Consultation on EPC Reforms: Sava’s Response.
From 4th December 2024 to 26th February 2025, a joint consultation by the Ministry of Housing, Communities and Local Government and the Department for Energy Security and Net Zero sought responses from multiple sectors about reforms to the Energy Performance of Buildings Regime.
Buildings account for around 20% of the UK’s greenhouse gas emissions, according to recent Government statistics. For years, Energy Performance Certificates (EPCs) have been used – particularly with regards to domestic properties – to indicate the energy efficiency of people’s homes and overtime their usage has broadened considerably. EPC ratings now form the basis of eligibility requirements for several Government funding schemes and regulatory requirements such as the Minimum Energy Efficiency Standards (MEES) for the private rented sector. It is a legal requirement to provide a valid EPC whenever a home is built, let or sold.
This consultation pulls the EPC into focus and marks the first step in the Government’s plan to create a new and improved regime that:
- Supports people in better understanding the energy efficiency and energy performance of homes and commercial properties
- Helps to achieve key national goals
- Drives progress towards the target of net zero emissions by 2050.
The 12-week consultation covering England and Wales called for insights across multiple sectors, from members of the public and individual energy assessors to housing associations, local authorities and those working in the energy sector, to name but a few. It was split into six sections for consultation:
- What EPCs Measure (Metrics)
- When EPCs and DECs Are Required
- EPC and DEC Data
- Managing EPC Quality
- Air Conditioning Inspection Reports
- Additional Questions
Sava has responded to the questions relevant to domestic buildings in sections 1 – 4. For the information of our customers and others, we now highlight some of our key points below.
What should EPCs measure?
Sava responded to the following metrics proposed for inclusion on domestic EPCs:
- Energy cost metric – STRONGLY AGREE
- Carbon metric – AGREE
- Fabric performance metric – NEITHER AGREE NOT DISAGREE
- Heating system metric – DISAGREE
- Energy use – DISAGREE
- Smart readiness metric – STRONGLY DISAGREE
Of the metrics proposed, Sava believes an energy cost metric is by far the most important. Research since the late 1980s has shown that the general public simply do not understand more technical terms such as kilowatt-hours (kWh), heat transfer coefficients (HTCs) and boiler efficiencies. Whilst these metrics are important, for consumers the EPC needs to reflect the cost of occupying their property if it is to make any sense and the household is to be triggered to take energy-saving action.
Regarding a carbon-based metric, there is enough talk in the mass media about climate change, carbon targets and net zero that householders are capable of understanding the impact of their carbon emissions. Including a carbon-based metric on the EPC enables the audience to see the wider potentially beneficial effect of an intervention, such as a switch from gas heating to electric heating.
Most would agree that ‘fabric first’ is a sound approach, and including information based on a fabric performance metric is valuable; however, whilst it should remain a core principle, including it on the EPC could be a source of confusion for the average consumer.
Sava disagrees with the inclusion of both heating system and energy use metrics which could muddy the water for consumers as they likely will not – and should not be expected to – understand what they mean. Cost is far easier for consumers to understand in the context of their own homes.
Similarly, Sava strongly disagrees with the proposal to add a smart readiness metric to domestic EPCs as this metric would be impossible to define and could, therefore, further cloud the key messages of the EPC which should be based on clear, scientific facts.
In contrast, Sava strongly agrees that smart metering technologies should be incorporated into the energy performance assessment framework for both domestic and non-domestic buildings. Physical measurements have a major role to play in real-world performance, and heat loss measurements of homes are possible using smart meter data alone (known as ‘SMETER’ technology). SMETER technology is now an established technology, and it would be short-sighted to exclude it altogether. It has the potential to reduce the so-called performance gap, and smart metering in general is essential for the implementation of consumer-instigated Demand Side Management (DSM) going forward.
When should EPCs be required?
Should changes be made to the EPC validity period?
The current validity period for EPCs is 10 years – Sava believes this period should be reduced to 5 years. Whilst we neither agree nor disagree that changes to validity periods should only apply to new EPCs, to approach this sensibly Government could declare straight away that when some additional trigger point occurs – for instance, material improvements are made to the property such as replacing the heating system – a new EPC must be presented EPC (and will have a validity period of 5 years). This would allow a proportion of existing EPCs to remain valid, but over time ensure that the average validity period becomes shorter. This would clearly help to alleviate any DEA shortages during the changeover period.
