BRE’s response to proposals for domestic Energy Performance Certificates.

Jane Goddard, Deputy CEO of BRE said,

"BRE welcomes the publication of the government’s consultation on Reforms to the Energy Performance of Buildings regime, principally covering Energy Performance Certificate (EPCs).

EPCs were introduced in 2008 to provide information to consumers at the point of choosing a new home. They’re now used by government to target grant funds, set regulations and assess progress to net zero. The private sector uses them for retrofit services and increasingly for green financing. EPCs need reform to effectively to meet the multiple applications they are now put to; consumer trust in the certificates remains key.

In our report published in January this year, BRE called for several changes to the EPC system to build trust and deliver more usable, effective and up-to-date information from the certificates. We’re pleased to see those ideas reflected in government proposals:

A shorter life time for the certificates. The certificates are currently valid for ten years; the government is suggesting a shorter lifespan for EPCs, potentially as low as two years. It is also suggesting, for landlords, an ongoing requirement to maintain an in-date EPC.

A revised set of headline metrics. Homes have got more energy efficient and are more and more are starting to use smart, renewable energy. The metrics on the EPC need to reflect this. The proposals the government have made – for metrics measuring energy cost, fabric performance, heating systems – align with the recommendations in our report. We’re particularly pleased to see a smart readiness indicator proposed, measuring homes’ capacity to use low carbon energy flexibly.

Starting to unlock data on the EPC register. BRE highlighted that input data into the SAP software used to produce EPCs are retained on the EPC Register but are not accessible. While protecting data privacy, such data could help with retrofit planning and services. The government seems to be moving in this direction: proposing to change the regulations to remove a general prohibition on the sharing of this data.

A focus on the skills and training of domestic energy assessors to ensure quality EPCs: for example, we suggested, and are pleased to see, a proposal for more robust CPD requirements for existing energy assessors.

Rightly, this consultation does not lay out details of how consumers will use the new EPCs. We suggested that needs to be informed by extensive consumer research, which the government is committing to. This will be a “comprehensive programme” focusing on “Better understand[ing] user needs and preferences in order to present EPCs in a way that aligns with climate objectives and consumer expectations.”

Perhaps most importantly the consultation states how the new Home Energy Model, the full update and modernisation of SAP, which BRE has developed for government, will provide the underpinning methodology for improved domestic EPCs. The transition to HEM is proposed for the second half of 2026.

There are of course areas discussed in the consultation where we would have liked government to go further or do things differently, which we will lay out in our response. One important issue is the third of homes that have never had an EPC because they haven’t changed hands since the certificates were introduced. Data shows these are likely to be some of the homes most in need of retrofit. We’ve suggested that a provisional EPC produced using national housing stock data could be provided to the owners of these properties.

The consultation sets out proposals for the domestic sector. For non-domestic EPCs, the government are principally asking for views from stakeholders on the policy directions. BRE will be planning its response to those non-domestic questions over the next few weeks."