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Tracking decarbonisation: are Energy Performance Certificates fit for purpose?
Posted on 9 May 2025

As I outlined in my last LinkedIn article, the government is walking a narrow path between balancing economic growth with its net zero obligations. Both are hugely important objectives, but are they antithetical? How do you balance trying to deliver 1.5 million new homes over the term of this government while reducing the country’s carbon emissions by 50% over the next four years?

There’s also the issue of existing housing stock. There are 24.7 million homes in England, a significant number of which are extremely old. There’s a case to be made that the UK has the oldest, and by extension, some of the least energy-efficient housing stock in the world. Indeed, heat-leaking homes in England and Wales are unleashing 30 million tonnes of avoidable CO2 every year.

If we are to successfully navigate this tricky balancing act, a key question is how best to certify and measure progress. If we can’t do this accurately, it becomes exceptionally difficult to develop a representative picture of where we are, benchmark progress, and take steps to either optimise or reassess our approach.

Energy Performance Certificates (EPCs)

EPCs were first introduced in the UK in 2007. Since then, they have served as the primary tool for assessing the energy efficiency of residential properties and a key measurement tool for the government to monitor the ongoing decarbonisation of the built environment.

Buildings receive a score of A (excellent) to G (poor). Gradings take into account excess energy demand – and, by extension, carbon emissions – from features such as insulation, window glazing, energy usage, heating systems, and more.

Currently, rented properties in the UK must have a minimum rating of E, although the government has pledged to enforce a mandatory minimum C rating by 2030. Landlords who fail to meet this standard will not be able to rent out their properties. They may be forced to sell up if they refuse, or are unable, to make the necessary upgrades. While this move brings an incentive for landlords to make properties more energy efficient, it won’t be extended to those who own their own homes.

Here, this pledge has a fundamental shortcoming: 16 million homes in England are owner-occupied. The idea that 65% of England’s homes will be exempt from changes to the EPC system, designed to bring improvements and ultimately make the UK’s built environment more sustainable, is alarming.

While regulatory requirements don’t need to be identical, there should be an obligation for both landlords and homeowners to make the changes that will ultimately help the UK reach its net zero targets.

There’s also the issue of cost. EPC improvement targets, and indeed any similar regulation for homeowners, should include some funding incentives.

In 2021, former Prime Minister Boris Johnson announced the Green Homes Grant, providing funding to help homeowners cover the costs of insulating England’s draughty homes and bring down their household energy bills. The scheme collapsed after only six months.

There are alternative schemes still in existence to support this. For example, the Great British Insulation Scheme and Warm Homes Grant provide support for properties with an EPC of D to G. The former offers free or cheaper insulation for some homes, while the latter provides grant funding for energy efficiency improvements and installing low-carbon upgrades such as heat pumps or solar panels. The Home Upgrade Grant provides a similar function for homeowners, aimed at lower-income households and those off the gas grid. However, applying for these grants can be confusing and bureaucratic and many only cover upfront costs, rather than the full cost of an upgrade, leaving homeowners and landlords significantly out of pocket.

There’s also an ongoing conversation about the accuracy of EPCs. Many are calling for an overhaul of the scheme, citing unreliable and misleading data. Ratings are often years outdated, with discrepancies between providers resulting in data that is not a consistent or fair comparison for asset owners.

Likewise, the methodology used for EPC measurements does not consider the whole lifecycle of a building. Measuring embodied carbon, which is produced during a building’s construction and development phases, is as important as operational carbon. EPCs do not take this into account.

What’s the result of this?

Inaccurate data can negatively impact carbon emissions and undermine efforts to reduce the environmental impact of our homes. If a property’s true energy efficiency is misrepresented, this can lead to a lack of action from landlords to upgrade properties, and conversely, could lead to incorrect costly upgrades based on misleading information.

Steps are being taken to introduce regulation which directly addresses the decarbonisation of our homes. The long-awaited Future Homes Standard, which aims to ensure all new homes produce 75-80% lower carbon emissions than current standards, is due to come into force this year. However, this still does not address the energy inefficiency of existing stock.

The government have made some headway in addressing misleading data, with reformed metrics set to be introduced as part of EPCs in 2026. This will include a new fabric performance standard for heating systems and consideration of smart technologies.

It’s clear that EPCs have pitfalls. If the government is to rely on them as a measure of progress, reforms are essential to accurately reflect the UK’s built environment and its greenhouse gas emissions, especially as Labour looks to ramp up housebuilding.

When applied correctly, EPCs offer a useful benchmark, but requirements must extend beyond rental properties. Stricter regulations and more financial support for homeowners, landlords and building operators are needed to ensure data is accurate and up to date.

If we are to rely on EPCs going forward, government-enforced accountability for developers, homeowners, landlords, and building managers alike is crucial to upholding a trustworthy measurement system.

Karen Dunstan
Co-Founder / General Counsel / COO

Karen has 15 years post qualification experience having completed her law degree at The London School of Economics. Karen was previously at Urban Exposure Plc for 7 years, as General Counsel. Karen has also worked at King & Wood Mallesons, Herbert Smith LLP and Charles Russell.

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