Rented flats and EPC C by 2030: what leaseholders who let, and their block company, should know

What happened

On 21 January 2026 the Department for Energy Security and Net Zero published its response to the consultation on raising energy efficiency standards in privately rented homes. It confirmed that “private landlords of all tenancies will be required to comply with the higher standard by 1 October 2030”. It covers England and Wales.

This is planned, not yet law. The response says the government “will seek new powers by Act of Parliament” and then lay regulations, “with the aim of it coming into force in 2027”. Today the existing rule still applies: since 2020, privately rented homes in England and Wales must reach EPC E unless an exemption is registered, with landlords expected to spend up to £3,500.

The main points of the plan:

• The standard is set against new EPC metrics. Landlords first work towards a fabric standard (insulation and similar), then either a heating system or a “smart readiness” standard of their choice. The government says it does not intend to require heat pumps.
• Spending cap. Landlords will need to spend up to £10,000 per property (including VAT). Spending on relevant improvements since 1 October 2025 counts. Homes worth under £100,000 have a lower cap of 10% of their value.
• Early action counts. A home with an EPC of C or better on the current energy efficiency rating, obtained before 1 October 2029, can rely on it.
• Exemptions include third-party consent (unchanged), a new “negative impacts” exemption where a measure would harm the building, and a solid wall insulation exemption.
• Fines of up to £30,000 per breach, enforced by councils.

What it means for your building

The duty will fall on the landlord of the let flat: in a block, that is usually the leaseholder who lets, not the block company. But the block company is often the “third party” whose consent is needed. Under most leases, outside walls, windows, roofs and shared heating belong to the freeholder or are its responsibility, and changes inside a flat may need consent. Respondents to the consultation told the government that freeholders “would likely refuse permission”. The government’s answer is to keep the third-party consent exemption, which can be registered when consent is refused and lasts five years or the length of the tenancy, and to improve the guidance on when it applies.

So from now to 2030 a board may get requests to fit external or internal wall insulation, new windows, loft or roof insulation over top-floor flats, or a heat pump unit on a balcony or wall. Some of these touch the whole building’s fabric, its fire safety and the lease. A refusal may let the leaseholder register an exemption, but the board still needs a reasoned decision. Some measures may work better done once for the whole block, which is a question for the company’s planned works and reserve fund.

A worked example (illustrative). In a 1930s block of 24 flats, six are let and rated EPC D. If each owner wants cavity wall insulation for their own flat, the company faces six separate requests on one shared wall. Treating it as one project, consulting all leaseholders under section 20 if the cost passes the threshold, may be cheaper and safer than six piecemeal jobs. Whether the lease lets the company recover that cost through the service charge depends on its wording.

This is legal information, not advice. What your lease allows, and whether an exemption fits, depends on its wording and the final regulations.

What to do now

• Find out which flats are let. Leaseholders who let will start asking about EPCs and works.
• Agree a policy on consent requests for energy measures: what the board needs to see (specification, fire safety, structural impact, installer) and how quickly it will reply.
• Ask your surveyor whether any measures, such as roof or wall insulation, would be better done block-wide, and add them to the planned works list.
• Keep the block’s own EPC-relevant information, such as wall type and roof insulation, ready to share with owners.
• Watch for the legislation and the new EPCs. Leaseholders who let should read the government guidance when it is published and take their own advice.

How Freeholdpilot helps

Freeholdpilot keeps the leases and building reports in the document store, and its votes and resolutions tool lets directors record a policy on energy works requests, so the board can answer each request the same way and show when and why it decided.