EPC band C deadline 2028: what UK landlords need to do now

Current minimum letting band: E. This has applied to all assured tenancies since 1 April 2020 (it applied to new tenancies from 2018). Letting a property below band E without a valid exemption is unlawful.

Proposed minimum from 2028 for new tenancies: C. Existing tenancies expected to comply by 2030. The 2028 and 2030 dates are subject to final regulations; consultation responses have pushed back on the timeline but the direction is clear.

Practical takeaway: if your portfolio is currently at band D or below, you have roughly 18 to 36 months to plan upgrades. Energy installers are already starting to see capacity pressure from this regulatory cliff.

EPC ratings are calculated using the Standard Assessment Procedure (SAP) or its successor RdSAP for existing buildings. Improvements that move the score most per pound spent are typically:

1. **Loft insulation** to current standards (270mm+). Often the cheapest single move; £400 to £700 typical, can shift the rating one whole band on poorly insulated properties.

2. **Cavity wall insulation** where the property has unfilled cavities. £400 to £1,500. Big rating impact and high tenant-comfort dividend.

3. **Boiler upgrade** to A-rated condensing combi or system boiler. £1,800 to £3,500 installed.

4. **Heating controls**: smart thermostats, TRVs, weather compensation. £200 to £600. Smaller but cumulative impact.

5. **Low-energy lighting** throughout. £50 to £150 across a typical flat. Trivial spend, real rating gain.

6. **Double or triple glazing** where the property still has single glazing. £4,000 to £10,000+. Last resort by cost-per-point, but sometimes unavoidable for stone-built or listed stock.

7. **Solar PV with battery**. £6,000 to £12,000. Strong for properties already at D heading to C; less efficient route from an F or G.

On a typical Victorian two-bed terrace at band D, the cheapest route to C is usually loft insulation + cavity fill + smart heating controls + LED lighting. Total spend £1,200 to £2,400; one to two band moves; assessment + new EPC £45 to £120.

On a 1950s mid-terrace at band E, the route to C usually requires the above plus a boiler upgrade. Total £3,500 to £6,000.

On a pre-1900 solid-wall stone build at band F or G, internal or external wall insulation is the difficult call. Internal £4,000 to £8,000 per room treated; external £12,000 to £25,000 for a whole house. Heritage stock often qualifies for exemption.

**Cost cap exemption**: under current MEES rules, landlords are not required to spend more than £3,500 (including VAT) on improvements per property. The proposed 2028 update raises the cap to £15,000, then to £10,000 for the existing-tenancy 2030 stage. The cost cap is per property, not per landlord.

**Listed building or conservation area** where consent is refused for material upgrades — register a temporary exemption with the PRS Exemptions Register.

**Devaluation exemption**: where a registered surveyor confirms an upgrade would reduce market value by more than 5 per cent.

**Wall insulation exemption**: independent assessor confirms insulation cannot be installed without damage to the building or interior. Common for solid-wall heritage stock.

All exemptions must be registered with the PRS Exemptions Register — they don't apply automatically.

Run a fresh EPC first, even if your current one is in date. The SAP methodology has been revised and a re-assessment under the current method sometimes pushes a borderline property up or down a band on paper alone.

Tackle insulation before any heating upgrade. A new A-rated boiler in a poorly insulated property still scores poorly on SAP.

Save the high-spend interventions (PV, external wall insulation, full window replacement) until last and only if the cheaper measures haven't got you to C.

Book a re-EPC after the work completes. The new certificate is the proof you'll need when MEES enforcement comes in 2028.

Under the current draft regulations, a landlord letting a non-compliant property after the 2028 date is exposed to civil penalties of up to £30,000 per property per year. The penalty mechanism remains under consultation but the precedent (current £5,000 cap) is clearly being escalated.

Insurance and mortgage implications are quieter but real. Several BTL lenders already require minimum EPC band on new portfolios; some explicitly require C-or-above for any new lending from 2026 onwards. Your remortgage in 2027 may surface this before the regulation does.

Get an EPC done now if your current one is over 5 years old or shows D or worse. See [our EPC platform comparison](/guides/best-platform-for-epc-uk-2026) for booking options.

Note the recommendations on the report. They are SAP-software-generated and form the cheapest plausible route to a higher band for that specific property.

Get three quotes per recommended measure. Use [Checkatrade](/api/go/checkatrade?cert=epc), [MyBuilder](/api/go/mybuilder?cert=epc) or your local cooperative.

Budget across the portfolio. A landlord with three D-rated properties is looking at £4k-£8k total spend across 18 months — manageable if planned, painful if rushed.