Which? published a policy paper on 29 April 2024 calling on the UK and Scottish governments to reform Energy Performance Certificates (EPCs) across three areas: better information and advice, improved accessibility, and improved accuracy and reliability1. The consumer body said EPCs were introduced in 2007 and that reform efforts have failed to keep pace with the change required1.
The paper cites a government survey showing that only 36% of the UK population know or have a sense of what their EPC rating is, and that only 29% of those aware of their EPC said they had seen the section with advice on how to improve their rating1. Which? also reported that a Google search on 29 February 2024 revealed three companies advertising EPCs from £35, and that assessments are generally available from £35 to £1001.
On the case for change, the paper states that home heating accounts for 17% of UK carbon emissions and that nearly 90% of households in the UK currently use fossil fuel heating systems1. It notes that the UK government's Heat in Buildings strategy set an ambition for all homes in the UK to be EPC C by 2035, with a target of 2030 for fuel poor households, and that the Scottish government proposes to place a requirement on households in Scotland to reach EPC C or equivalent by 20331. The UK government recently dropped proposals for properties in the Private Rental Sector to meet EPC C by 2028, according to the paper1.
Which? set out its three areas for action as follows1:
"we are calling on the UK and Scottish governments to take action in the following three areas"
The paper's recommendations include giving EPCs more than one headline metric, such as energy use, cost, heating system and environmental impact; linking EPCs to a Building Passport or Log Book; supporting apps and online services that present EPC data more accessibly; maintaining non-digital formats; reviewing training requirements for Domestic Energy Assessors and improving auditing; requiring every property sold or let to have an EPC less than five years old; and including location data in the new Home Energy Model software that will generate EPC ratings1.
On accuracy, the paper notes that the 2016 review increased auditing to 3% but included random, smart and follow on audits, and that smart or risk-based auditing was introduced in 2016, with the criteria for risk-based reviews regularly reviewed1. It also notes differences in what certificates show: in England and Wales an EPC gives an estimation of the annual energy costs for the property, while in Scotland the EPC gives an estimation of the energy costs for the property for three years1. The rating is measured on a scale divided into 100 units and between five ratings marked A to G1. The paper states that the energy bill for a home with an EPC of D is likely to be £300 more than for a household with an EPC of C1.
Why it matters for households
An EPC is the document a household meets when buying or renting a home, when checking what improvements a property needs, and when applying for grants and financial products such as green mortgages and loans1. It is also used to verify that rented properties meet the Minimum Energy Efficiency Standard of EPC E1. If the rating, the cost estimate or the improvement advice is wrong or hard to read, the practical effect falls on the household relying on it.
The paper's figures point to a gap between the role EPCs play in policy and what households take from them. With home heating at 17% of UK carbon emissions and nearly 90% of households on fossil fuel heating, the certificate is one of the few documents that could tell a household what its heating system costs, when it may need replacing and what low-carbon options suit the building1. Which? says awareness of the coming fossil fuel heating bans and their implications for households is very low1.
The paper also notes that an EPC does not reflect a property's actual performance, because it is based on assumptions about construction, insulation and heating installation, and does not account for how many people live in a home or how they use heating and hot water1. Two identical-looking ratings can therefore sit alongside different real bills.
What happens next
The paper points to a UK government EPC Action Plan launched in September 2020, based on a consultation in 2018, and a consultation on EPC reform in Scotland that closed in October 20231. It states that the UK government is committed to ban the installation of new gas or oil boilers from 2035, and that the Scottish government is also proposing an absolute ban on fossil fuel heating by 20451. Which? says the vast majority of households will need to start switching to low-carbon heating from 2035 in England and Wales and 2028 in Scotland1. No government response to the paper has been reported.