Asking a Landlord for Energy Improvements

A tenant cannot install insulation, replace a boiler or fit new glazing without the owner's agreement: guidance is direct that tenants should speak to the landlord first and should not make any changes without the landlord's consent¹. What a tenant can do is make a documented request, backed by the property's Energy Performance Certificate and its recommendation report, and by the grant schemes that will pay for the work. Where funding covers the cost, the position is stronger than many renters assume: landlords must not unreasonably refuse tenant requests for energy efficiency improvements that can be funded at no cost to the landlord, for example through grants or third-party funding².

The legal floor in England and Wales is band E. No domestic private rented property with a rating below E may be let, and a landlord must not continue letting a property already tenanted if it is rated F or G, unless a valid exemption is registered². A property rated F or G must be improved to at least an E before it can be rented out³. That rule is the single most useful lever a tenant in a cold, poorly insulated home has, because it turns a request into a compliance question for the landlord rather than a favour.

Funding is the other half of the argument. The Energy Company Obligation, now in its fourth iteration as ECO4, requires medium and large energy suppliers to support energy efficiency improvements for eligible households, covering insulation, boilers and central heating, and solar and renewable energy technologies⁴. Tenants in privately rented homes can apply, but the owner's permission is required, and eligibility for private rentals is usually limited to properties rated E, F or G⁵.

What the EPC tells you before you ask

An EPC must be provided when a building is advertised for sale or for let to a new tenant, and in Scotland it is also required on completion of construction of a new building⁸. Where a property is being rented, providing the certificate to the potential tenant is the landlord's responsibility⁶. So a copy should already be in the tenancy paperwork; if it is not, that is itself a compliance failure, carrying a penalty charge notice of £500 or more for failing to provide EPCs or omitting the rating when advertising⁹.

The certificate is more than a coloured band. The assessment records the dwelling type, floor area, construction type, insulation, heating, ventilation and lighting¹⁰. Each EPC comes with a report setting out cost-effective measures the occupier or owner can take to improve efficiency and the rating, such as low energy bulbs or upgrading insulation¹¹, and the recommendation report is a required part of the certificate's content¹².

Reading it before raising anything serves three purposes. It shows what an independent assessor has already identified, so a request is not a matter of opinion. It shows the current band, which decides whether the minimum standard bites and whether grant routes are open. And it is the document schemes themselves use: for the Boiler Upgrade Scheme, whether insulation requirements are met is judged through information on the EPC¹³. Under the Domestic Renewable Heat Incentive the point was sharper still: where an EPC recommended loft or cavity wall insulation, the insulation had to be installed and a new EPC obtained that no longer carried those recommendations, unless an insulation exemption applied with evidence¹⁴.

One limit to be clear about: implementing the listed measures is not in itself mandatory⁹. The recommendations are advice. It is the minimum standard, not the recommendation report, that creates the duty.

Why band E matters for renters

The minimum standard for domestic private rented property in England and Wales is an EPC rating of E or above², set by the 2018 Minimum Level of Energy Efficiency standard¹⁵. Two separate prohibitions follow. Landlords may not grant a tenancy to new or existing tenants where the rating is band F or G, and they must not continue letting a property that is already let if it falls in those bands, unless an exemption applies². Guidance for landlords still letting an F or G rated property is that they must act or register an applicable exemption¹⁵. The exemptions register records those properties that are permitted to be let below an EPC rating of E or above¹⁶.

Where a measure counts as a "relevant energy efficiency improvement" is governed by cost. A recommended measure qualifies where third-party funding covers the full cost, or where the cost is £3,500 or less including VAT, or where a combination of landlord self-funding and third-party funding comes to £3,500 or less including VAT². That figure is why grant availability changes the conversation: funding moves a measure inside the landlord's obligation rather than leaving it a discretionary spend.

The standard is set to rise. A 2025 consultation update confirmed a dual-metric standard, with a fabric performance standard first, followed by landlord discretion to meet either a heating system standard or a smart readiness standard¹⁷. From 1 October 2030, landlords will be required to ensure properties meet a minimum score of EPC C against the fabric performance metric and either the heating system or smart readiness metric¹⁸, consistent with the stated policy of preventing landlords from renting out homes under an EPC rating of C or equivalent by 2030¹⁹.

In Scotland, EPC reform brings a new Property Report setting out potential improvement measures ranked by lowest installation cost and greatest heat saved, plus alternative heating systems with their potential installation and running costs²⁰. The regulations require a domestic property report to carry an indicator of estimated emissions, an indicator of estimated energy used, information on what alternative main heating system could be installed, the estimated emissions from such systems, and estimated installation and operation costs²¹. For a tenant, that is a far more useful document to hand a landlord than a single letter grade.

