New EPC regulations in 2028: the landlord guide.

From the proposed 2028 implementation date (subject to confirmation; the date has already moved once), no rental property in England or Wales would be lettable, to a new tenant or an existing one, unless it achieves a minimum EPC rating of C. The current minimum has been E since 2020. The jump from E to C is significant: an E-rated property typically needs work across insulation, glazing, and heating to make the leap. If confirmed, the penalty for non-compliance would be the property cannot be let, which for a portfolio landlord is an existential risk.

There is no single magic intervention. EPC ratings are computed across the entire building envelope, heating system, hot water system, and lighting. The five interventions that typically deliver the biggest jump on a Victorian terrace: loft insulation to 300mm (U-value below 0.18), cavity wall insulation if not already done, replacement of single-glazed windows with double-glazing, condensing boiler replacement, and full LED lighting. For solid-wall properties, internal wall insulation is the largest single move: and the biggest commitment.

Two patterns we see repeatedly. First, landlords run the upgrade themselves in piecemeal fashion, never quite achieving the rating jump because each individual upgrade only moves the EPC by 5-10 points. Second, landlords go for the cheapest contractor and discover the assessor reports the work doesn't actually qualify under the assessment criteria. Both end up costing more than getting it done properly first time.

Now, if you can. The date has moved before and may move again, but the work is the same whenever it lands, and contractors get busier as any deadline approaches. A landlord starting the upgrade programme in 2026 has flexibility on contractor choice and pricing. A landlord starting in late 2027 will pay a panic premium and may not finish on time.