On 21 January 2026, the government published its long-awaited Warm Homes Plan (WHP), a key Labour manifesto commitment. The plan sets out how homes will be upgraded to reduce emissions, adapt to climate change and lower energy costs, supported by a new Warm Homes Agency and a focus on skills and delivery capacity.
Crucially for landlords, the WHP confirms the government’s direction on Minimum Energy Efficiency Standards (MEES).
Below is our understanding of the government’s announcement.
EPC C by 2030 is now confirmed
For privately rented homes in England and Wales, the headline requirement is clear:
Landlords must upgrade properties to reach EPC Band C across two metrics by 1 October 2030, unless a valid exemption applies.
This was widely expected, but the confirmation provides long-needed certainty after several years of delay and consultation.
Alongside the WHP, the government published responses to two closely linked consultations:
- Improving the energy performance of privately rented homes: 2025 update
- Reforms to the Energy Performance of Buildings regime
Together, these clarify how EPCs will change and how MEES will be enforced.
What is changing with EPCs?
Domestic EPCs will move away from a single headline rating and instead show four new headline metrics:
- Energy cost
- Fabric performance
- Heating system
- Smart readiness
Two secondary metrics will also be added, covering energy demand and carbon impact. The existing Energy Efficiency Rating (EER) will be retained during the transition to support compliance with current rules.
Commercial EPCs will continue to use a single carbon-based Environmental Impact Rating.
The government also confirmed:
- EPCs will remain valid for 10 years
- EPCs will be required at the point of marketing
- All heritage buildings will require an EPC
- EPCs will be required for whole HMOs and short-term rentals.
New EPCs are currently targeted for October 2026, subject to industry readiness.
How MEES will work for private landlords
The final policy confirms a dual-metric MEES standard:
- Landlords must first invest towards meeting a fabric performance standard
- They must then invest towards either the heating system or the smart readiness metric, at their discretion.
Even where an exemption applies to the fabric standard, the secondary standard must still be addressed unless further exemptions apply.
All tenancies must be compliant by 1 October 2030. Unlike earlier proposals, there is no earlier compliance date for new tenancies, which many landlords will welcome.
Transitional arrangements and cost cap
Properties already rated EPC C or above before 1 October 2029 will be treated as compliant until that EPC expires.
Landlords will be required to invest up to £10,000 per property. Once this cap is reached, a 10-year exemption may be registered if the property still falls short of the cap and meets the relevant criteria. Spending from 1 October 2025 onwards will count towards the cap, including third-party funding, with the exception of the Boiler Upgrade Scheme.
The government estimates the average spend to be around £5,400 per property. The cost cap will be reviewed every five years, although not before the 2030 compliance date.
Exemptions and enforcement
New and updated exemptions include:
- Negative impact and solid wall insulation exemptions
- A property value adjustment for homes valued under £100,000
- Retention of high-cost, third-party consent and new landlord exemptions
- Exploration of a portfolio-level exemption for larger landlords
Local authorities will be able to issue fines of up to £30,000 per breach, with further guidance on enforcement to follow.
A new PRS database, introduced under the Renters’ Rights Act 2025, will support compliance checks from late 2026.
What is not changing yet
For now:
- Short-term lets are not included within PRS MEES
- Letting agents and platforms are not required to restrict advertising to properties that comply with the law.
Both remain under review.
What this means for portfolio landlords
For landlords managing multiple properties, MEES compliance is no longer just a building-by-building issue. The government has signalled it will explore a portfolio-level exemption, allowing larger landlords to apply the cost cap across a group of properties rather than on an individual basis. While details are not yet confirmed, this signals a more planned approach to compliance.
Portfolio landlords should now audit EPC expiry dates, identify higher-risk assets, and plan upgrades in a coordinated way to avoid bottlenecks ahead of 2030. A portfolio view also makes it easier to phase works, manage budgets, and align EPC improvements with lease events, refurbishments, or asset-disposal decisions.
What about social and commercial property?
Social rented homes must reach EPC C or equivalent by April 2030, with a phased approach to meeting multiple metrics by 2039.
There is still no update on MEES for commercial property, despite progress on the domestic side.
What should landlords do now?
While some details are still emerging, the direction of travel is clear. Landlords should be reviewing existing EPCs, understanding likely upgrade pathways and factoring MEES compliance into medium-term planning well ahead of 2030.
If you manage multiple properties, the work you do in the next 12 to 24 months will largely determine how painful or smooth 2030 turns out to be.
If you are looking for advice or support around the Warm Home Plan and MESS, talking to our team is simple:
- Call us – London 020 3143 1881 or Cambridge 01223 269 215
- Email us on info@beachenergy.co.uk
- Visit www.beachenergy.co.uk
