Can UK Property Be Rented Without an EPC?

Ever since its introduction in 2007, Energy Performance Certificates (EPC) has been an integral part of any UK rental property. So much so, in fact, that every landlord provides a possible tenant with a copy of their EPC. However, can you even rent a property without an EPC in the UK?

UK property cannot be rented without an EPC. However, the details depend on where in the UK a rental property is. EPCs apply to England and Wales, while Scotland also has its version of EPC. Every buy-to-let has to have an EPC by law, and landlords must provide their EPC to tenants.

In this article, I’ll talk about what an EPC actually is, current UK regulations regarding EPCs and what is assessed in an EPC check. So, if you’re a future landlord yourself or a tenant, continue reading.

What Is an Energy Performance Certificate (EPC)?

Energy Performance Certificate (EPC) is a governmental scale system that measures energy efficiency in rental properties across the United Kingdom, though some variations are present in England and Wales on one side and Scotland on the other.

As a law, EPC was passed in 2007, so it’s been with us for quite some time now. EPCs provide tenants with an assurance that the rental they’re staying in has at least some positive impact on the environment. 

Additionally, EPCs measure the level of energy efficiency and put them on different scales for the government to review and make some changes.

When it comes to the scale, EPCs use what’s called “the minimum energy efficiency standard,” or MEES for short. This scale ranges from A through G, where A represents a point range from 92 to 100 points. As such, it’s the most optimal (and quite rare). 

The G category is at the bottom of the scale, with points ranging from 1 to 20. However, the G rating is no longer available, but more about that later.

This scale is highly important for UK landlords since it means that they can legally rent out a buy-to-let property. In addition, it also means potential future tenants are more likely to live in a secure and energy-efficient home. This can also save those landlords some money because the higher you’re on the EPC scale, the lower the bill costs

EPC Regulations for Rentals in the UK

So, the law is quite clear regarding EPCs: you have to have them if you want to have a rental property available to your tenants. However, there are some additional regulations that landlords need to take into consideration. 

Landlords are required by law to provide their EPC to a potential tenant as soon as possible. Another instance where a landlord must provide the EPC certificate is if that future tenant asks for it, and no, landlords can’t charge anyone for providing their EPC. 

Another question that future landlords and tenants usually have is: once I get my EPC, is that it? Does it last forever? 

The answer to that question is no. Every EPC has an “expiration date,” which is ten years. So, every ten years, you have to register for a new EPC certificate and have your rental reassessed. 

The reason for the 10-year limit’s because energy policies are constantly changing and the scale used ten years ago might be inconsistent with the new policy. 

As a matter of fact, that’s precisely what happened a few years ago. Recently, landlords were required by law to have at least an E rating for their rentals for all new tenants in 2018 and for regular tenants from 2020. This means that the G rating from the EPC scale was removed because it was no longer energy efficient. 

This regulation has come with a huge price tag for many landlords. Therefore, the government has placed a price cap on all future EPC improvements on rental properties, which is £3,500. If a landlord simply can’t afford that much money, they can apply for an “all relevant improvements made” exemption. 

It doesn’t stop there. In 2021, the government introduced a new MEES regulation which states that from 2025, rental properties for new tenants in England and Wales will have to have a minimum C rating if they want to be available for renting out. The government plans to increase the price cap to £10,000 for this regulation.

I’m sure many are wondering about possible penalties. The maximum penalty for domestic property can reach up to £5000. However, if you, as a landlord, haven’t registered for an EPC certificate before renting your property out, you can be fined £200 or a maximum of £2000 for renting a property for three months or less. 

When You Don’t Have to Provide EPC

There are some exemptions outlined by the government, and if you fall under one of those categories, you don’t have to register for an EPC. According to the government website, the exemptions include buildings:

  • They already have an EPC, but additional improvements would devalue them.
  • Places of worship.
  • A detached property that’s under 50² metres of floor space. 
  • A property that’s only going to be used for two years maximum.
  • Properties which don’t use much energy, like industrial sites or workshops.
  • A property that’s going to be demolished soon.

It’s worthy to note that Scotland’s EPC exemptions differ in some respects, such as no exemption for places of worship.

There are additional exemptions designed for landlords in England and Wales:

  • “All relevant improvements made” exemption: Lasts for five years. Intended for landlords who can’t afford all the necessary improvements over £3,500.
  • “High cost” exemption: Lasts for five years; for one necessary improvement that costs more than £3,500.
  • Wall insulation exemption: Lasts for five years; if the wall improvements include: external and internal wall insulation or cavity wall insulation. 
  • Third-party consent exemption: Lasts for five years; for landlords who need consent for improvements from a third party and can’t get one. 
  • Property devaluation exemption: Lasts for five years; if the necessary improvement would decrease the value of the rental property by over 5%.
  • Temporary exemption due to recently becoming a landlord: Lasts for six months; for new landlords who can’t afford or make necessary improvements immediately. 

EPC Checks: What You Need to Know

As I mentioned, EPCs are renewed every ten years. Because of that, landlords need to have their rentals assessed for every new EPC certificate, and it’s the energy assessors’ job to do just that. They visit rental properties and assess every room, including everything that spends some form of energy (like gas or electricity) in those rooms. 

The price for an EPC check varies. It can range from around £40 to about £70. Usually, if you get cheaper EPC checks, the assessment process lasts shorter, and the quality of the assessment may be questionable at best. 

So, what exactly is assessed in these EPC checks? Well, pretty much everything. Energy assessors will most definitely check: 

  • The type of lights you’re using (you want to have LED lights).
  • Level of insulation (reduces gas heating and mould on the walls).
  • Quality of air inside the property (if there’s mould).
  • Rooves.
  • Your heating system.
  • Cooling system.
  • Floors (they should be insulated as well).
  • Windows (you should have at least double-glazed ones).
  • Boilers (you want those that don’t spend too much electricity).

And speaking of boilers, you might want to check out my article on the government’s possible ban on gas boilers as part of their net-zero emissions targets for 2050.

Final Thoughts

Hopefully, everything regarding EPC and rentals is a bit clearer now. Rental properties can’t be rented without a proper EPC certificate that’s not older than ten years. On top of that, new regulations aim to bring the energy efficiency of rentals to the C ratings from 2025. So, if you’re a landlord, some additional requirements are coming your way.


Sources

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