Positives and pitfalls in the push for EPC C in social housing

The smart readiness challenge

Wider reforms to EPCs have already been proposed and are currently under review by government. These look set to include energy cost, smart readiness, fabric energy efficiency (how the walls, roof and floor retain heat) and type of heating system, with carbon emissions and energy cost also included as a secondary metric.

The new MEES proposals for social rented homes will give social landlords a choice of secondary metric – heating system or smart readiness – to meet in addition to a fabric metric rating of C.

The smart readiness metric may be more challenging to meet for some properties, depending on their age, geography and how they were constructed. In rural areas, where WiFi and mobile network signal is absent, the installation of a smart meter can be problematic.

For certain electrical heating systems to benefit from cheaper energy from plans like a time-of-use tariff, a smart meter is necessary. Using heating system and smart readiness as metrics may simply not be possible in homes where smart meters cannot be installed.

The issue of how these homes then meet the new MEES target of EPC C must then be addressed.

One-size-fits-all cost cap

The government is considering a range of targeted exemptions, which should support rural and hard-to-treat homes.

A new time-limited spend exemption is being proposed specifically for MEES. This would allow landlords to classify a property as compliant if they have spent up to a proposed limit of £10,000 per property on qualifying energy efficiency improvements, even if the property still falls short of the standard. All relevant spending, including grant-funded work, would count towards the exemption, and costs incurred from the date of the government’s formal response to the consultation would be eligible.

The exemption would last for ten years from the MEES compliance deadline of 1st April 2030, after which landlords would be expected to complete any outstanding work to bring the property up to standard. The government believes this approach supports the core aims of reducing fuel poverty and carbon emissions, while allowing social landlords to manage competing demands on resources, such as delivering new housing and maintaining existing stock.

However, for older homes with solid walls and outdated heating systems, £10,000 doesn’t stretch very far. The cost of installing external wall insulation alone can run into many more thousands of pounds. Add to those essential measures like improved ventilation and glazing – it quickly becomes clear that many properties will require far more investment.

While the cap is framed as a floor rather than a ceiling, many providers may view it as a hard limit, especially with large portfolios and finite budgets.

PAS 2035/2030: recommendation vs requirement

In an ideal world, all government funding and regulation should require that work is carried out to the right standards using competent people. PAS 2035:2023 is a strong, whole-house, multi-measure specification for retrofitting dwellings. When used alongside PAS 2030:2023, it ensures retrofit projects are holistically planned, quality assured and deliver the intended outcomes, backed by insurance protections for landlords.

However, for single-measure interventions, mandating PAS could prove too costly, especially as many sole traders or micro companies aren’t yet certified or registered under the framework. In this case, a proportionate approach would be more practical.

Elmhurst-accredited domestic energy assessors (DEAs) and retrofit coordinators are well placed for the next phase of MEES. Energy assessors can offer advanced techniques such as airtightness testing and measured heat transfer coefficient (HTC) analysis – methods that evaluate a property’s actual performance before and after retrofit, ensuring that interventions are appropriate and effective.

The Government’s own modelling suggests that MEES could lift 400,000 of these households out of fuel poverty by 2030 and deliver substantial carbon savings over the lifetime of improvements.

While there are currently no minimum energy efficiency requirements in the social rented sector, many providers have already made significant progress, with a large proportion of homes now achieving EPC band C or better. Establishing MEES for social landlords will help to build on that momentum, providing certainty needed for long-term investment in both existing homes and new developments.

 

Andrew Parkin, technical director at Elmhurst Energy, which trains and accredits energy efficiency professionals