Our response to the ‘Reforms to the Energy Performance of Buildings regime’ consultation

Strongly agree 

We support the inclusion of an energy cost metric on EPCs. Cost is the measure of most importance and interest to the majority of households and is useful to them to understand bill impacts and compare properties. It is also most likely to motivate them to upgrade the performance of their homes.  

However, we would note that a rating is only useful for comparison if the difference between the values in cost terms is known. We therefore also consider that the EPC should state the estimated cost for the home based on its floor area to enable full and proper comparison between properties. For example, two different properties may have the same £/m2/yr rating but one may be larger than the other.

The estimated cost is helpful and useful to consumers who would otherwise have to try to work it out for themselves and could easily be caveated by making it clear that the estimated cost is modelled to allow for comparison and that actual usage will influence costs. 

We would support the idea of a £/m2/yr metric being the primary metric, as this is consistent with previous practice and is a reasonable indication of what people understand by the idea of an efficient home. The actual modelled running cost for the property could be included as a secondary metric. 

Strongly agree 

We agree that a fabric performance metric should be included on EPCs as this is crucial for household thermal comfort and reducing energy demand. Improving the energy efficiency of the UK housing stock is key to permanently lowering energy bills as it reduces a household’s energy demand. Reducing overall demand will also help lower our dependence on volatile fossil fuel markets as well as support the UK Government’s clean power target. 

The UK Government should also consider how EPCs can better inform households on the next steps for improving the performance of their home. This could include signposting people to schemes they may be eligible for (eg ECO or GBIS) or directing them to impartial advice services to provide further support. We think the UK Government should set up a national advice service for England which would give households impartial, tailored advice and the confidence to make the right changes to their homes.  

HLP/HTC 

We’d recommend that the HLC and HLP are recorded in the publicly accessible online database as a minimum, as they are calculation output steps already present in the process and very straightforward to include. Ideally some form of one of these metrics would also appear on the EPC, increasing the issue of fabric quality in the public’s awareness.

Strongly agree 

We strongly agree with the inclusion of a heating system metric on EPCs provided this is based on the carbon efficiency of the system, aiming to incentivise the adoption of low carbon heat.  

The UK Government should also consider how EPCs can better inform households on the next steps for changing their heating system. This could include signposting people to schemes they may be eligible for (eg the Boiler Upgrade Scheme) or directing them to impartial advice services to provide further support.

We think the UK Government should set up a national advice service for England which would give households impartial, tailored advice and the confidence to install the right heating system for their homes.  

We are supportive of a heating system metric but it’s important that this metric focuses on the carbon efficiency of the system. A simple but appropriate metric would be the greenhouse gas emissions per unit of heat energy delivered to the home (kg CO2e per kWh).  

Efficiency of the system would be incorporated in the calculation, as well as in the energy cost metric, meaning it does not need to be highlighted specifically. It will be important to make sure that efficiency assumptions are appropriate and comparable between technologies.

In use performance of gas and oil boilers is well understood, but information available on heat pump performance is still developing and being interpreted and the range of measured performance varies dramatically between installations.  

The Electrification of Heat report and analysis of RHI metered for payment installations both show that there is little or no correlation between the design efficiency (SCoP) of an installation and its actual in situ performance (SPF). The SCoP is therefore not a useful indicator of likely performance and should not be used as a basis for a metric. 

The variation between SCoP and SPF can be put down to a number of factors including: 

• poor design, including oversizing of heat pumps leading to excessive cycling
• poor installation, such as missing or inappropriate lagging
• poor commissioning, such as setting the compensation curve too high
• inappropriate operation, such as setting multiple low temperature setback periods

None of these can be accounted for in an EPC assessment. The one determining factor that could potentially be accounted for is the design flow temperature, which is specific to the system not the occupier and has a significant impact on the potential system efficiency.

We would suggest that, in the first instance, the efficiency used to calculate the heating metric for heat pumps is based on technology type (eg air-to-water) and either design flow temperature of the system (if available) or maximum flow temperature of the unit (if design temperature is not available).  

