EPC Requirements for Bath Landlords: Meeting the 2028 Deadline

Energy Performance Certificaterequirements are tightening, and for landlords in Bath, the path to complianceisn't always straightforward. The city's Georgian and Victorian housing stockdoesn't lend itself to standard insulation approaches, and listed buildingrestrictions add another layer of complexity.

Current EPC Rules forRental Properties

Since April 2020, rentalproperties in England and Wales have needed a minimum EPC rating of E to belet. Properties below this standard cannot be legally rented unless anexemption applies.

What's Required Now: • MinimumEPC rating: E • Valid EPC required at point of marketing • EPC must be providedto tenants before tenancy starts • Certificates valid for 10 years

Penalties for non-compliance:Letting a property without a valid EPC or below the minimum standard can resultin fines up to £5,000.

Upcoming Changes: The2028 and 2030 Deadlines

The government has confirmedthat the minimum EPC rating for rental properties will increase to C: • 2028:EPC C required for new tenancies • 2030: EPC C required for all tenancies(including renewals and continuing tenancies)

New Fabric-BasedMetrics (From 2026)

The government is alsointroducing new assessment criteria focusing on the building fabric rather thanjust energy costs. From 2026, EPC assessments will include Fabric EnergyEfficiency (how well the building retains heat), Environmental Impact Rating (carbonemissions), and heating system efficiency.

Bath's UniqueChallenges

Bath's housing stock createsspecific obstacles to EPC improvement that don't apply to most of the UK.

Solid Wall Construction: MostGeorgian and Victorian properties have solid walls—typically 9-inch or thickerstone or brick construction with no cavity. Standard cavity wall insulationsimply isn't applicable. Solid wall properties typically rate D or E on EPCassessments.

Listed Building Restrictions:Bath contains over 5,000 listed buildings, and the entire city centre is aUNESCO World Heritage Site. This means external wall insulation is generallyprohibited, window replacement may require like-for-like traditional materials,solar panels on front-facing roofs often refused, and changes to chimneys arerestricted.

Conservation Area Controls:Even unlisted buildings in Bath's conservation areas face restrictions onexternal alterations.

Improvement Optionsfor Different Property Types

Georgian/VictorianProperties (Listed):

Internal Wall Insulation: Thininsulation boards can be applied to internal walls without affecting externalappearance. Modern aerogel-based products achieve good insulation in minimalthickness (25-40mm).

Secondary Glazing: Addingsecondary glazing behind existing single-glazed sash windows preserves thehistoric windows while significantly reducing heat loss.

Loft Insulation: Usuallypermitted even in listed buildings. Increasing loft insulation to 270mm isstraightforward and offers excellent return on investment.

Draft-Proofing: Addressing gapsaround windows, doors, floorboards, and chimneys. Low-cost but cansignificantly reduce heat loss.

Heating System Upgrades: Moderncondensing boilers, smart heating controls, and improved hot water cylinderscan improve ratings.

Typical Costs forBath Properties

• Loft insulation (top-up to 270mm): £300-600, +2-5 EPCpoints

• Draft-proofing throughout: £200-500, +1-3 EPC points

• LED lighting throughout: £100-300, +1-2 EPC points

• New condensing boiler: £2,500-4,500, +5-15 EPC points

• Smart heating controls: £200-500, +2-4 EPC points

• Secondary glazing (per window): £350-700, +1-2 EPC pointsper window

• Internal wall insulation: £5,000-15,000, +10-20 EPCpoints

• External wall insulation: £10,000-25,000, +15-25 EPCpoints

• Air source heat pump: £10,000-18,000, +10-20 EPC points

• Solar PV (4kW system): £6,000-9,000, +5-10 EPC points

Exemptions and WhatQualifies

Cost Cap Exemption: If the costof necessary improvements exceeds a set threshold, you can claim an exemption.The current cap is £3,500 including VAT, expected to increase for 2028requirements—potentially to £10,000.

"All ImprovementsMade" Exemption: If you've made all relevant improvements but still don'treach the required rating, an exemption applies.

Listed Building ConsentExemption: If a recommended improvement would require listed building consentthat has been refused, or would be likely to be refused, an exemption can beclaimed.

Third-Party Consent Exemption:If improvements require consent from a third party that has been refused orcan't reasonably be obtained.

Devaluation Exemption: Ifimprovements would reduce the property's value by more than 5%.

Important: Exemptions must beregistered on the PRS Exemptions Register. They last for five years, afterwhich they must be reassessed.

Planning YourApproach

Step 1: Understand YourStarting Point If your current EPC is over three years old, consider getting anew assessment.

Step 2: PrioritiseCost-Effective Improvements Start with low-cost, high-impact improvements: topup loft insulation, draft-proof windows and doors, upgrade lighting to LED,service or replace old boiler, add or upgrade heating controls.

Step 3: Assess MajorImprovements Get quotes for secondary glazing, assess feasibility of internalwall insulation, consider boiler upgrade.

Step 4: For Listed Buildings,Engage Early Contact B&NES conservation officers to discuss whatimprovements are likely to be acceptable. Document any refusals for exemptionpurposes.

Step 5: Consider the ExemptionRoute For properties where achieving EPC C is genuinely impractical: make allcost-effective improvements, document costs and consent refusals, registerappropriate exemption.

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