Few compliance topics generate more confident misinformation than EPC C. Half the internet says it is already law; the other half says it was scrapped forever in 2023. Both halves are wrong, and an agency that plans on either version will either spend money it did not need to spend yet, or sleepwalk into 2030 with a D-rated portfolio and a £30,000-per-property downside.
Here is the honest status as of 11 July 2026, verified against gov.uk consultation outcomes, legislation.gov.uk and the Warm Homes Plan, followed by the plan an agency can actually run. General information, not legal advice; the policy area moves, which is why this guide carries a visible review date.
The law in force today: EPC E, £3,500 cap, £5,000 penalties
The governing rules remain the Energy Efficiency (Private Rented Property) Regulations 2015. Since 1 April 2018 for new tenancies and 1 April 2020 for all in-scope tenancies, a domestic rental in England and Wales legally required to have an EPC cannot be let below band E unless a valid exemption is registered on the public PRS Exemptions Register.
The current cost cap is £3,500 including VAT per property (spend since 1 October 2017 counts), and the exemption menu includes "all relevant improvements made", high-cost, wall-insulation-unsuitable, third-party consent refused, devaluation and a six-month new-landlord exemption, mostly lasting five years. Local authorities enforce, with penalties reaching £5,000 in total per property. Letting an F or G property without a registered exemption is unlawful now, which makes any F/G stock on your books today's problem, not 2030's.
The 2030 standard: decided, dated, not yet law
On 21 January 2026, alongside the Warm Homes Plan, the government published its response to the 2025 consultation and fixed the shape of the next regime:
- One compliance date: 1 October 2030, for all tenancies. The earlier idea of a 2028 start for new tenancies was dropped.
- Not literally "EPC C". On reformed EPCs the standard becomes dual-metric: a primary fabric performance standard, plus the landlord's choice of a heating system or smart readiness secondary standard, marketed as the equivalent of EPC C.
- Cost cap £10,000 including VAT (down from the £15,000 consulted on), with assessment costs counting toward it; government's own estimate of average spend is around £5,400. Cost-cap-based exemptions will last ten years.
- Penalties up to £30,000 per property per breach.
- Grandparenting: a property already holding an EER C or better on an EPC in place before 1 October 2029 counts as compliant until that EPC expires or is replaced.
The critical caveat: government said it will seek new primary powers and then lay regulations aiming to be in force in 2027. As of 11 July 2026, no such Act or statutory instrument exists. So the 2030 standard is a firm, dated policy decision, the right basis for planning, and still not something anyone can be fined against today.
The EPC itself is changing too
Two reforms run underneath the MEES story and interact with it. First, assessments got more rigorous in June 2025 when RdSAP 10 arrived: post-June-2025 ratings can genuinely differ from older ones because the methodology now measures more. Second, the reformed EPC, with four headline metrics (energy cost, fabric, heating system, smart readiness) produced by the new Home Energy Model, has been delayed to the second half of 2027. Validity stays ten years, HMOs will need a whole-building EPC when letting single rooms, and the question of forcing renewal mid-tenancy is explicitly deferred.
For planning purposes, the interaction that matters is: the 2030 standard will be assessed on reformed EPCs, except where grandparenting applies, and grandparenting runs off the current-style EER band. That makes the window before October 2029 unusually valuable.
The agent's playbook
- Audit the portfolio now. For every managed let: current EER band, EPC issue and expiry dates, tenancy renewal dates. Three buckets fall out: F/G (unlawful today without a registered exemption, act immediately), D/E (the 2030 work queue), and C+ (check expiry against the grandparenting window).
- Play the grandparenting window deliberately. A property that can reach EER C on an assessment done before 1 October 2029 locks in compliance until that EPC expires, up to ten years. For D-rated properties near the boundary, modest measures plus a post-RdSAP-10 reassessment may be the cheapest compliance that will ever be on sale. The mirror-image caution: do not casually reassess a marginal C, because the newer methodology could drop it to D.
- Sequence voids fabric-first. The confirmed primary metric is fabric performance, so lofts, cavity walls, floors and glazing go first in any between-tenancy works plan; a heat pump (the £7,500 Boiler Upgrade Scheme persists) or smart-readiness measures can satisfy the secondary standard. Zero-rated VAT on energy-saving materials runs until March 2027, which argues for earlier rather than later.
- Build the evidence file as you go. Dated invoices, three-quote evidence, and correct, diarised entries on the PRS Exemptions Register (they are public, they expire, and they do not transfer on sale). Today's records underpin tomorrow's ten-year exemptions and defend against penalties in both regimes.
- Tell landlords the honest version. Nothing kills credibility like an agency parroting "EPC C is law" scare content. The accurate pitch is stronger anyway: E is the law, C-equivalent is coming on a fixed date, the cheap window closes October 2029, and here is your property's number.
Where LintelCRM fits
This is registry work: per-property EPC bands, issue and expiry dates, works invoices and exemption entries, tracked against dates that matter. LintelCRM's compliance module keeps EPCs alongside gas and electrical certificates with expiry status per property, the document module holds the invoice and exemption evidence trail, and the landlord portal lets each landlord see their own EPC position without a phone call, which is precisely the conversation the 2030 planning requires.
Sources
Gov.uk domestic MEES landlord guidance; SI 2015/962 as amended by SI 2019/595; the February 2025 consultation "Improving the energy performance of privately rented homes" and its 21 January 2026 government response; the Warm Homes Plan; the Energy Performance of Buildings reform consultation and partial response; the March 2026 EPC-reform delay statements. All checked 11 July 2026. Policy in this area moves: the review date above is a commitment, not a decoration.