Registered Exemptions
While the move to EPC C is mandatory, the Government recognises that “one size does not fit all.” For complex assets or difficult-to-treat builds, the PRS Exemptions Register remains a vital mechanism for legal compliance. As we transition to the 2030 standard, three primary exemptions will be key for your portfolio planning:
1: Third-Party Consent
Compliance is not required if you cannot obtain the necessary legal consent. This applies if a tenant refuses access for the works, or if a superior landlord/freeholder (common in leasehold flats) denies permission for external measures like solar panels or heat pump units.
Evidence: You must demonstrate “reasonable efforts” were made and provide copies of the formal refusal.
2: The High-Cost Exemption
If the cheapest recommended improvement required to reach Band C exceeds the £10,000 cost cap, you can register an exemption.
Evidence: You will need to upload three separate quotes from qualified installers to prove that the cost of the single cheapest measure (including VAT) surpasses the limit.
3: Fabric & Wall Insulation
A specific safeguard exists for historic or traditional buildings. If an expert, such as a surveyor from the Royal Institution of Chartered Surveyors (RICS), gives written advice that installing insulation (such as cavity, internal, or external wall insulation) would damage the building’s structure (referred to as its fabric) or unacceptably alter the building’s character, you are exempt from that measure.
Crucial Update: Under the 2026 reforms, cost-cap exemptions are expected to be valid for 10 years, providing long-term regulatory certainty once registered.
Frequently Asked Questions (FAQ)
Q: Do I need a new EPC right now? A: If your current certificate is a D or E, you don’t need an immediate update. However, it is wise to wait until the Home Energy Model (HEM) metrics launch in late 2026 before commissioning major works. This ensures your investment aligns precisely with the new scoring system rather than “chasing points” on an outgoing model.
Q: What if my property is a listed building? A: Listed buildings are not automatically exempt. You are exempt only if the required works would “unacceptably alter” the building’s character. You must still attempt to comply where possible (e.g., secondary glazing or loft insulation) and, if the standard cannot be met, you must apply for a formal, evidence-based exemption on the PRS Exemptions Register.
Q: Will this apply to Short-Term Lets (STLs)? A: As of January 2026, the Government has confirmed that the EPC C mandate will not apply to short-term holiday lets. While these properties still require a valid EPC for marketing, they currently remain outside the scope of the 2030 MEES requirements.
Q: Does the Boiler Upgrade Scheme (BUS) reduce my £10,000 obligation? A: It helps your cash flow, but not your compliance “spend.” The £7,500 grant is excluded from the cost cap calculation. You must still meet the required landlord spend threshold using your own funds to qualify for a “high-cost” exemption.
Strategy: The Managing Agent Shield
Navigating the transition from confusion to compliance requires a strategic partner, not just a contractor. As your managing agent, we serve as a regulatory shield, providing a professional interface between complex legislation and your financial interests. Our role now extends beyond maintenance to comprehensive Retrofit Coordination.
End-to-End Retrofit Coordination
Achieving an EPC C rating under the new 2026 Home Energy Model requires a technical “fabric-first” approach. We manage this entire lifecycle for you:
- Audit & Strategy: We identify which properties in your portfolio are at risk and schedule assessments before the 2029 “legacy” window closes.
- Procurement: We obtain three competitive, technical quotes for all works. This is not only for best value but also a mandatory requirement if a High-Cost Exemption needs to be demonstrated.
- Cap Management: We meticulously track every pound spent from 1 October 2025 onwards, ensuring that your investment is correctly recorded to meet the £10,000 cap without overspending.
Expert Exemption Management
Not every property can or should reach Band C. Where works are physically impossible or financially unviable, such as exceeding the £10,000 cap or the 10% low-value safeguard, we manage the legal filing with the National PRS Exemptions Register. By handling all required evidence, from surveyor reports to tenant refusal logs, we help protect you from proposed £30,000 non-compliance fines and ensure your portfolio remains compliant.
Final Thoughts: The Roadmap to 2030
The 1st of October 2030 is now the definitive deadline for the UK rental sector. While the transition to the reformed EPC C standard is significant, compliance is achievable through a structured approach.
The strategy for the next four years is clear: audit first, then act. Begin by identifying at-risk assets in your portfolio, specifically those currently rated Band D or E, and prioritise fabric-first improvements such as insulation. These measures are reliable, performing well under the current SAP system and forming the basis of the new Home Energy Model (HEM) launching in late 2026.
Wait for the technical details of the 2026 metrics before undertaking major heating system upgrades. This ensures your £10,000 cost cap is used effectively, rather than on a soon-to-be outdated scoring system. Maintain thorough documentation, including all invoices, quotes, and correspondence from 1 October 2025 onwards. Detailed records will support retrospective credit claims or high-cost exemption registrations.
By adopting a phased, evidence-based approach now, you can avoid last-minute challenges in 2029 and ensure your portfolio remains protected.
