Reforming EPCs, as easy as A-G?

Why do EPCs matter?

The energy performance of our homes — how much energy it takes to heat and light the building — shapes how warm and comfortable we’re at home, how much we pay in energy bills, and the environmental impact of where we live. But the way we talk about the energy performance of our homes is changing.

The government has launched a consultation on reforming Energy Performance Certificates (EPCs) — the colourful A-G label we see when buying or renting a property, or potentially when applying for government support to make energy efficiency improvements to our homes. An EPC uses a survey from an accredited assessor to give information about a property’s expected energy costs, and recommends any changes that could reduce these. Designed and used effectively, these certificates have the potential to be an effective tool for helping people to understand their home’s energy efficiency and the improvements they could make.

And EPCs aren’t just a tool for informing people on how to improve the energy performance of their homes or to make decisions about buying or renting a property. They form the foundation of key policies to boost energy efficiency standards more widely. Having or reaching a particular EPC rating is used to measure:

• Targets for tackling fuel poverty and climate change
• Eligibility criteria for energy home improvement schemes
• Minimum energy efficiency standards for private rented homes

That’s why it’s so important that EPCs are meaningful, accurate, and useful both for individuals and policy makers. Citizens Advice welcomes the opportunity afforded by this consultation to shape an EPC that works well for everyone. Despite their less than glamorous reputation, EPCs done right are a key building block in the transition of our homes to net zero.

The introduction of multiple metrics

Currently the EPC headline is based on the expected cost of energy in your property (calculated as cost per square metre). But now the government wants to replace this single headline rating with 4 headline metrics to measure energy performance:

Energy Cost: helping individuals understand how their home’s energy efficiency affects their bills.

Fabric Performance: giving people information about how well their home retains heat, promoting comfortable and energy-efficient spaces

Heating System: giving people information about the efficiency and environmental impact of a home’s heating source and encouraging the adoption of low-carbon heating technologies.

Smart Readiness: assessing the potential to integrate smart technologies into the home that can inform access to smart tariffs.

There will also be 2 complementary metrics: Carbon, an estimate of the carbon emissions arising from the energy used in the building and Energy Use, offering insights into overall energy consumption.

We welcome the effort to give consumers a more complete picture of their home’s energy performance as cost alone does not cover everything a consumer might want to consider. But our concern is that multiple metrics could overwhelm rather than inform.

The current A-G system is intuitive, and in our recent polling 76% of people who have read their EPC say it’s easy to understand. Though more information can be helpful for consumers, adding in too much complexity could make EPCs less clear and useful. A focus on cost, especially in the context of rising energy prices, is a priority for consumers. Our research, conducted in 2024, shows that reducing energy bills and increasing warmth and comfort are the most common motivation for making energy efficiency improvements — approximately twice as many choose reducing energy bills as a motivator than climate impact.

With limited information on how the government plans to display these metrics currently available, we stress the importance of consumer testing to ensure they are presented in a way that is useful.

When metrics clash

There’s also a risk that different metrics could send contradictory messages. For example, installing direct electric heating might improve a home’s heating system score but actually increase bills, especially in poorly insulated properties. This is particularly worrying if the ranking system incentivises expensive legacy electric systems like storage heaters. This is a real concern for those with little to no control over the choice of heating system in their property.

This could be particularly problematic in the private rented sector, where landlords might be tempted to choose options that are cheap to install and improve elements of their EPC score but that leave tenants facing higher costs. Our research has shown that those with inefficient legacy systems pay 25% higher energy costs and are disproportionately likely to be private tenants.

Ravi* lives in a privately rented home heated by electric storage heaters that are expensive to run. The property has an EPC rating of E and extensive mould, which is aggravating his long-term medical conditions. Unsure where to turn next for help, Ravi contacted Citizen’s Advice for support.

This is why we are supporting a fabric first approach to decarbonising heat in homes. Fabric changes deliver concrete improvements that aren’t dependent on factors external to the property. They make homes warmer regardless of policy decisions or factors like the cost of electricity and can make homes more resilient to bill shocks. Fabric improvements are also vital for preparing homes for low-carbon heating and don’t rely on the decarbonisation of the grid supply in order to have tangible climate benefits. Fabric performance as well as energy cost should be the main metrics for policies and schemes that aim to reduce bills and tackle fuel poverty, such as Minimum Energy Efficiency Standards, Warm Homes: Local Grant, and Energy Company Obligation (ECO) grants.

Solid foundations

EPC quality control and accuracy are also important. After all, an EPC is only valuable if people trust what it tells them. We have long-standing concerns about the reliability of assessments that underpin EPCs, with research from UCL highlighting the significant variation in their quality.

With government support for upgrading homes tied to EPCs, and higher minimum EPCs for landlords on the horizon, gaming could be incentivised. Reducing the validity period of EPCs is certainly a positive, as this would limit the impact of an inaccurate assessment. The government has published proposals relating to improving the quality of assessments and improving compliance. These include increased training for assessors, higher penalties for non-compliance and longer time periods for local authorities to pursue EPC fraud.

We support these proposals, but feel that separate work to manage EPC quality is essential. The best way to ensure assessments are reliable is an effective quality assurance process. This would require monitoring, for example by assessor certification schemes, to give an accurate picture of the quality of work and effective enforcement action where quality falls short.

Making EPCs work for everyone

We also support plans to tighten requirements in the private rental sector so that landlords would need to provide a valid EPC throughout a tenancy, and provide EPCs for houses in multiple occupation (HMOs). Inaccurate or out of date EPCs prevent tenants and landlords from gauging the energy efficiency of their properties. Our research has found that upgrading all inefficient homes in Britain to EPC C (using the current rating system) would prevent 6,000 excess winter deaths per year and stop 670,000 children from developing asthma by 2030, saving the NHS £2 billion by 2030. Energy efficiency — or lack of it — has real consequences so it’s vital that landlords are transparent about the performance of their properties.

Landlords also need to have up-to-date and accurate EPCs so they can understand how to improve their properties in line with new standards. In our report Room for Improvement, we found that almost half of landlords who manage all their properties through an agency don’t know the EPC of at least one of their properties. And over 4 in 10 (41%) of landlords with only one property say they don’t know its EPC.

A reformed EPC, which gives landlords the information they need to improve the energy efficiency of their properties, coupled with tighter requirements, is a positive development. We also support the reduction of the validity period of an EPC from 10 to 5 years and an increase in EPC ‘trigger points.’ But as we have previously recommended this must be backed up by enforcement action where standards are not met, including giving local authorities the resources to take proactive action.

Getting the priorities right

Based on our experience helping people navigate energy issues, we believe EPCs should prioritise what matters most to consumers. This means:

1. If the government needs to prioritise metrics, then energy cost and fabric performance are most important — especially when applied to policies and schemes designed to reduce fuel poverty.
2. EPCs must be presented simply and clearly, with straightforward next steps for improvements.
3. EPCs must be trusted. This means that the accuracy of EPCs must be improved. Reduced validity periods to 5 years would go some way to achieve this, but monitoring and enforcement must be robust.

*Names have been changed to protect anonymity