The Energy Saving Trust published its response to the government consultation on improving home energy performance through lenders on 5 May 2026. The charity said it welcomed the proposals for a mandatory requirement on lenders, describing them as "an innovative tool for improving the UK's housing stock"1.
The consultation proposes that lenders take steps to improve the energy performance of the homes they lend against. The Energy Saving Trust said the current proposals would focus improvements on homeowners able to afford a commercial loan and on homes that can be improved to EPC C with a maximum investment of £10,000, including VAT, survey and Trustmark costs1. It said those limits would reduce the number of homes upgraded from between 8 million and 10 million to 2.8 million by 2030, with an average improvement of five SAP points, from SAP 64 to SAP 691.
The charity set out its estimate of what a wider scope would deliver. It said extending the proposals would triple the number of homes improved, support 75,000 jobs and stimulate £24 billion in additional investment1.
| Measure | Current proposals | Potential |
|---|---|---|
| Homes improved | 2.8 million | 8 to 10 million |
| Average improvement (SAP points) | 5 | 13 (estimate) |
| Additional investment to economy | £8 billion | £24 billion |
| Jobs supported to 2030 | 25,000 | 75,000 |
Source: Energy Saving Trust, Table 11
The response states there are over 10 million mortgaged owner-occupied and private rented homes in England and Wales, at least 80 per cent of which are likely to be refinanced by 20301. It notes that emissions from heating homes account for 15 per cent of UK carbon emissions and fell by just 15 per cent between 1990 and 2020, against a 41 per cent reduction for the whole economy1. The charity said the proposals do not do enough to meet the stated intent to significantly improve the energy performance of mortgaged properties in the 2020s, or the commitment to at least a 68 per cent reduction in emissions by 2030 from a 1990 baseline1.
On affordability, the Energy Saving Trust recommended that the government consider using the proposed National Infrastructure Bank to provide long-term, low-interest loans that would allow the proposals to be extended to all mortgaged homeowners, and said there is a need for alternative finance where homeowners or retrofit packages do not meet commercial lending criteria1. It also recommended that the government commission a new "net zero" homes service, arguing that people are unlikely to act at the scale required without trusted and impartial advice and support1.
Why it matters for households
Mortgage lenders hold a lever over a large share of the housing stock, and the consultation would make that lever mandatory rather than voluntary. For a household with a mortgage, the practical question is whether a lender's duty would reach their property, and on what terms. Under the proposals as described, that reach is limited: the Energy Saving Trust says the £10,000 cost ceiling and the commercial lending test would leave out homes needing deeper work or owners who cannot take on a commercial loan1. The charity's own figures put the average owner-occupied home at SAP 64, against a proposed target of SAP 691. The wider question of how EPC regulations and reform would interact with a lender duty is not addressed in the response. The Energy Saving Trust is authorised and regulated by the Financial Conduct Authority and states that it does not provide or run the financial advice, products or services mentioned on its page1.
What happens next
The consultation itself is run by the UK government, and the Energy Saving Trust's response is one submission to it. No date for the government's response to the consultation, or for any decision on the recommendations, has been reported1. The charity's recommendations on the National Infrastructure Bank and a net zero homes service are proposals to government, not commitments.
Sources1 cited
- Improving energy performance through lenders - Energy Saving Trust, energysavingtrust.org.uk