This calculation could be modified over time as more data becomes available. Data from individual product fiches should not be used in the calculation until a relationship between claimed performance and in situ performance has been demonstrated and quantified. Monitored performance of an individual installation could, in principle, be used to over-write the modelled efficiency in the future.

However, care would be needed to avoid reducing ratings for a system because it was being used sub-optimally by the current resident and to ensure that monitored and unmonitored systems are comparable.  

The other key factor in the calculation would be the carbon factor of the fuel. For most fuels this is consistent, but the factor for electricity will diminish over time. It will be important to show the factor used, or to include some other mechanism for EPCs from different dates to be compared – for example, showing a rating based on factors for a consistent baseline year, as well as the rating at the time of the assessment.  

There is currently no agreed methodology or dataset for calculating different electricity carbon factors based on time of use, but we would recommend that this is considered for future development so that electrical heating systems incorporating storage can be accounted for correctly. 

The main risk with a carbon-based heating metric is that systems with a high running cost, such as electric panel heaters, perform better as the grid decarbonises. This risk can be mitigated through the energy cost metric, providing a clear and obvious link is made between the heating system and the energy cost rating. One way might be a pie chart showing how much of the energy cost comes from each use type. 

Agree 

We support the proposal to introduce smart readiness as one of the EPC’s metrics.  

We supported the Centre of Net Zero’s proposal for a Smart Building Rating (SBR), the potential and technical requirements of which are included in the latest report, Net Zero Building Metrics (2025).

This metric will be important to ensure demand flexibility is reflected in building performance as it will be a key part of a future energy system that can deliver significant benefits to consumers. According to Cornwall Insight, household flexibility could deliver an annual saving of £14.1 billion for GB consumers and the energy system in 2040.

We support the development of a smart readiness metric as a valuable tool for both individual consumers and policy makers. Such a metric could effectively help occupants understand their property’s current smart capabilities and identify potential improvements to enhance this capacity.

For policy makers and other stakeholders, a smart readiness metric would be particularly valuable when combined with additional datasets (such as housing tenure, location and household income). This comprehensive approach would enable more targeted and effective policy interventions to support the transition to smarter, more energy efficient buildings. 

It is crucial that this metric focuses on the intrinsic capabilities of the building rather than occupant behaviour, to allow for comparison and objectivity. The metric should assess building assets and infrastructure that enable smart energy management, rather than technologies that relate primarily to occupant choices or lifestyle. 

For example: 

• An EV charger installation might be considered less relevant to a building’s inherent smart readiness, as its utility depends on vehicle ownership, which is an occupant choice rather than a building characteristic. This becomes particularly apparent for buildings well-served by public transport. 
• Conversely, smart heating controls or smart-enabled heating systems (storage heaters, electric battery, thermal stores) represent the building’s capacity for intelligent energy management regardless of occupant behaviour, provided the capacity is large enough. 

It is essential that the purpose and limitations of the smart readiness metric are clearly communicated to avoid misaligning incentives. For example, households with low energy use may find that smart technologies do not deliver significant financial or carbon saving benefits compared to other interventions such as installing low carbon heating systems or energy efficiency measures. 

The metric should therefore: 

1. Clearly articulate what is being measured 
2. Provide context for the potential benefits of improvements 
3. Acknowledge when other energy efficiency measures might deliver greater benefits than increasing smart readiness 

Strongly disagree 

We would not support information from an energy use metric being displayed on EPCs because it is less relevant to the occupant and can be confusing. The other metrics proposed in the consultation are more effective and relevant to households. 

Delivered energy  

There are multiple definitions of delivered energy and primary energy and both have become less meaningful as the electricity grid has relied less on fossil fuel combustion. As such, the terms have been used in conflicting ways. This is one reason why we do not support an energy metric – the range of options for an energy metric make this unsuitable for a document aimed primarily at homeowners and occupants. 

Disagree 

Some households are increasingly motivated by carbon emissions reductions and may be willing to make renovations with minimal financial returns if the carbon emissions reductions are substantial. However, provided the heating metric is carbon focused, as proposed in our response to question 5, we are of the view that there is no need for a separate carbon metric. 

