Property Investors: Don’t Let EPC Uncertainty Stall Your Growth

Is fear of EPC changes stalling your property investment plans? Discover why now might be the perfect time to act - not wait.

At REALM 47, we recognise that the evolving regulatory landscape is causing uncertainty for both UK-based and overseas landlords and property investors. With proposed increases in EPC banding requirements, rising running costs, and the growing complexity around managing compliance, it’s more important than ever to stay informed and supported by experienced property investment agents.

There’s growing concern within the property investor community about how these changes will impact profitability, legal compliance, and overall strategy. That’s why we are here to cut through the noise and provide clear, expert guidance - helping you confidently navigate what lies ahead.

What Are the EPC Changes for Landlords and Investors?

The UK government has long signalled its intention to raise the minimum energy efficiency standards for privately rented properties, as part of its wider commitment to reducing carbon emissions and tackling climate change.

Currently, the minimum legal EPC rating for rental properties is Band E, but proposals have been tabled to raise this to Band C by 2028 for new tenancies - and potentially by 2030 for all existing tenancies. Originally planned for this year but the can has been kicked down the road a number of times with this initiative.

For landlords, property investors, and search agents sourcing investment opportunities in this climate, this means:

  • Properties with EPC ratings below C may require upgrades or face rental restrictions.

  • Non-compliance could lead to financial penalties and impact both capital value and market appeal.

  • There may be increased demand for energy-efficient homes, creating opportunities for well-informed investors.

  • Costs may be incurred for insulation, heating upgrades, improved glazing, or renewable technologies.

While the ambition is clear, many industry professionals are raising concerns about how this aligns with the current reality: limited rental supply, economic pressure on landlords, and rising material and labour costs.

Will EPC Regulations Actually Tighten – or Is This Another Delay?

Let’s address the key concern:

Is the government still planning to enforce EPC Band C as a requirement for rental properties?

While the intent to raise minimum standards remains on record, the political appetite to enforce it in the short term appears to be cooling:

Our assessment is that the proposed EPC Band C requirement — originally slated for 2025 — now appears increasingly likely to be delayed or softened. In short, decisive action may once again be deferred to avoid deepening the ongoing supply crisis. While the government’s long-term ambition to improve energy efficiency across the UK’s housing stock remains on record, the political will to enforce this mandate in the near term is clearly waning.

Against this backdrop, our Founder and Managing Director, Sara Newson, shares her perspective on what this shift means for landlords, investors, and the broader market:

“I suspect we’ll continue to see the government kick the can down the road when it comes to EPC reform. Not because it’s unimportant, but because it’s not urgent – not compared to their current legislative and fiscal priorities. The Renters Reform Bill is already laying the groundwork, quietly smoothing out some of the market distortions that tighter EPC rules would bring. Think: no rental bidding wars, capped increases – predictable responses to supply-demand imbalance.

But when the EPC changes do land – and they will – there are two areas I believe investors should be paying close attention to:

1. Spend Caps

We’ve already seen indications of a maximum investment threshold – say, £3,500 – beyond which landlords wouldn’t be expected to meet a ‘C’ rating. At first glance, that’s a relief. But a word of caution: investing just enough to dodge penalties might work in the short term, but failing to reach ‘C’ could undermine your asset’s long-term viability. It may impact refinancing, lettings, resale value, and even tenant appeal. In other words: short-term saving, long-term cost.

2. Grants & Incentives

Until the government can offer realistic grants to support the cost of upgrades, they’ll hesitate to force compliance. They know rental stock is under strain – and another wave of regulation risks pushing more landlords out of the market. That’s a political risk they’ll avoid until they have a safety net in place – and funding to back it.

The broader message? Be strategic. If you’re refurbishing, build EPC ‘C’ into your scope from the outset. If you’re not, understand what it would take to get there – and how to maximise improvements within a £3,500 spend. But hold off on action unless necessary – this is one of those rare moments in property where ‘wait and see’ is genuinely a smart move.”

If the Landlord Covers Utilities – Should Exemptions Apply?

At REALM 47, we’ve been exploring this important consideration as part of our wider analysis into the practical impact of EPC reform on different property strategies, including student pods and professional HMOs.

If a landlord is covering all utility costs - as is common in HMOs and rent-to-rent models - should they be subject to the same EPC requirements as landlords where tenants pay the bills?

This raises a larger question: is the legislation truly focused on protecting tenants from high energy bills, or is it purely about reducing the UK’s carbon footprint?

Clarity on this will be essential in shaping fair and forward-looking policy - and we’ll continue to monitor developments closely on behalf of our clients.

Achieving EPC Band C: It’s Often Easier Than You Think

Achieving EPC Band C: Often Simpler Than Expected

While some properties - particularly older or poorly insulated stock - may require more substantial upgrades to meet Band C standards, the reality is that many can achieve compliance with relatively modest improvements.

To illustrate this, here are two example scenarios based on typical upgrade strategies we regularly see in the market. These are not specific properties, but reflect common outcomes achievable for landlords and investors working with experienced professionals:

Example 1 – 3-Bed Mid-Terrace, Hull

  • Original EPC Rating: D

  • Upgrades: LED lighting installation, additional loft insulation, and replacement of a single inefficient wall heater

  • Estimated Cost: £1,200

  • Post-Upgrade EPC Rating: C

Example 2 – Professional HMO (Student Pod Format), Manchester

  • Original EPC Rating: E

  • Upgrades: Smart electric radiators, improved draft-proofing, and selective glazing upgrades in high-heat-loss areas

  • Estimated Cost: £3,500

  • Post-Upgrade EPC Rating: C

In both illustrative cases, the upgrades were scheduled during natural void periods, reducing disruption and avoiding rent loss - a key strategy for maintaining cash flow.

For property investors working with trusted property sourcing agents, improvements like these can be efficiently identified, budgeted, and implemented - turning potential compliance risk into long-term asset value.

A Note on HMOs, Void Risk & Property Management

As an experienced property investment agency and consultancy with a strong track record in HMOs, we understand first-hand the additional complexities these strategies can bring - particularly around utilities, maintenance, and tenant management.

That’s why at REALM 47, we collaborate with a network of trusted lettings and property management specialists to ensure our clients receive consistent, high-quality support across their portfolios. Whether it’s a professional HMO or a single-let property, we ensure the right expertise is in place to handle the day-to-day operations with efficiency and care.

Whether you’re new to property or scaling a portfolio, our goal is to remove friction and provide premium, proactive support at every stage.

Looking for Expert Support with Your Property Investments?

Whether you’re assessing your current property’s EPC potential, exploring new acquisitions, or seeking a trusted property investment agency to uncover the best opportunities, REALM 47 is here to guide you every step of the way.

We specialise in hands-off investment strategies, access to exclusive off-market deals, and expert insights that will help you to achieve your investment goals.

As industry leaders, we help our clients navigate the complexities of changing legislation and market dynamics, providing the support and guidance needed to make informed, confident decisions for the future of their property portfolios.

Get in touch today for personalised advice and strategic support - and partner with REALM 47 to confidently build a future-proof property portfolio.

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