Citizens Advice published its response to the Department for Energy Security and Net Zero (DESNZ) consultation on the Home Energy Model and Energy Performance Certificates on 18 March 2026. The consumer body said it supports the modular approach to assessment in principle, but set out conditions before agreeing to it.
The modular approach would see assessors use dwelling-specific information where they can and defaults where they cannot. Citizens Advice said EPCs should be as accurate and specific to a home as possible, but asked for more clarity on the standards for collecting and verifying data, how the Government will avoid a two-tier system of assessment, and whether the approach will add costs for consumers getting an EPC.
"But, before we agree with this approach, we need more clarity on the standards for collecting and verifying this data, how the Government will avoid a two-tier system of assessment, and whether this will add more costs for consumers when getting an EPC."
On the individual metrics, the response takes positions across four areas:
| Metric | Citizens Advice position |
|---|---|
| Fabric performance | Supports the Fabric Energy Efficiency methodology's focus on heat loss and overheating risk; says EPC C should represent a decent standard for future decades when C/D boundaries are set |
| Heating system | Agrees efficiency should count alongside carbon emissions, but concerned electric storage heating could score C, which under Minimum Energy Efficiency Standards could incentivise landlords to install systems that are cheaper to install but more expensive to run |
| Smart readiness | Wants detailed and clear definitions of which technologies are in and out of scope; prefers Option 2 (microgeneration and storage) as the threshold for EPC C, citing research that solar PV with battery storage saves significantly more than solar PV alone |
| Energy cost | Says this metric should be prioritised within the EPC, as energy costs are what consumers find most useful; presentation must be robustly tested with consumers through user research |
The consultation sits within the wider reform of EPC regulations and the government department's role in home energy policy. The response forms part of the consultation process through which rules are proposed, decided and changed.
Why it matters for households
EPCs set the standard that homes are measured against, and increasingly the standard that triggers obligations on landlords and, in Scotland, privately rented homes under separate energy efficiency standards. How the Home Energy Model scores a home therefore affects what improvements are counted, what a property is worth on paper, and what running costs a household can expect.
The electric storage heating point is the most direct consequence for households. If storage heaters can score C on the heating system metric, a landlord meeting minimum standards could install a system that is cheap to fit but expensive to run, with the running cost falling on the tenant. Citizens Advice raised this explicitly in the context of Minimum Energy Efficiency Standards.
The energy cost metric, if prioritised and well presented, would put running costs in front of households at the point of a sale or let, rather than fabric scores alone. Citizens Advice said that presentation must be tested with consumers through user research, which indicates the format is not yet settled.
What happens next
The response was published on 18 March 2026. No date for the Government's response to the consultation, or for any decision on the metrics, has been reported.