On 7 February, the government launched a new "update" consultation on its proposals to raise Minimum Energy Efficiency Standards (MEES) for private rented homes in England and Wales by 2030. This will be achieved by making amendments to the Energy Efficiency (Private Rented Property) (England and Wales) regulations 2015 (PRS Regulations). 

The government contends that the recently published consultation on the future of Energy Performance Certificates provides an opportunity to ensure that new standards in the Private Rented Sector (PRS) incentivise the right measures for each home. It is proposing to set higher MEES standards against the new metrics which will be introduced as part of the EPC reform (projected to be implemented in 2026). 

The government's preferred approach is then to require landlords to prioritise meeting a standard set against the "fabric performance metric" (which is likely to require similar improvement measures as meeting an EPC C on current EPCs), and to then meet a standard set against either the "heating system metric" or the "smart readiness metric". The desired outcome is to deliver significant bill savings for tenants and improve the thermal comfort of privately rented homes, whilst also encouraging decarbonisation. 

The consultation is, in particular, seeking views on: 

• a landlord's requirement to invest up to £15,000 per property on improvements to meet the standard (the "cost cap") after which they can register a 10-year exemption to continue to let the property if it does not reach the required standard; 
• proposals for the higher standard to apply to new tenancies from 2028, with all tenancies required to be compliant by 2030;
• for properties remaining below EPC C following 2026 EPC reform, a requirement for landlords to commission a new EPC before taking action to comply with the higher standard (those properties already at EPC C will be considered compliant until their existing EPC expires);
• whether to introduce an affordability exemption which will lower the cost cap to £10,000 for some properties; 
• whether to increase the scope of the PRS Regulations to include short term lets to ensure a consistent standard between privately rented homes and short term lets; 
• what regulatory measures could be used to drive the installation of smart meters in privately rented homes; and 
• the existing exemptions regime for the PRS Regulations and whether there are other instances in which exemptions should apply. 

The proposed measures are part of the government's "Warm Homes Plan", its ambitious strategy to upgrade five million homes to "cut bills, slash fuel poverty and support people to take greater control of their energy with clean technology like heat pumps, batteries and solar panels". 

The policy proposals also link closely with wider government work being done to improve standards in the private and social rental sectors including The Renters Rights' Bill and the Decent Homes Standard. 

A step in the right direction

Whilst the proposals are undoubtedly steps in the right direction in terms of updating performance metrics of buildings, and contributing towards net zero targets, they will place yet more obligations on landlords (who are already contending with prospective large-scale regulatory changes under the Renters Rights Bill, and leasehold reform measures) to install potentially extensive measures to improve a building's heat retention and reduce energy consumption. 

The consultation closes on 2 May 2025, and you can respond by clicking on this link.