The Energy Saving Trust published its response to the UK Government's consultation on improving the energy performance of privately rented homes on 19 February 2026. The consultation, run by the Department for Energy Security and Net Zero, covers the 2025 update to proposed Minimum Energy Efficiency Standards for the private rented sector1.
The Trust agreed with the government's preferred approach of using new alternative Energy Performance Certificate metrics, following EPC reform, as the basis for higher standards. It also backed a two-part structure in which landlords must first meet a fabric performance standard, then a secondary standard. The Trust disagreed with letting landlords choose between the smart readiness metric and the heating system metric, recommending that the heating system metric be the only secondary option, provided it is developed on a carbon basis rather than simply on efficiency1.
On costs, the Trust supported raising the maximum required investment to £15,000 per property, and said grant funding received by tenants in fuel poverty, such as through the Energy Company Obligation, should not count towards a landlord's cost cap contribution. It disagreed with extending the cost cap exemption period from five years to ten1.
"almost a quarter (24.1%) of private renters are in fuel poverty"
The Trust cited figures on the sector's shape and its take-up of support. Purpose built flats and apartments account for 39% of properties in the private rented sector, despite only accounting for a fifth (22.2%) of all properties, it said. It also said the sector has only accounted for 14% of homes receiving measures through ECO1.
| Proposal | Energy Saving Trust position |
|---|---|
| New EPC metrics as basis for standards | Agrees |
| Fabric standard first, then secondary | Agrees |
| Landlord choice of secondary metric | Disagrees; heating system metric only |
| Cost cap raised to £15,000 per property | Agrees |
| Cost cap exemption extended to 10 years | Disagrees |
| New tenancies from 2028, all tenancies by 2030 | Agrees |
Why it matters for households
The private rented sector is where energy efficiency improvements have lagged, and where the Trust says fuel poverty is higher than in any other tenure type. For a household renting privately, the fabric of the building sets a ceiling on how much can be done to cut bills through behaviour alone: insulation, glazing and draught-proofing are the landlord's decisions, not the tenant's. The Trust's argument for putting fabric measures first is that they permanently lower demand, whereas a low carbon heating system installed before fabric upgrades may raise bills given the current cost of electricity1.
The consultation also touches on how rented homes are rated. The Trust noted that the current EPC framework is not designed to incentivise low carbon heating, because it focuses on lowering fuel costs rather than emissions. It gave no firm view on whether landlords should be able to demonstrate compliance with the existing EPC E standard using past certificates, or whether properties rated C before 2026 should be recognised as compliant with the future standard until their EPC expires1.
What happens next
The Trust said the proposed dates, new tenancies meeting the higher standard from 2028 and all tenancies by 2030, are the latest the standards should come into force and should not be delayed. It called for a national retrofit advice service in England, accessible to landlords and tenants, and for green finance options including low interest UK Government backed loans as part of the Warm Homes Plan. It cited interest free loan funding of up to £100,000 (£38,500 per property) as an example of the kind of offer needed1.
The response also pointed to Citizens Advice research finding that only one in five landlords could correctly identify the current minimum energy efficiency standards, and said smaller landlords were less likely to be aware of them. No government decision on the consultation has been reported1.
Sources1 cited
- Improving the energy performance of rented homes - Energy Saving Trust, energysavingtrust.org.uk