More than half of homes in England and Wales have an EPC rating of D or below, according to an analysis of local authority data, underlining how far landlords may still need to go before the proposed 2030 minimum of EPC C for rented homes.
EPC ratings leave a big upgrade gap
The analysis, by Emperor Paint using data from more than 300 local authorities, found that 55 percent of homes were rated D, E, F or G. That matters for landlords because the current legal floor for most rented property remains EPC E, but the policy direction is towards a tougher standard.
The government has already confirmed that reformed domestic EPCs will use four headline metrics instead of the single familiar score, while the timetable for the wider reform has moved into the second half of 2027. Alongside that, ministers still intend rented homes in England and Wales to reach the equivalent of EPC C from October 2030 for new tenancies.
For landlords, the immediate point is not that millions of homes suddenly become non-compliant. It is that a large share of the market may still need work, and the new system could make upgrade planning harder rather than easier during the transition.
The local breakdown also shows the challenge will not be evenly spread. Isles of Scilly topped the table, with almost 85 percent of homes rated D or below, followed by Gwynedd and Pendle, both above 74 percent. Areas with older stock, harder-to-treat homes and lower values are likely to face the toughest economics.
Landlords face cost pressure before the 2030 EPC C target
That creates a practical warning for landlords who have put off energy work while waiting for final rules. A property that scrapes past today’s standard may still require insulation, heating upgrades or other fabric improvements before the decade is out.
This follows Landlord Knowledge’s report on NRLA concerns over assessor shortages, which highlighted the risk that EPC reform could stall if the market lacks enough trained professionals to deliver new assessments at scale. The latest data adds another problem: even if the system is ready on time, a large stock of lower-rated homes still needs work.
Landlord Knowledge has also covered Greater Manchester’s EPC grant support for landlords, and that points to a wider issue. Where grants or local incentives exist, landlords may have a better route to compliance. Elsewhere, many will be left funding improvements from rent, refinancing or cash reserves.
The government’s Energy Performance of Buildings reform programme makes clear that ministers still want EPCs to give tenants and landlords a better picture of building performance. But better information does not reduce the capital bill. For landlords with older terraces, flats with limited control over fabric changes, or stock in lower-rent areas, that gap remains the central issue.
Ahead of the final rules, the sensible move is to treat EPC C as a live portfolio planning issue rather than a distant policy note. The properties most likely to become expensive problems are usually the ones that already look marginal on rent, age or condition.
What this means for landlords
- If you’re holding older stock: review current EPC certificates now and identify which homes are already sitting at D or low C.
- Watch for: final confirmation of how the new EPC metrics map across to the proposed EPC C rental standard.
- If you’re refinancing or buying: build likely retrofit costs into the numbers, especially in areas with older housing and weaker rental growth.
- Bottom line: the 2030 target still looks a long way off, but the scale of lower-rated stock means waiting could leave landlords facing a rush and higher costs later.
Editor’s view
EPC reform is drifting back into focus for a reason: too much of the housing stock still sits below the level ministers want by 2030. For landlords, the risk is not just regulation. It is leaving upgrade decisions so late that every installer, assessor and lender becomes harder to pin down at the same time.
Author: Editorial Team – UK landlord & buy-to-let news, policy, and finance
Published: 21 April 2026
Sources: Emperor Paint analysis of local authority EPC data, GOV.UK Energy Performance of Buildings reform programme
Related reading: NRLA warns EPC reform will fail without more trained assessors
🏠 EPC Rules for Landlords: What You Need to Know
Minimum EPC C required by 2030 – new assessment rules from late 2027