How to read the recommendations report

The recommendation report is designed to be read in order. In the reformed Scottish format the ranking logic is explicit: measures are set out by lowest installation cost and greatest heat saved²⁰. That ordering matters for a request, because the measures at the top are the ones most likely to sit within the £3,500 cap or to be fully covered by a grant².

Three questions are worth asking of each listed measure:

• Is it fabric or is it heating? Fabric measures (loft, cavity and solid wall insulation, draughtproofing) are what the 2030 dual-metric standard puts first¹⁷.
• Does it need building control sign-off? Making significant changes to thermal elements (walls, roofs or floors) would normally require Building Regulations approval and require the thermal insulation of the element to be upgraded to a reasonable standard²². Installing or replacing a heating system is also covered work²³.
• Is the certificate current? An EPC is valid for a maximum of ten years or until another EPC is commissioned for the same building, whichever comes sooner⁶. A report drawn up before earlier works may list measures already done.

Where a landlord later claims all relevant improvements have been made, they may rely on information contained within the property's EPC, and if relying on a separate report, a copy of that report must be uploaded to the register¹⁶. That means the paperwork a tenant reads is the same paperwork an enforcement officer would look at.

Insulation, heating and ventilation: what landlords are most often asked for

Northern Ireland guidance sets out a plain list of what a landlord should do in a property rented to tenants: make sure roof spaces are insulated; replace draughty, ill-fitting windows and doors; draughtproof external doors and windows, but not rooms containing an open-flue gas appliance; insulate exposed water pipes; and fit the hot water tank with a good quality insulation jacket²⁴. It also states that before letting a house to tenants, the landlord should ask a qualified surveyor to check the condition of the property²⁴.

In Wales, fitness for human habitation guidance addresses heat hazards through controllable heating systems, and sets the response standard for repairs: once the landlord is aware of the need for repairs, they must be carried out in a reasonable time and to a reasonable standard²⁵. That is a different legal route from the EPC standard, and it is often the more immediate one for a home that is cold because the heating does not work rather than because the walls are thin. Both can be raised in the same letter.

Where a solid masonry wall is being lined internally, one recognised approach is to maintain a cavity between the masonry wall and form a separate insulated layer²⁷. This is the kind of detail that decides whether a measure is straightforward or specialised, and it is one reason landlords sometimes push back on wall insulation specifically.

Who pays: ECO4, the Warm Homes: Local Grant and the national schemes

ECO funding pays for energy efficiency measures such as heating improvements and insulation to be installed²⁸, and qualifying householders can access funding to upgrade heating or improve home insulation through the obligation placed on suppliers²⁹. Supported heating work under ECO4 can include installing central heating where there is no boiler or radiators, replacing storage heaters or coal fires with gas central heating, replacing a non-condensing combi boiler with a modern combi boiler, and replacing a heat-only boiler with a modern combi boiler³⁰.

For private rentals the rules tighten. Where a tenant rents from a private landlord, the house must have an energy efficiency rating of E, F or G to be eligible, and the owner's permission is required⁵. Private landlords can only access ECO to replace an old heating system with a renewable heating system if the existing EPC is an E, F or G³⁰. Eligible applicants are described as homeowners, private tenants or landlords, and landlords may be asked to contribute towards the costs of installed measures depending on the circumstances of the tenant at the qualifying property³¹. An upgrade to a non-renewable heating system is eligible in the private rented sector only where one of a listed set of measures, such as solid wall insulation, is installed as part of the same project, and where the measure does not replace a boiler, electric heating system or electric storage heater³².

The Warm Homes: Local Grant provides free or subsidised home improvements including insulation upgrades, heat-pump installations, solar panels, ventilation and damp-prevention measures⁷. Privately rented properties with an EPC rating of band D or E are within scope in some delivery areas³³. Landlords can apply for multiple eligible homes but receive full funding for only one, and must pay half the upgrade costs for any eligible homes upgraded after the first⁷; a separate delivery page states the same 50% minimum contribution for additional properties with no limit on the number upgraded³⁴. One condition is worth quoting to a landlord who worries about the effect on rent:

Elsewhere in the UK the shape differs. In Wales, Nest offers free, impartial advice and, for eligible households, a package of free home energy efficiency improvements such as a new boiler, central heating or insulation³⁶. In Northern Ireland, a consultation on the Affordable Warmth successor scheme proposes that tenants who privately rent may apply with the agreement of the landlord, where the landlord agrees to pay half the cost of the energy upgrades³⁷. The Green Deal route offered home owners, landlords and tenants loans for improvements such as adding insulation or solar panels³⁸. Where a heat pump is the measure, the installer applies for the grant on behalf of the household through Ofgem³⁹.

Making the request

The practical sequence is a matter of evidence and order, not persuasion.

