How Energy Performance Certificates can be utilised to better serve homeowners, landlords and the community

While we acknowledge some criticisms directed at the current system, particularly concerning accuracy as a driver for retrofit projects, we’re encouraged by many aspects of the proposals. The government’s willingness to review and update the EPC framework is positive, and we’re hopeful that a system that better serves the needs of homeowners, landlords and the community is developed.

This particular consultation focuses mainly on the metrics used in EPCs, rather than the underlying calculation methodology. While the metrics are vital, we also look forward to the consultation later in the year that will address the calculation methodology itself. A comprehensive review of both aspects is necessary to create a truly effective EPC system.

The proposed headline metrics – fabric performance, heating system, smart readiness and energy cost – appear to be a step in the right direction. Secondary metrics, such as carbon emissions and energy use, also hold value.

“The government’s willingness to review and update the EPC framework is positive, and we’re hopeful that a system that better serves the needs of homeowners, landlords and the community is developed”

However, metrics should be measurable to allow for meaningful comparisons between modelled and real-world performance. If we’re to make a genuine impact on climate change, actual emissions must be accounted for rather than relying solely on projections.

By focusing on actual performance data, we can move beyond theoretical models and develop a more precise understanding of how buildings are performing in practice, enabling us to make informed decisions about retrofit, technology and building design.

We support the inclusion of heat loss parameter or heat transfer coefficient as the preferred method for evaluating fabric performance, as this approach allows for real-world measurement and comparison with modelled figures.

We suggest that water heating be explicitly included in the heating system metric, as it represents an increasing proportion of overall energy use as space heating demand declines.

We believe that the validity period for EPCs should be reduced to five years instead of 10. Given the rapid progression of energy systems, building efficiency and regulations, a shorter renewal cycle would ensure more accurate assessments. Finally, we support the development of a smart-readiness metric to raise awareness of energy demand management, particularly as households transition away from fossil fuels.

Previous evidence has indicated that variations in EPC ratings can often be attributed to assessor-input errors, with 60% of respondents in a recent call for evidence citing this as a concern.

Conducting EPC assessments requires expertise and sufficient time to ensure accuracy. Even in the cost-conscious environment of social housing, selecting a provider based solely on the lowest price may prove to be a false economy.

Given the impact of EPC data on business decisions, investing in quality assessments is essential. Additionally, recent changes allowing access to EPC input data present an opportunity for landlords to enhance their stock data and derive greater value from assessments.

We are pleased to see the proposal to allow the use of existing data to generate replacement EPCs. We’ve seen examples of high-performing homes suffering a heavy ratings drop when reassessed after the expiry of the original EPC, because assessors could not use the as-built data and instead used default values.

“Given the impact of EPC data on business decisions, investing in quality assessments is essential”

We recognise that the financial value attached to EPC ratings through compliance requirements and funding eligibility has raised the risk of fraud. Strengthening oversight, training and standardisation for assessors would improve reliability significantly.

This consultation provided an opportunity for social landlords to help shape the future of EPCs. By participating in the discussion, we can ensure that EPCs better reflect real-world energy performance and provide meaningful insights for both residents and housing providers.

We would encourage stakeholders across the sector to engage in future consultation processes, ensuring that the reforms lead to an improved, more reliable, and future-focused EPC framework.

Vicki March, head, Greenoak Centre of Excellence, Stonewater