EPC C for Landlords — What London Properties Need and How to Get There

The proposed EPC C minimum standard for rental properties has driven significant concern among London landlords. This guide explains what properties need upgrading, which measures are most cost-effective, and the expected timeline.
The EPC C Requirement for Landlords
The Renters' Rights Bill and associated energy efficiency proposals create a minimum EPC C standard for privately rented properties in England. Under the proposed legislation, landlords will be required to upgrade properties to EPC C before granting new tenancies, with existing tenancies following on a separate timeline.
The current minimum standard (EPC E) has been in place since 2020 and affects only very low-rated properties. The proposed EPC C requirement is a significant uplift that affects a large proportion of London rental stock — approximately 38% of private rented properties in London are currently rated D or below.
Which London Properties Are Most Likely to Need Upgrading?
Properties most likely to be below EPC C:
- Pre-1940s terraces and semis with solid brick walls — solid wall insulation is expensive and the SAP model credits it significantly, but it is a major undertaking
- Properties with old gas boilers (10+ years) — an A-rated condensing boiler is assumed by SAP; old inefficient boilers significantly reduce the score
- Properties with no loft insulation or insufficient loft insulation — loft insulation is the cheapest and most impactful measure for houses
- Properties with electric storage heaters or direct electric heating — electricity's high cost per unit reduces EPC scores severely
- Flats with poor fabric insulation scores — particularly ground and top-floor flats with uninsulated floors or roofs
Most Cost-Effective Improvements for London Properties
| Improvement | Typical SAP Points Gained | Typical Cost |
|---|---|---|
| Loft insulation (houses) | 3-8 points | £300-600 |
| Cavity wall insulation | 4-8 points | £500-900 |
| Boiler replacement (old to A-rated condensing) | 5-12 points | £2,000-3,500 |
| Smart thermostat + TRVs | 1-3 points | £300-600 |
| LED lighting throughout | 1-3 points | £150-400 |
| Double/secondary glazing | 3-6 points | £3,000-8,000 |
| External wall insulation (solid walls) | 10-20 points | £8,000-20,000 |
Exemptions
Proposed exemptions include properties where:
- The cost of reaching EPC C exceeds a cost cap (likely £10,000-15,000 per property)
- Listed buildings where improvements would unacceptably alter character
- Planning constraints prevent external insulation
- The property is a leasehold flat and the freeholder refuses consent for works
Landlords who believe their property should be exempt must register the exemption on the PRS Exemptions Register — the exemption is not self-certifying.
Frequently asked questions
When will EPC C be required for rental properties?
The current proposal is for EPC C to be required for new tenancies from 2025, with existing tenancies following by 2028. However, these dates have been revised multiple times — check current MHCLG guidance for the latest timeline.
What is the cheapest way to improve EPC rating for a London rental?
For houses: loft insulation (£300-600, high SAP impact). For all properties: replacing an old boiler with a new A-rated condensing boiler (£2,000-3,500) gives the biggest single SAP improvement per £ spent. LED lighting and smart controls are cheap but have smaller impact.
Can I be exempt from EPC C requirements if my property is a Victorian terrace?
Potentially — if reaching EPC C would require solid wall insulation and the total cost exceeds the cost cap (£10,000-15,000). You must register the exemption on the national PRS Exemptions Register with supporting evidence of the costs involved.
Does replacing a boiler improve EPC rating?
Yes significantly. Replacing an old boiler (pre-2005, less than A-rated) with a modern A-rated condensing boiler can add 5-12 SAP points. This is one of the most impactful single measures for properties currently rated D or E.