EPC C by 2028: what landlords and homeowners need to do now

The headline version is: from 2028, you won’t be able to let a new tenancy on a property below EPC C. From 2030, the same rule extends to existing tenancies. That’s the proposal on the table from DESNZ as of 2026. It’s not yet final regulation, but it’s firm enough that lenders and letting agents are already pricing it in.

The problem: 61% of UK private-rented stock currently sits at D or below (English Housing Survey 2023). Millions of homes, two years of runway. Some of those properties will get exemptions. Some will be sold. But most landlords need a plan, and most landlords don’t have one yet.

This post gives you the plan.

The rules, briefly

Spending cap: £10,000 per property. If the cheapest compliant measure stack costs more than that, you can register a high-cost exemption on the PRS Exemptions Register and let anyway (5-year validity). You must register the exemption — simply not doing the work is an unlawful let, and Trading Standards are empowered to fine up to £30,000 per breach.

Which properties are most at risk

Fastest rule of thumb for whether a property will struggle:

• Built pre-1919 — almost certainly has solid walls, which are the single most expensive fabric measure.
• Off-gas (oil, LPG, electric) — heating-system carbon factor tanks your SAP score even with decent fabric.
• No cavity or thin loft — both are cheap to fix but both are SAP-score anchors if unfixed.

If your property ticks two or three of these, budget for £8–12k to reach C. If it ticks all four and is detached, realistically budget £15k+ and plan for the exemption route.

The measure stack, cheapest-first

This is the order we use in our MEES compliance calculator. Each measure stacks the SAP-point lift onto the one before, so you walk it in order and stop when you hit C.

1. Loft insulation top-up to 270mm — ~£450. +2 SAP points. If your loft is under 100mm, do this first, always.
2. Full LED lighting retrofit — ~£250. +1 SAP point. Near-zero payback on its own but always in the stack for the cheap SAP lift.
3. TRVs + smart thermostat — ~£400. +1 SAP point. Only applies if you have wet heating (gas/oil/LPG/heat pump).
4. Cavity wall insulation — ~£1,200. +6 SAP points. Enormous ROI for properties built 1930–1995 with uninsulated cavity walls.
5. Modern double glazing — ~£6,500. +4 SAP points. Only counts if you currently have single glazing or poor pre-2002 double glazing.
6. Air-source heat pump — ~£11,000 before grant, ~£3,500 after the £7,500 BUS grant. +10 SAP points. The biggest single SAP lift available and grant-eligible — always consider it if your stack exceeds cavity + loft + glazing.
7. Solid wall insulation — ~£12,000. +12 SAP points. Last-resort for properties that can’t reach C any other way; internal and external variants both qualify.

Most landlords who need to act end up with stacks 1+2+3+4 (£2,300, +10 SAP), which lifts a typical D into C. Poorer-starting properties add 6 (and claim BUS). Worst cases add 7 and usually hit the £10k cap.

Don’t forget to stack grants

• Boiler Upgrade Scheme: £7,500 off a heat pump in England/Wales. Small non-domestic (including FHLs) also qualifies. Check eligibility.
• ECO4: fabric measures (insulation, heating upgrades) for tenants on qualifying benefits. Your tenant’s eligibility, not yours. Worth checking — can knock £1,500+ off the net bill.
• Capital allowances: most retrofit spend on a let property qualifies under the Annual Investment Allowance. At a 20% marginal tax rate that’s another 20% off the net cost.

What this looks like for specific landlord types

Single-property landlord, 1960s semi at EPC D: typically £1,200–£2,500 in the stack (loft top-up + LED + TRVs + cavity fill). Tenant pays lower bills, property hits C, no drama. This is the easiest path and probably the one to start costing today.

Portfolio landlord with mixed stock: the top-priority property is the one closest to a new-tenancy deadline. For a property falling void in late 2027, plan and quote the stack now — installers book up.

Holiday-let operator (FHL): your property might be on commercial EPC rules (NDEPC), which currently have an E floor. C-by-2028 for commercial is also mooted but less certain. Comfort-premium booking uplift makes many FHL retrofits pay back even without the compliance angle. See the dedicated FHL calculator.

Homeowner not letting: MEES doesn’t apply to you — but reaching B unlocks a 0.10–0.25% green mortgage rate discount. On a £250k balance that’s £250–£625/year, every year of your fix. Often pays a fabric upgrade on its own.

What to do this month

1. Pull your EPC from the EPC Register — it’s free.
2. Run the property through our MEES compliance calculator (or the homeowner EPC variant if you live in it). Five minutes.
3. If the stack is under £5k and clears C: get quotes from a TrustMark-registered installer. Lead times are 6–12 weeks for most measures, longer for heat pumps.
4. If the stack is £10k+: register a high-cost exemption on the PRS Register as soon as the deadline date is announced for your tenancy type. Don’t wait until the deadline.

The cheapest time to fix this was five years ago. The second-cheapest time is now, before your peers start bidding up installer capacity in 2027.