Propertymark says major omissions in the Government’s new Warm Homes Plan are “deeply concerning” for landlords and agents.
22nd Jan 20261 1,027 3 minutes read Simon Cairnes
The Government has published its Warm Homes Plan, setting out its long-awaited plans for improving energy efficiency across the UK’s housing stock, including the PRS.
It confirms that privately rented homes will be expected to meet EPC Band C by October 2030, unless a valid exemption applies.
Compliance criteriaIt also sets out the new compliance criteria. Instead of relying on a single EPC measure, landlords will need to meet EPC C across one of two metrics – either a “smart” route or a “heat” route, depending on what is most practical for the property.
In basic terms, the heat metric focuses on how the home produces heat — meaning compliance can be achieved through changes to the heating system and a move towards cleaner heat.
The smart metric, instead, focuses on how the home uses energy overall, rewarding measures that improve efficiency and reduce energy wastage.
More flexibilityThe aim is to introduce more flexibility into the system – what works for a newer flat or modern terrace may not be suitable for older stock, with complex layouts and harder-to-treat buildings.
Landlords’ potential financial exposure will be capped at a £10,000 cost cap, after which they may be able to register an exemption. It also introduces a low-value safeguard, lowering the cap for properties when £10,000 would represent 10% or more of their value.
Improvements made from October 2025 can be counted towards the £10,000 cap, while homes reaching EPC C before October 2029 would remain compliant until that EPC expires.
However, the plan still leaves major questions unanswered for landlords and letting agents — including how exemptions would work, what enforcement will look like, and what long-term funding package will back the upgrades, beyond references to ongoing finance options and Boiler Upgrade Scheme (BUS) grants
The absence of detail on interim targets, exemptions, enforcement, and financial support makes it impossible for landlords to plan responsibly or invest with confidence.”
Timothy Douglas, Propertymark
Timothy Douglas, Head of Policy and Campaigns at Propertymark, says the proposals “as they stand are deeply concerning” for landlords and agents. He warns they are being asked to deliver “substantial and costly upgrades” without clear, long-term funding commitments, realistic delivery timescales, or sufficient flexibility for older, complex, and hard-to-treat properties.”
He adds: “The absence of detail on interim targets, exemptions, enforcement, and financial support makes it impossible for landlords to plan responsibly or invest with confidence.”
Nick Maclean, President, RICS
Douglas says that without “certainty”, “genuine flexibility” and “practical financial support”, there is a “serious risk” landlords will withdraw properties from the market — reducing supply and driving up costs.
RICS President Nick Maclean, however, says: “The Warm Homes Plan is a critical step towards improving the UK’s housing stock. Enabling retrofit through strong investment will ensure that surveying professionals can support the delivery of desperately needed safer, warmer and more affordable homes.
Nigel Walley, Chair, Residential Logbook Association
Nigel Walley, Chair of Residential Logbook Association, says:” We were disappointed to see that DESNZ effectively ignored the role of data in the revised Warm Homes plan and the poor level of information being given to homeowners who install low carbon technologies (including cladding, solar, heatpumps, EV chargers).
“In November, the policy team at Citizens’ Advice published a report highlighting the poor state of consumer information called Stepping up, which calls for all homes receiving a retrofit installation to be given a Building Logbook to store key and info and help monitor performance.
“Specifically, it says: ‘Building on the outcomes of MHCLG’s Consultation on buying and selling homes, routes to introduce building logbooks into the retrofit market should be identified.
“’Performance of measures to be verified at installation and logged in a building logbook so changes to homes can be tracked over time’.
“It also calls for the Government (via DESNZ) to: ‘Develop an implementation timetable for introducing building logbooks in the retrofit market’.
“The CA report follows a series of other reports from bodies like the Climate Change Committee, the Energy Systems Catapult, and the Institute of Engineering, which have all made similar calls to follow the EU example and include Digital Building Logbooks in Warm Homes policy.
“We would also highlight that the Legal Services Consumer Panel (the primary body representing the interests of legal services consumers) highlighted, in their response to the MHCLG Consultation, echoed the Citizens Advice policy paper.
“They said that ‘consumers must be empowered with information to make the best choices for themselves and this principle is even more important in the property market. ‘
“Given that MHCLG are now considering mandation of Logbooks, and that the Law Society has already changed its TA forms to include information on low carbon tech installs, the lack of coordination between Government departments on Retrofit is disappointing.”
You can see the full Warm Homes Plan here.
TagsMinimum Energy Efficiency Standards (MEES) 22nd Jan 20261 1,027 3 minutes read Simon Cairnes Share Facebook X LinkedIn Share via Email