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EPC Action Plan

Reasons to choose Wilson Browne

On 30 September 2020, the government published its Action Plan on EPCs, together with responses to the consultation.

Action Plan

The Action Plan sets out a series of actions that aim to deliver:

  • Accurate, reliable and trusted EPCs.
  • EPCs that engage consumers and support policies to drive action.
  • A data infrastructure fit for the future of EPCs.

For each priority area, the Action Plan sets out actions that it will take forward to ensure EPCs are fit for the future. This will involve stakeholder engagement and formal consultations where legislative change is required to take actions forward. The Action Plan contains a timetable for taking forward the various actions in 2020 and 2021.

There will be a consultation on the Energy Performance of Buildings (England and Wales) Regulations 2012 (SI 2012/3118) (EPB Regulations) seeking views which will be used to inform future domestic policy after the end of the Brexit transition period.

Accurate, reliable and trusted EPCs

The government will:

  • Take steps to better identify non-compliance with the EPC regime and review the penalties for non-compliance.
  • Consider how to provide better consumer information and improve quality assurance of EPCs.
  • Review requirements for EPC assessor competence.
  • Improve the existing assessor registration process to ensure unique assessor registration numbers and prevent multiple assessor records.
  • Consider implementing a formal error reporting system for the Energy Performance of Buildings Register.
  • Consider options for improved oversight and accountability of the whole EPC system to deal with quality, compliance, and potential gaming and fraud issues in a more comprehensive way.

It will also consult on options for the introduction of a new operational ratings scheme for non-domestic buildings. As part of this, it will consider how a new operational ratings scheme will align and interact with the existing Display Energy Certificates (DECs) framework.

EPCs will need to move from a reflection of the features of a building (fabric, services and installed improvement measures) to a true measure of “in use” building performance. This can be based on more sophisticated building modelling that takes actual energy consumption into account.

EPCs that engage consumers and support policies to drive action

The government wants to engage consumers and third parties more on how a building is performing and how they can make appropriate improvements. The government is aiming for as many homes as possible to achieve EPC Band C by 2035.

The government will consider the advantages and disadvantages of reducing the validity period of EPCs from ten years to a shorter period, and whether there should be new trigger points for requiring an EPC (for example, where substantive works have triggered the need for planning permission or Building Regulations approval).

The government will also:

  • Consider changes to the EPB Regulations which would improve compliance with Minimum Energy Efficiency Standards (MEES) in the private rental sector.
  • Publish a consultation on the merits of setting requirements for lenders to help households improve energy performance of homes for which they make a loan.
  • Clarify EPC guidance in relation to minimum standards in the private rented sector.
  • Improve presentation of EPC data online, consider additional training requirements for assessors and review EPC recommendations.
  • Consider how smart meter and other smart technologies can be reflected in EPCs to provide additional information about the features of a property.

A data infrastructure fit for the future of EPCs

Various steps will be taken to enable easy access to EPC information and link it to other relevant sources of data. Actions to achieve this will include the transitioning to a new Energy Performance of Buildings Register, allowing EPCs to be updated following changes to the property, publishing an extended Open Data dataset and considering how to provide additional information to consumers.

There will be a new consumer-facing Property Hub which will allow property owners to access a “logbook” for their property showing works which have been carried out.

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Tom Warrender


Tom Warrender


Tom is a Solicitor and Partner with 15 years + experience advising clients in relation to commercial property matters. A Legal 500 recognised lawyer, Tom is a member of SHLA and CRELA, sits on our Board of Management & Heads our Social Housing Team.