A typical household’s carbon emissions predominantly come from their heating system and space and water heating are the two main energy uses where there is a choice of fuel and technology, so carbon emissions do not vary in line with running costs. A carbon based heating metric therefore highlights the most significant area where emissions can be reduced, while excluding other energy uses where the energy metric already acts in lieu of a carbon metric. 

Strongly agree 

Incorporating smart meter data into EPCs could improve their accuracy, reliability and trustworthiness, addressing the performance gap between predicted and real-world energy use. 

We would also note that it is essential that RdSAP equipment tables are updated to include an up to date understanding of typical ‘in-use’ efficiencies, particularly regarding heat pumps. We would recommend removing the reference to the Product Characteristics Database (PCDB) for heating equipment efficiencies (which are self-reported by manufacturers) and instead creating a table of ‘in-use’ standardised efficiencies.

As a minimum, a decision to include a heating system metric should be accompanied by a review and update of the PCDB. 

We believe that the validity period for EPC ratings should be reduced to five years. This would ensure that the latest RdSAP and reference data has been used and that any recent renovations are reflected.  

Agree 

Retaining cancelled or erroneous EPCs risks having misleading or incorrect records in the EPB Register so removing them will help to ensure that only valid, issued EPCs remain available for public access and policymaking, while also reducing the risk of consumers acting on incorrect data.  

Keeping them on the register for two years will still enable government to track and analyse the rate of cancelled or not for issue certificates for compliance purposes. It would also reduce any storage and maintenance costs. 

Agree 

We agree with removing the option to opt-out of EPCs. This would ensure all EPCs are publicly accessible, helping buyers, tenants and policy makers make more informed decisions. It would also prevent landlords and sellers being able to hide poor energy performance of their properties, encouraging compliance and supporting enforcement of any future policy interventions, such as minimum energy efficiency standards. 

Making EPC’s publicly accessible would also ensure any advice provided to households on the changes to make to their property is both accurate and tailored.  

Disagree 

We disagree with retaining the option to opt-out EPC address level content from the Open Data as this would prevent having a more complete picture of domestic energy efficiency in England and Wales. Having more complete data would improve the quality and accuracy of any national housing stock analysis and reduce reliance on less accurate modelling or gap filling techniques. This data could also be used to support the development of retrofit policies and better target public funding.  

Agree 

We’re supportive of a more flexible approach to data sharing that allows for greater use of EPC data in critical areas such as: 

• Policy development for energy efficiency and decarbonisation. 
• Research on housing stock and energy performance.
• Collaboration with local authorities, industry stakeholders and academia. 

If this proposal moves forward, it would be useful to have clear guidelines on what factors will guide the Secretary of State’s decisions and timelines for when changes will be made to allow organisations to prepare for any change.   

Agree 

We agree that existing data gathered in previous EPC assessment should be available for two main reasons:   

1. It would reduce the time and cost required for assessors to complete new EPCs, especially when no significant changes have been made to the property. This would also lower the administrative burden for homeowners, landlords and assessors. 
2. It would enhance data consistency and accuracy by maintaining a clear historical record of property energy efficiency improvements over time. It would also help to avoid discrepancies between multiple assessments by ensuring consistent baseline data. 

There are risks associated with using existing data, so safeguards need to be put in place to prevent errors and misuse, such as: 

• Data validation checks to ensure previous assessments remain relevant (eg major renovations should trigger full reassessment). 
• Guidance on which data points can be reused (eg permanent features like wall insulation vs modifiable factors like heating systems). 
• Accreditation bodies must oversee data reuse to prevent assessors from relying on old or inaccurate records without verification.     

A structured data verification process should be implemented to ensure reused data is accurate and up to date. This should specify which data points can be reused automatically and which require reassessment.

For example, reusing static property data (eg property type, wall construction, floor area, property age) reduces the burden on assessors and lowers cost for households. However, other property elements which are more dynamic in nature (eg heating systems, windows, insulation) should require reassessment.  

It will be important to ensure assessors have clear guidelines on when to accept, modify or override historical data to ensure the assessment approach is consistent. By adopting a hybrid approach – reusing static, validated data while requiring verification for changeable factors – this system can be both practical and accurate.