Do you have an opinion on how the assessment of energy performance of buildings could be better? The Government is asking for your views on its changes to the Energy Performance of Buildings (England and Wales) Regulations 2012 (EPB Regulations).

Emma Reilly explains the consultation and how you can participate.

What are the EPB Regulations?

Currently the EPB Regulations require:

• Residential and commercial properties must have an Energy Performance Certificate (EPC) when they are sold, rented or leased
• Buildings over 250 square metres that are occupied by a public authority must display a Display Energy Certificate (DEC)
• Air conditioning units of over 12kW must have an Air-Conditioning Inspection Report (AICR)
• EPCs, DECs and AICRs are registered on the EPB Register

What might be changing?

The Government is currently asking for industry views on changes to the EPB Regulations. The consultation closes on 26 February 2025 and the proposals include:

Reducing the validity period for new EPCs

An EPC currently lasts for ten years and is required when a property is sold or leased.

The Government wants your views on whether a shorter period could help property owners better identify how to improve their buildings and allow changes to properties to be captured sooner.

When an EPC should be obtained

EPCs must be commissioned before a property is marketed. There is a 28-day period where the property can be marketed while a certificate is produced.

The Government thinks the EPC market has become more efficient at providing certificates and therefore a building should not be marketed without an EPC.

The time to produce an EPC depends on property size, location and assessor availability. Removing the 28 day period could disadvantage property owners where an EPC will take some time to obtain.

Heritage buildings

Currently some heritage buildings are not required to have an EPC.

The Government is proposing that all heritage buildings should have an EPC and that particular EPC recommendations are developed for these buildings. It notes that even if an EPC is required, owners could often avoid making energy efficiency changes due to the exemptions within the minimum energy efficiency standard (MEES) regime.

Historic England’s 2022 case studies identified flaws with the current EPC system for historic buildings, including that current EPC recommendations to improve energy efficiency are often inaccurate and misleading on cost and process.

The Government recognises that some of the generic EPC recommendations are not appropriate for heritage buildings and said it will set up an industry group to work on improving them. It said it will consider making changes to the underlying calculation methodologies.

An alternative approach could be to first change the recommendations system and calculation methodologies. If the changes prove effective, the Government can then consider in consultation with bodies such as Historic England whether it would be useful to impose EPC requirements on all heritage buildings. A more cautious approach such as this could limit risk exposing more heritage building owners to unanticipated and unnecessary costs in case there are still flaws in the system.

Changing EPC metrics for domestic buildings

The current EPC metric for domestic buildings is the Energy Efficiency Rating (EER), which is calculated using modelled energy costs per square metre. This is expressed as an A-G rating.

The Government want your views on whether this metric is right as it can be impacted by the fluctuation in fuel prices a factor which is beyond a building owner’s control. It has proposed four additional metrics – fabric performance, heating system, smart readiness and energy cost.

How to respond

The consultation is open until 26 February 2025, the questions are available here.

The Government have set up a Citizen Space for online survey responses.

You can also send an email response to: energyperformanceofbuildingsregulations@communities.gov.uk

If you have questions about participating in this consultation, EPBs, EPCs or whether you are in compliance with the current regulations, please do not hesitate to get in touch with Emma Reilly on EmmaReilly@schofieldsweeney.co.uk.