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  • Writer's pictureKaren Fletcher

Are EPCs on the way out? And will we miss them?

Updated: Aug 1, 2023


At the end of July 2023, the UK government announced that it would delay proposed changes to its Minimum Energy Efficiency Scheme for private rented homes.


The original proposal had been to set a minimum EPC rating of C for all privately-rented dwellings by 2028. Currently, an E rating is the minimum requirement. Michael Gove, Secretary of State for Levelling Up, Housing and Communities, commented: “We do want to move towards greater efficiency, but just at this point when landlords face so much, I think that we should relax the pace that’s been set for people in the private rented sector…”


The National Residential Landlords Association (NRLA) objected to the deadline. It pointed out that, since the government had not yet committed to its proposal, NRLA members would have difficulty meeting that target date.


It seems the government has been quick to drop a scheme which would have supported the energy upgrades of significant numbers of existing UK homes. However, it is very interesting to note that as far back as 2020, the government was questioning the value of EPCs as a measure of building efficiency.


Lacking accuracy In its report, Energy Performance Certificates for Buildings Action Plan, the government discusses feedback from a call for evidence on EPCs. The government wanted to explore the effectiveness of EPCs, particularly in light of its proposals to use them as a critical measure for driving energy efficiency in the UK’s existing building stock.


The report states that because of this vital role: “EPCs need to be accurate, reliable and trusted.” Feedback made it clear that in their current form, EPCs do not meet those criteria.

One of the key findings is that EPCs do not accurately reflect the energy use of buildings in operation (homes or non-dwellings).


Only 3% of respondents to the call for evidence said that EPCs were accurate. A large majority pointed to a lack of clarity about what information goes into an EPC and said that better information on how EPCs are created would make them less of a ‘black box’, particularly for householders.


In the commercial construction sector, EPCs are required by regulations, but experts believe that they’re no longer fit for purpose. For example, RICS (Royal Institute of Chartered Surveyors) notes that: “The construction industry and the government both recognise the need for EPC methodology to be revised to not only consider fuel cost as its main metric but also look to use the other metrics available on the EPC such as carbon emissions and primary energy.”


One of the main criticisms of EPCs is that they indicate theoretical, as designed, energy use – not actual or metered energy use. Commercial landlords are increasingly interested in understanding metered energy use to accurately inform their building operation strategy and corporate carbon goals.


The result is the growing popularity and adoption of voluntary schemes such as NABERS, which measures metered energy and is based on a Design-for-Performance agreement. Many leading UK developers and main contractors have been involved in its introduction to the UK (from Australia, where it originates,) and several buildings have already achieved the NABERS star rating.


Where next for EPCs? For domestic EPCs, the government has updated its website and provides more information for households on the EPC rating scheme. It has also updated its error-reporting system. Further response is due from the government on other steps it intends to take to improve the scheme.


For non-dwellings, the government is considering options for introducing “a new operational ratings scheme for non-domestic buildings, including how a new operational ratings scheme would align and interact with the existing Display Energy Certificates (DECs) framework.” Final word on the next steps will be published “in due course”.


Display Energy Certificates currently only apply to public buildings occupied by public authorities and frequently visited by the public. Unlike EPCs, they are based on the actual amount of metered energy use in the building over the previous 12 months. For public buildings over 1,000m2, a DEC is valid for 12 months. DECs for public buildings between 250m2 and 1,000m2 are valid for 10 years.


With greater emphasis placed on the energy and carbon performance of buildings, accurate and transparent measurements are vital for success. Without it, there is no clear benchmarking for scheme users, so building designers or owners do not have clear targets. It’s also challenging to track the success of energy-saving building improvements without accurate data.


It has to be said that with every change to Net Zero strategies the government makes, the harder it becomes for manufacturers, consultants and contractors to step up. Without a clear direction from the government, it is difficult to plan for investment in new low-carbon product development or training courses for installers, for example.


One thing to note is that in the commercial building sector, clients are leading the way by adopting voluntary schemes such as BREEAM or NABERS. This determination means that the market is there for the right products and services that can forge the way to low-carbon, energy efficient buildings.


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