The National Insulation Association (NIA), which represents insulation installers, system certificate holders and manufacturers, stated in a consultation response that the UK Government had abandoned the amendments to MEES that it had proposed in its 2020 consultation on improving the energy performance of privately rented homes1. The response, published on 17 November 2023, was submitted to the Welsh Government's consultation on its Heat Strategy for Wales, which closed on 8 November 20231.
The NIA said the abandonment was signalled by the Prime Minister's speech in September 2023, and asked the Welsh Government to adopt the proposals in Wales instead1. The three proposals it listed were:
| Proposal | Detail |
|---|---|
| Minimum EPC rating | Rising from E to C before a property can be rented out, reached by 2025 for new tenancies and 2028 for existing tenancies |
| Cost cap | Rising from £3,000 to £10,000 per property |
| Fabric first | Investment in the fabric of the building, such as loft, cavity or external wall insulation and double windows and doors, before heating system upgrades |
"Although it has since abandoned these commitments, as signalled by the Prime Minister's speech in September 2023, the NIA would like to see the Welsh Government commit to adopting these proposals in Wales."
The NIA also cited the BRE Group's 2023 report on the Cost of Poor Housing in England by Tenure, which estimated the average cost of mitigating excess cold in the private rented sector at £6,835 per home, below the proposed £10,000 landlord cap. It gave comparable figures of £6,690 for owner occupiers and £3,800 for social homes, and said the NHS spends over £540 million a year treating people affected by living in the worst performing properties in England1. On the effect of efficiency improvements, it cited Energy & Climate Intelligence Unit research that raising a property's EPC by one SAP band from D to C can cut space heating demand by 20%1.
The response also covered skills and standards. It cited Construction Industry Training Board modelling that an additional 12,000 full-time equivalent construction jobs will be required in Wales by 2028, and a 2021 report by the Future Generations Commissioner for Wales estimating 26,500 new jobs could be created by 2030 through a long-term strategy to decarbonise housing in Wales1. It welcomed Welsh Government plans to use PAS 2035/2030 standards in all its retrofit programmes, while noting that PAS compliance can be costly, especially for small businesses1.
Why it matters for households
For private tenants in England, the practical position is that the higher EPC C requirement and the larger landlord cost cap described here were proposed but not enacted, so no date has been set for either. The NIA's account is the only one given here; the UK Government's own statement on the status of the amendments is not reported in these sources. Households in the private rented sector therefore face no confirmed timetable for the standard described, and the cost of any improvement work remains a matter for landlords and tenants to settle under existing rules.
The wider point concerns insulation and how it interacts with heating. The NIA argues that a property can only be heated at low flow temperatures, where heat pumps run at higher efficiency, if it has high thermal efficiency, and that installing low-carbon heating before insulation can leave a system oversized for the home's reduced heat demand, with unnecessarily high capital and running costs1. That is the case for treating the building fabric as the first step rather than the last.
What happens next
The Welsh Government consultation closed on 8 November 20231. The NIA's response asks the Welsh Government to adopt the MEES proposals in Wales and to support businesses with the cost of PAS compliance1. No response from the Welsh Government to the consultation is reported in these sources, and no date has been given for publication of its position.