On 21 January 2026, the government published its partial response to the consultation on “Reforms to the Energy Performance of Buildings.” The EPC reform document confirms significant structural changes to how Energy Performance Certificates will operate after EPC changes 2026, with implementation targeted for October 2026.
This update moves the domestic EPC regime away from a single headline rating towards a multi-metric approach, while tightening compliance requirements for previously exempt sectors.
Here is a technical breakdown of the new framework.
EPC Reform Framework – EPC Changes 2026

1. Domestic EPCs: The Move to Four Metrics
Historically, domestic EPCs have relied on a single Energy Efficiency Rating (EER) based largely on fuel costs. This has often created a disconnect between a building’s thermal efficiency and its rating—for example, penalising electrically heated homes due to higher unit costs compared to gas.
From October 2026, new-style domestic EPCs will display four separate headline metrics to provide a more granular assessment:
- Fabric Performance: A specific measure of the building envelope’s efficiency (walls, roof, windows and floors), independent of the heating system. This separates the “insulation” assessment from the “technology” assessment.
- Heating System: A rating based on the efficiency and carbon intensity of the heat source.
- Energy Cost: An estimate of running costs to ensure transparency for occupiers regarding affordability.
- Smart Readiness: A new metric assessing the building’s capacity to integrate with smart meters and flexible energy tariffs.
Transitional Arrangements: To maintain continuity for the “EPC C by 2030” target, the legacy EER metric will be retained temporarily alongside the new metrics.
2. Non-Domestic EPCs: Retaining the Carbon Standard
For commercial and non-domestic buildings, the government has opted to maintain the status quo regarding the headline metric.
Non-domestic EPCs will continue to use the Carbon-based Environmental Impact Rating (EIR) as the single headline rating. The consultation concluded that this remains the most effective tool for businesses reporting on Net Zero progress and managing compliance with non-domestic MEES regulations.
3. Regulatory Scope: Exemptions Removed
The response confirms that the requirement for a valid EPC will be extended to several sectors that were previously exempt or operated in regulatory grey areas.
- Heritage & Listed Buildings: The exemption for heritage properties is being removed. Landlords of listed buildings will be required to produce a valid EPC when the property is marketed, sold, or let.
- HMOs (Houses in Multiple Occupation): Regulations will be updated to require a valid EPC for the whole building whenever a single room is rented out.
- Short-Term & Holiday Lets: Properties will require a valid EPC regardless of whether the guest is responsible for paying the energy bills.
This aligns with the wider tightening of the Minimum Energy Efficiency Standards (MEES). For a full timeline of the 2030 targets and regulatory deadlines, read our guide on Navigating the Reintroduction of MEES.
4. Timelines and Validity
Validity Period
The government consulted on reducing the EPC validity period from 10 years to 5 years to improve data accuracy. However, following industry feedback regarding costs, it has been confirmed that EPCs will retain their 10-year validity period.
Marketing Trigger Point
The regulations are being tightened regarding when an EPC must be commissioned. A valid EPC will be required strictly at the point of marketing a property for sale or rent, rather than prior to exchange or completion.
Implementation Date
The government is working to specific timelines to allow the industry to prepare:
- Early 2026: Final government response on outstanding technical questions (including Air Conditioning Inspection Reports).
- October 2026: Target launch date for new-style domestic EPCs.
Industry Implication: The Focus on Fabric
The introduction of a standalone Fabric Performance metric is a significant policy shift. By decoupling fabric efficiency from heating costs, the new regime will likely expose properties that rely on low-carbon heating systems to mask poor insulation.
For asset managers and landlords, this reinforces the importance of a “fabric-first” retrofit strategy. Upgrades to insulation and glazing will now be directly visible on the certificate, rather than being buried within a composite score.
Preparing for EPC Reform – EPC Changes 2026
With the EPC reform set for October 2026, we advise landlords and asset managers to start reviewing their portfolios now. Waiting until the new system goes live could leave you with properties that suddenly look “poorer” on paper—particularly if they rely on electric heating but have poor fabric efficiency.
- Review your data: Look at your existing EPCs. If you have properties with high “Cost” scores but low insulation levels, they may be exposed under the new Fabric Performance metric.
- Plan retrofits holistically: When planning upgrades between now and 2026, ensure you are improving the building fabric (insulation, windows), not just changing the heat source.
- Stay informed: The government will release further technical guidance throughout 2026.
Understanding the new metrics is just step one. To see how these changes fit into the government’s wider legal targets for 2030, check out our update on The Return of MEES.
Source Reference: You can read the full text of the government’s consultation outcome here: Reforms to the Energy Performance of Buildings regime – partial government response (GOV.UK)
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