1. Obtain the current EPC and recommendation report, and check the date against the ten-year validity limit⁶.
2. Identify which listed measures are fabric measures and which are heating, and note the current band against the band E minimum².
3. Check local scheme eligibility for the property and household, since ECO4 and Flex routes are administered locally and accept private tenants as applicants³¹.
4. Put the request in writing, naming the specific measures from the recommendation report, the funding route, and any landlord contribution the scheme expects³¹.
5. Keep the dated correspondence. Repairs must be carried out in a reasonable time once the landlord is aware of the need²⁵, so the date the landlord became aware is a material fact.

Consent has procedural consequences beyond the yes or no. For loft insulation under ECO4 and under the Great British Insulation Scheme, the installer, operative or assessor, and either the occupier or landlord, must sign the pre-existing loft declaration regarding the presence of loft insulation in the property⁴¹. Work on thermal elements will normally need Building Regulations approval²², and installing or replacing a heating system is notifiable work²³. Those are landlord obligations, but a tenant who knows they exist can anticipate the objection that the work is complicated.

Tenants who want to understand which changes are theirs to make at all, including reversible ones, will find the wider position in renting and home energy and in energy independence when you rent or live in a flat. The landlord's side of the funding question is set out in funding energy upgrades as a landlord.

Where to get free help

Citizens Advice offers information and support on struggling to pay bills, problems with an energy supplier or energy supply, saving energy at home and getting a better energy deal⁴³. Its free consumer service can help people in England and Wales with problems with energy bills or supply⁴⁴.

The Citizens Advice consumer helpline for England and Wales is 0808 223 1133, open Monday to Friday, 9am to 5pm, with 0808 223 1144 for service in Welsh¹. In England there is also a separate number, 0808 144 8844².

Local schemes add practical routes. The Local Energy Advice Programme arranges a free telephone advice service covering benefits, money and bill problems, and refers households for further energy efficiency improvements such as loft or cavity wall insulation and, in some instances, a new boiler⁴⁷. In Northern Ireland, advice on EPCs, or where an EPC has not been made available to a new tenant, comes from the local district council building control team¹¹.

Households facing cold homes for reasons of income rather than tenure may also want fuel poverty in the UK and help for low-income households in England.

When a landlord can refuse, and what happens next

Refusal is not automatically unlawful, but it is bounded. The clearest constraint is that landlords must not unreasonably refuse tenant requests for energy efficiency improvements where they can be funded at no cost to the landlord, for example through grants or third-party funding².

Against that, the exemptions framework gives landlords specific, evidenced grounds for remaining below band E. These include: all relevant improvements made but the property remains below E; the cost of relevant improvements exceeding the spending cap; no improvements being possible; expert written advice that wall insulation would harm the fabric or structure; third-party consent required and refused after reasonable attempts; a RICS registered valuer's report that improvements would reduce market value by more than 5%; the property being already let when the landlord purchased an interest; and sudden landlord circumstances such as the insolvency of a tenant where the landlord was guarantor².

Each carries an evidence burden. For the wall insulation ground, the landlord must upload to the register a copy of the written opinion of the relevant expert stating that the property cannot be improved to an EPC E rating because a recommended wall insulation measure would have a negative impact on the property or the building of which it is part¹⁶. For third-party consent, the landlord must demonstrate that consent for a relevant measure was required and sought, and was refused, or granted subject to a condition the landlord was not reasonably able to comply with¹⁶.

A tenant's own refusal also has legal weight. Regulation 31 provides that the letting restriction does not apply at any time when the landlord has, within the preceding five years, been unable to raise the energy performance indicator to the minimum level because a tenant refused consent to a relevant energy efficiency improvement, or third-party consent was refused or granted subject to a condition the landlord cannot reasonably comply with⁴⁸. Importantly, where a landlord has relied on that exemption in relation to a particular tenant's refusal, the landlord may no longer rely on it once that tenant's tenancy has come to an end⁴⁸.

Where a landlord simply does not respond, the routes are the exemptions register and local enforcement, the repairs standard in the relevant nation, and the advice services above. Failing to provide EPC information can attract a penalty charge notice of £500 or more¹.

What this changes, and what it does not

Energy improvements secured through a landlord shift a household's position meaningfully: insulation and a working, controllable heating system cut the amount of gas and electricity the home has to buy, and reduce exposure to price movements. Solar and renewable technologies are within ECO4's funded scope⁴, and the Warm Homes: Local Grant can cover heat pumps, solar panels and ventilation⁷.

The dependence that remains is structural. The asset belongs to the landlord, not the tenant: the panels, the insulation and the heat pump stay with the property at the end of the tenancy. Consent remains the gate for every measure¹. Grant availability depends on scheme rules that change, on the property's EPC band⁵, and in some schemes on a landlord contribution the landlord may decline to make³¹. And the works themselves sit inside Building Regulations approval and, for grant-funded heat pumps, an installer-led application process through Ofgem³⁹. Independence here is real but partial: a tenant can reduce what the home consumes, and can hold a landlord to a legal minimum, but cannot own the means of producing or retaining that energy.