The Energy Saving Trust has published its response to the UK Government's consultation on improving the energy efficiency of socially rented homes in England, originally published on 10 September 20251. The response addresses the proposed minimum energy efficiency standard for the social rented sector at EPC C, the metrics landlords would use to demonstrate compliance, and the exemptions and cost caps that would apply1.
The Trust supports the introduction of a minimum energy efficiency standard for the social rented sector for the first time at EPC C, and agrees with the Government's preferred approach of requiring landlords to meet the fabric energy performance metric first, before secondary metrics1. It disagrees, however, with allowing landlords a choice between the heating system metric and the smart readiness metric, recommending that only the heating system metric be available for a secondary standard1. On the proposed compliance date of 1 April 2030, the Trust agrees with the timelines but states the dates are the latest the standards should come into force and should not be delayed1.
"We think that the cost cap for the SRS should be set at £15,000 to align with what was proposed in the recent PRS MEES consultation"
On exemptions, the Trust agrees with a time-limited spend exemption in principle but disagrees with the proposed 10-year duration from 1 April 2030, proposing instead that it be reduced to five years1. It also recommends that the cost cap increase in line with inflation, and that grant funding received by tenants in fuel poverty, such as through the Warm Homes: Social Housing Fund, should not count towards a landlord's contribution to the cap1. The Trust notes that 44 per cent of social rented sector homes are flats, and that meeting the standard in mixed tenure blocks could be challenging where measures can only sensibly be applied at whole-block level1. It also states that the current EPC framework is not seen as fit for purpose to drive improvements in energy efficiency and low carbon heating1.
| Proposal | Energy Saving Trust position |
|---|---|
| Minimum standard at EPC C | Support1 |
| Fabric metric first, then secondary | Support1 |
| Choice of heating system or smart readiness metric | Oppose; heating system metric only1 |
| Compliance by 1 April 2030 | Support, no delay1 |
| Cost cap | £15,000, rising with inflation1 |
| Spend exemption duration | Five years, not 101 |
Why it matters for households
The proposed standard would apply to homes in the social rented sector in England, where tenants have historically had less control over the energy performance of their homes than owner-occupiers. A minimum standard at EPC C, enforced on landlords rather than tenants, would place the cost of fabric improvements, such as insulation and glazing, on the landlord. The Trust's response argues that focusing on fabric performance first is the best way to reduce household energy demand and bills1. Its recommendation that grant funding for fuel-poor tenants not be counted within the cost cap is intended to prevent public money substituting for landlord investment1. The Trust also notes that the in-home display supplied with a smart meter can help tenants manage energy use after improvements are made1.
What happens next
The consultation response was originally published on 10 September 20251. The Trust states that the new EPC framework must be progressed as soon as possible to avoid delays to implementing the standards, and that enabling policies should be in place well ahead of 20301. It also recommends that the Government provide additional impact analysis on the proposal to recognise properties meeting EER C before 2028 as compliant until their EPC expires1. No date for the Government's response to the consultation has been reported.
Sources1 cited
- Improving energy efficiency in social housing- Energy Saving Trust, energysavingtrust.org.uk