Elmhurst Responds to 'EPC Reform' Consultation
Elmhurst has now issued its full response to the government’s Reforms to the Energy Performance of Buildings Regime Consultation; a consultation which has proposed wholesale change to Energy Performance Certificates (EPCs) in England and Wales.
In addition to proposed changes to both Domestic and Non-Domestic EPCs, the consultation also looked at potential revisions to Display Energy Certificates (DECs) required for public buildings and Air Conditioning Inspection Reports (ACIRs). The outcome of the consultation and changes are likely to come into force in 2026.
Summary of Proposals
The government is proposing to introduce a number of different metrics to be displayed on EPCs- representing a move away from the colourful A to G rating scale (A+ to G for Non-Domestic EPCs). The new metrics proposed are intended to provide a more complete representation of building energy performance.
- Energy cost: helping individuals understand the financial implications of a building’s energy efficiency and make informed decisions about potential improvements
- Fabric performance: assessing the thermal performance of a building’s envelope
- Heating system: providing information on the efficiency and environmental impact of a building’s heating source
- Smart readiness: assessing a building’s potential to integrate smart technologies that can optimise energy consumption
- Carbon: an estimate of the carbon emissions arising from the energy used in the building
- Energy use: offering insights into overall energy consumption and identifying areas for energy efficiency improvements
The consultation highlights that Domestic EPCs would use four headline metrics which includes: ‘fabric performance’, ‘heating system’, ‘smart readiness’ and ‘energy cost’. Other metrics would then be provided as secondary information which would be less prominent on the EPC.
Non-Domestic EPCs will likely maintain the single headline carbon metric in the short term, as they are already carbon-focused and aligned with net zero objectives.
The consultation proposes a change to when an EPC is required for a property. At present, the validity period of an EPC is 10 years, and a valid EPC is required when a property is marketed for sale or let or is newly constructed.
The consultation now poses the question as to what the validity period for EPCs should be, presenting 6 different options, ranging from less than 2 years to 10 years.
A reduction of validity period is also being proposed for DECs, from 10 years to 7 years for buildings between 250-1,000m², and from 7 years to 5 years for buildings over 1,000m (DEC Recommendation Report Only).
As well as the validity period, the government is also considering increasing the requirements/trigger points for EPCs. One of the biggest proposals here includes the need for private landlords to get a new EPC when their current EPC has expired.
The government is proposing a redesign to ACIRs which will aim to simplify them for system operators. A new look report will aim to include the following information:
- the likely efficiency of the system and any suggestions for improvement of any faults identified
- the adequacy of equipment maintenance and any suggestions for improvement
- the adequacy of the installed controls and control settings and any suggestions for improvement
- the current size of the installed system in relation to the cooling load and any suggestions for improvement
- consideration of the capabilities of the system to optimise its performance under typical operating conditions
- a summary of the findings and key recommendations
The consultation aims to enhance compliance and enforcement of EPC requirements.
Proposed updates include revising penalties to better reflect the actual costs of compliance. At present, some fines may be lower than the cost of meeting regulatory requirements, making non-compliance a more attractive option.
Additionally, it has been highlighted that certain penalties have remained unchanged since 2007 and may no longer serve as an effective deterrent.
The consultation is also looking at energy assessors; the training they receive to qualify, as well as the ongoing competency they need to deliver energy certificates for different buildings.
Options have been proposed to tighten this up and identify areas where additional/optional training would be of use. This could include energy assessment of heritage buildings for example.

Elmhurst’s Response Summary:
Priotising Cost, Carbon and Energy Consumption Metrics
Elmhurst supports the proposals to introduce additional metrics to EPCs. There remains much confusion in the industry about what the EPC represents, and the addition of new metrics will help to demystify this. While all 6 proposed metrics have their uses, Elmhurst believes that ‘Energy Cost’, ‘Carbon’ and ‘Energy Usage’ should be the headline metrics, with the others presented as secondary metrics.
Given that so many policies focus on the need to decarbonise, to not give prominence to the Carbon metric seems to be a big missed opportunity. Elmhurst are also concerned that any desire to reform the EPC must not lose sight of the goal of making it an easier document for the average consumer to understand.
Reduce Validity Period of Energy Certificates
Since 2019 Elmhurst has been advocating that an EPC should only be valid for 3 years. As 3 years isn’t an option, we have opted for 2 years. This is driven by the fact that properties can and do change within this time period, particularly sale properties, when new owners (especially buy-to-let landlords) make improvements upon taking ownership. Validity is necessary to provide clarity and overarching direction, over and above this, no building should be marketed with an incorrect EPC. Irrelevant of validity and EPC should be updated and made available when there is a significant change to the property that would impact on the rating or recommendations.
Currently, properties can transact using an (up to) EPC which is 10 years old, which could contain potentially old and out-of-date information, such as property features, recommendations, carbon factors and running costs and savings. This almost entirely negates the value of the EPC for the buyer or renter. This is why a reduction to validity is needed.
Furthermore, we agree that the validity period for DECs and DEC Recommendation Reports should be reduced. Elmhurst’s view is that the validity period should remain the same, irrespective of the building size. In our opinion a DEC should only be valid for 1 year irrespective of building size. Additionally, the DEC Recommendation Report should only be valid for 3 years because this would provide consistency with other energy certificates that require a site visit to establish whether changes have occurred at the property.
Use DECs Beyond Public Buildings
Elmhurst believes that it would be beneficial to extend the application of DECs beyond public buildings so that they encompass all commercial buildings. In doing so this would provide building owners and tenants with valuable insights into their energy consumption, helping them identify areas for improvement and achieve meaningful energy savings in practice.
Review Penalties and Enforcement
Elmhurst agrees that penalties and enforcement for non-compliance should be looked at for all energy certificates, as not addressing these areas effectively could limit any future changes to EPCs and the action which may be required by building owners.
Read Full Consultation Response
Access Elmhurst’s full response to the 48 question consultation, by clicking below
SEE FULL CONSULTATION RESPONSE >