The UK government has published a partial response to its consultation on Reforms to the Energy Performance of Buildings regime, outlining significant updates to how Energy Performance Certificates will operate from 2026 onwards. While much of the reform focuses on domestic EPCs, there are important implications for commercial landlords, particularly around when EPCs are required and how the regime will apply across different rental sectors.
This article summarises what has been confirmed so far, using only information published in the official consultation documents and partial government response.
The consultation, launched on 4 December 2024 and closed on 26 February 2025, sought views on:
The reforms are part of the government’s broader objectives to:
The Ministry of Housing, Communities and Local Government, supported by the Department for Energy Security and Net Zero, is leading these changes in England and Wales.
One of the most important clarifications for commercial landlords is that non-domestic EPCs will retain the single carbon-based Environmental Impact Rating as the headline metric.
During consultation, views were sought on whether additional metrics should be added. However, the government has confirmed that:
This decision is intended to:
While some respondents highlighted that the carbon intensity of electricity generation is outside the control of building owners, the government has decided to maintain this approach.
For commercial landlords, this means that the overall structure of non-domestic EPC scoring will not fundamentally change in 2026.
The consultation explored reducing EPC validity from the current ten-year period to a shorter timeframe.
Many respondents, particularly landlords, expressed concern about:
The government has confirmed that:
For commercial landlords, this provides continuity and avoids the need for more frequent reassessments solely due to regulatory reform.
A more significant operational change for commercial landlords concerns when an EPC must be in place.
Currently, regulations allow up to 28 days after marketing begins for an EPC to be obtained.
The government intends to update regulations so that:
The majority of consultation respondents supported this proposal, recognising that prospective buyers and tenants should have access to energy performance information at the decision-making stage.
For commercial landlords and managing agents, this means:
This change is designed to improve clarity and strengthen compliance and enforcement.
The government intends to clarify the scope of the regime so that:
While this primarily affects residential HMOs, it signals a broader government approach of ensuring consistent information across rental sectors.
The consultation addressed short-term and holiday lets, where regulatory requirements have previously been less explicit.
The government intends to update regulations so that:
Although this change is primarily residential in impact, it reflects a wider move toward expanding EPC coverage across building types and tenures.
One of the more controversial proposals concerned removing the exemption for heritage properties.
The government has stated its intention to:
While consultation responses raised concerns about suitability of retrofit recommendations and cost implications, the government’s position is that removing the exemption provides:
Importantly, the government noted that where MEES applies, exemptions remain available to ensure owners are not mandated to install unsuitable measures.
For commercial landlords with listed or heritage buildings, this means EPC requirements may apply more consistently in future.
The government confirmed it is working to ensure that:
interact effectively without placing undue burdens on landlords.
The final position on requiring a new EPC when one expires during a tenancy is still being refined. Further detail will be published in 2026.
For commercial landlords, it remains critical to monitor how EPC reform aligns with evolving MEES requirements.
New-style domestic EPCs are expected from October 2026, subject to parliamentary approval.
For non-domestic buildings:
The government has acknowledged that implementation timelines are ambitious and has committed to engaging with industry to support transition.
Further responses covering:
are expected in 2026.
Based on the confirmed reforms:
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