There is a growing misconception that landlords will have to remove gas or oil boilers before their properties can meet the new EPC C requirements.
That is wrong.
A property will not automatically fail simply because it has gas or oil central heating. Nor do the reforms create a blanket requirement for landlords to replace every working boiler with a heat pump.
The new system is more complicated than that—but it also gives landlords more flexibility than many commentators are suggesting.
The EPC system itself is changing
From the second half of 2027, domestic EPCs in England and Wales are expected to move away from the present system based primarily on one overall Energy Efficiency Rating.
New EPCs are intended to show four separate headline assessments:
- fabric performance;
- heating system;
- smart readiness; and
- energy cost.
The precise scoring methodology and band thresholds are still being finalised, but the Government has confirmed the basic structure of the new certificate. (GOV.UK)
This means that after the reforms, talking about a property simply “getting an EPC C” may no longer tell the whole story. Different parts of the property will receive separate grades.
What landlords will actually have to achieve
The proposed minimum standard for privately rented homes will use two of the new metrics.
By 1 October 2030, a property will generally need to achieve:
A C grade for fabric performance
and
A C grade for either smart readiness or heating-system performance
The choice between the two secondary routes will rest with the landlord. The property will not need a C rating in every category. (GOV.UK Assets)
That distinction is crucial.
A gas- or oil-heated property may perform less strongly under the heating-system metric than a property using a heat pump or low-carbon heat network. However, the landlord may instead choose to meet the smart-readiness standard.
The Government has expressly stated that this approach is intended to avoid penalising gas-boiler users or forcing landlords to replace a working heating system. (GOV.UK Assets)
Route one: retain the existing boiler
A landlord may be able to keep a working gas or oil boiler and comply by improving:
- the property’s fabric performance; and
- its smart readiness.
Fabric improvements could include:
- loft insulation;
- cavity-wall insulation;
- suitable solid-wall insulation;
- floor insulation;
- improved glazing;
- draught-proofing; and
- better insulation around hot-water systems.
The exact measures will depend on the building, its construction and the recommendations produced by the new EPC assessment.
Once the fabric requirement has been addressed, smart-readiness measures may provide the second route to compliance. Depending on the final methodology and the property concerned, these could include:
- a smart meter;
- solar photovoltaic panels;
- battery storage;
- intelligent heating controls;
- systems capable of responding to variable tariffs; and
- other technology that allows energy to be generated, stored or used more flexibly.
A smart meter alone should not be assumed to guarantee a C grade. It may improve the score, but the property could require additional measures.
Route two: improve or replace the heating system
A landlord may instead choose to meet the secondary requirement through the heating-system metric.
That could involve measures such as:
- improved heating controls;
- more effective radiators or other heat emitters;
- hot-water-cylinder improvements;
- cylinder insulation;
- solar water heating;
- connection to a low-carbon heat network; or
- installation of a heat pump.
Replacing the existing boiler is therefore an available route—but it is not the only route.
Heat pumps may be appropriate for some properties, particularly where the building fabric is already suitable. They will not necessarily be the most practical or cost-effective answer for every rental property.
Oil heating is not an automatic failure either
Oil-heated properties are likely to face particular challenges because oil is a higher-carbon fuel and many oil-heated homes are older, rural and harder to insulate.
That does not mean an oil boiler automatically prevents compliance.
An oil-heated property may still qualify by achieving the required fabric grade and meeting the smart-readiness standard. Alternatively, the landlord could consider upgrading the heating system where that is practical and financially sensible.
The outcome will depend on the property—not simply the fuel used by its boiler.
Existing EPC C properties receive transitional protection
Landlords who already improve their properties under the present EPC system are not necessarily wasting their money.
Under the Government’s confirmed policy position, a privately rented home with a current Energy Efficiency Rating of C or above on an EPC lodged before 1 October 2029 will be treated as compliant until that EPC expires or is replaced.
Properties without an existing C rating by that date are expected to require a new-style EPC before improvement work is undertaken, followed by another assessment once the work has been completed.
Landlords should nevertheless avoid spending large sums solely on the basis of speculation about how a future assessment might score. The final methodology and recommendations under the new system will matter.
There will be a cost cap and exemptions
The maximum required investment is intended to be £10,000 per property, covering the work needed across both the fabric and secondary standards.
For properties valued below £100,000, the proposed affordability limit will be £10,000 or 10% of the property’s value, whichever is lower.
Where the relevant amount has been spent and the property still cannot reach the standard, the landlord should be able to register an exemption and continue letting it for the applicable exemption period. Other exemptions are expected to cover circumstances including unavailable improvements, refused third-party consent, negative effects on the building and unsuitable solid-wall insulation.
The cap is not a grant and it does not mean every landlord must automatically spend £10,000. It is the maximum qualifying expenditure that may be required before a cost-based exemption becomes available.
Do not remove a working boiler because of a rumour
Landlords should not be rushed into replacing serviceable gas or oil boilers because somebody has claimed that fossil-fuel heating will make an EPC C impossible.
That claim is false.
The new standard is designed around a choice of compliance routes. The property must first address its fabric performance and then meet either the smart-readiness standard or the heating-system standard.
A modern, properly controlled gas or oil boiler may therefore remain in place where the property can comply through fabric and smart measures.
The sensible approach is clear:
- understand the property’s present condition;
- complete sensible maintenance and insulation work;
- retain records and invoices;
- avoid premature assumptions about the final scoring system; and
- obtain property-specific advice once new-style EPC assessments become available.
Landlords face a substantial programme of change, but they should base investment decisions on the actual rules—not exaggerated claims, sales pressure or social-media speculation.
NetRent does not provide legal or energy-assessment advice. This article reflects our general understanding of the proposed EPC and minimum energy-efficiency reforms and is provided for information only.