rating F or G: The property cannot legally be let. If a tenancy is active, you are currently in breach.
• Expiring certificate: Renew before it expires, a valid in-date EPC is required to demonstrate compliance.
• No EPC on register: Commission an assessment before the next letting (common for pre-2008 properties).
• Rating D or lower: Worth planning improvements against the proposed band C aim for 2030.

We offer bulk assessment scheduling across all London boroughs. Contact us to discuss portfolio programmes.

Step 2, Understand your property types

Improvement costs and feasibility vary enormously by construction. Categorise your portfolio:

Cavity-wall properties (1920–1990)

Found across outer London, Ealing, Croydon, Bromley, Enfield, Barnet, Sutton, Havering, and Bexley. These are the easiest to improve:

• Cavity wall insulation, where the cavity is unfilled and suitable
• Topping up loft insulation
• LED lighting throughout

These are the cheaper measures, and generally the right order to do them in. What they are worth on a specific property is calculated from the whole dwelling, and appears on that property's EPC recommendation report.

• Total to reach C from D: typically £800–£2,000

Many qualify for ECO4 or GBIS funding, potentially free. Prioritise these now.

Victorian and Edwardian solid-wall properties (pre-1919)

The dominant type in inner London, Hackney, Islington, Lambeth, Wandsworth, Southwark, Tower Hamlets, Newham. These require more significant intervention:

• External wall insulation (EWI): £12,000–£18,000, highest impact, planning/conservation area check required
• Internal wall insulation: £8,000–£14,000, loses floor area
• Solar PV 3–4kWp: £5,000–£9,000, often the most cost-effective single route to C
• LED + loft + heating controls combined: may reach C from high D (SAP 65+) without wall works

Get your exact SAP score first. A Victorian terrace at D66 may reach C with LEDs and loft insulation. One at D55 almost certainly needs wall insulation or solar PV. Our assessment tells you this, with guide prices from £65.

Post-war flats and maisonettes (1945–1980)

Common in Tower Hamlets, Lambeth, Southwark, Newham, Hackney, and Brent. The heating system is often the critical factor:

• Electric storage heaters: typically D or E, the heating system is the main lever
• Communal gas heat network: often C already
• Individual gas boiler: usually D, achievable to C with insulation

For flats with storage heaters, replacing with a modern gas combi (if gas is available) or heat pump is the most impactful single measure. This may require building consent and freeholder involvement.

Step 3, Prioritise improvements strategically

Priority order:

1. F/G properties first, actively non-compliant, improvement is mandatory
2. E properties next, plan for the proposed C deadline; improving between tenancies is far cheaper than mid-tenancy
3. D properties third — if band C is legislated, D becomes the compliance risk
4. Use ECO4 wherever eligible, the scheme is time-limited; apply now for any tenant receiving means-tested benefits
5. Batch by property type, five cavity-wall semis in the same area can be surveyed and insulated in a single contractor visit

Step 4, Exemptions: when and how to use them

Exemptions are narrow and must be registered on the PRS Exemptions Register before you continue letting. An unregistered exemption is not valid.

Cost cap exemption: All relevant improvements would cost more than £3,500 (the current cap under the E standard; expected to rise to £15,000 under the proposed C standard). You must get three installer quotes, carry out all improvements that collectively cost under £3,500, then register the exemption with evidence.

Consent exemption: A tenant, lender, or planning authority has refused consent in writing. Document everything.

Devaluation exemption: An independent surveyor confirms the works would reduce market value by more than 5%.

Listed building exemption: Applies where compliance would unacceptably alter the character of a listed building.

Common mistakes: getting only one quote, not completing sub-cap measures before claiming the exemption, letting the five-year exemption lapse without re-registering.

Step 5, The proposed C standard: planning now

The C standard is not yet law, but the 2030 planning horizon is worth working to. Key actions:

1. Know your scores, commission assessments for any property without a current EPC
2. Model improvement costs per property type, cavity-wall vs solid-wall costs differ by 5–10×
3. Check ECO4 eligibility — scheme rules and end dates change, so confirm current eligibility on GOV.UK
4. Schedule works between tenancies, insulation and wall works in an empty property are faster and cheaper
5. Factor into purchase decisions, an F-rated Victorian terrace needs an £8,000–£18,000 improvement budget

For the full legislative timeline and cost cap details, see our EPC C by 2030 guide.

Getting assessments across your portfolio

For London landlords managing multiple properties, we recommend a portfolio sweep: a bulk EPC assessment programme to confirm all current ratings in one round. We can assess multiple properties in a single day if geographically clustered.

All 32 London boroughs are covered. See our landlords page for service details, our pricing page for per-property costs, or contact us to arrange portfolio scheduling.

For the full legal detail on MEES, see our MEES regulations guide. For individual improvement costs, see our EPC improvement guide.