A new EPC should be required when an existing one expires for private rented buildings – STRONGLY AGREE
Sava strongly agrees that a new EPC should be required when an existing one expires for private rented buildings. The private rented sector has the lowest average SAP of any sector and would therefore appear to be in the worst condition. Requiring a valid EPC at all times would enable the tenant to understand the impact on bills as well as pressure the landlord to make improvements.
As expressed in the previous section, Sava believes that Government should also consider mandating a new EPC when a material change to the property occurs (e.g. for all notifiable works under Building Regulations). This could also apply to owner-occupied homes at the time of sale if a material change has occurred, even if the EPC has not yet expired.
Short-term rental properties should have a valid EPC at the point of being let – STRONGLY AGREE
Sava believes an EPC should be required for all domestic properties, including short-term rental properties at the point of being let. Consumers are becoming increasingly interested in energy efficiency and running costs, and a poor EPC rating would clearly incentivise landlords to improve the property for the sake of their rental income.
EPC Data
Option to opt out EPC address level content from the Open Data should be retained – DISAGREE
Sava disagrees that homeowners should be allowed to opt-out of their EPC content being included in Open Data, as the EPC contains no personal data per se. Being able to search Open Data Communities (ODCs) for EPCs on neighbouring properties using an address search is useful to purchasers, owners of large housing stocks, landlords, tenants and researchers, and Sava sees no reason for a homeowner to opt out.
Managing EPC Quality
Accreditation Schemes should be given more responsibility for overseeing the training of energy assessors – STRONGLY DISAGREE
With so many reliant on the accuracy of EPCs, nobody can deny that the quality must be managed; however, Sava strongly disagrees that Accreditation Schemes should be given more responsibility for overseeing the training of energy assessors. Training and assessment of Domestic Energy Assessors (DEAs) must remain independent of the Accreditation Schemes.
This will ensure impartial assessment of competence – rather than training being tailored to meet scheme-specific requirements. Sava chose to cease operating its DEA Accreditation Scheme in 2016, but whilst we no longer run a scheme, we continue to monitor EPC results through our software and provide independent training with no scheme affiliation. As an Ofqual-regulated training provider, we ensure that learners meet nationally-defined knowledge and competence standards, regardless of which scheme they later join.
Our experience shows that assessors trained independently of Accreditation Schemes develop better property knowledge and a stronger grasp of EPC fundamentals, rather than just learning to meet scheme-specific audit requirements.
Further Suggestions
Within the consultation response, Sava made a number of suggestions to improve the accuracy and quality of energy assessments, the most important being:
Raise the qualification level for energy assessors
The current entry requirement for DEAs is an Ofqual Level 3 Certificate – equivalent to an A-Level. Given the technical demands of the role, the forthcoming complexity of the Home Energy Model (HEM) and the importance of accurate EPCs, we believe that the qualification should be raised to Level 4 or higher to reflect the expertise required. This would provide a deeper, more comprehensive understanding of energy assessment, covering advanced technical knowledge and real-world application, ensuring that assessors can handle complex scenarios with confidence.
Standardisation
Accreditation Scheme operating rules and audits should be standardised to improve assessment accuracy and to prevent fraud. Currently, schemes set their own audit rules, creating inconsistencies; one scheme may demand high evidence standards, while another may apply minimal checks.
What’s next for EPC reform in England and Wales?
The response window for the consultation closed on 26th February 2025 and leaves the government with much to consider. The industry now awaits the results, with any changes to EPCs currently expected to be introduced in the second half of 2026.
If your organisation is looking to better understand the energy performance of its housing stock, explore data-driven improvement strategies to reach Government targets or enhance the technical knowledge of your workforce, contact technology@sava.co.uk to discuss your requirements and learn more about our:
- Leading energy and carbon calculation software, Sava Intelligent Energy
- Analytics support and research capabilities
- Online Domestic Energy Assessor Training
- Suite of Level 4 qualifications for those working in the housing sector.
This article was written by Sava’s Special Project Director, Dr Neil Cutland.