Morningstar DBRS has found that 51.8 percent of rental homes initially rated EPC F or G improved only to band E, a pattern that points to a larger second round of work before the proposed 2030 minimum.
The fresh analysis tracked more than 500,000 continuously rented homes in England and Wales through linked EPC records. It found the share rated F or G fell from 13.8 percent at the first inspection to 1.9 percent at the latest one, but most upgrades stopped at the legal floor rather than moving substantially beyond it.
With the government proposing an EPC C minimum for privately rented homes from 1 October 2030, the findings give landlords a clearer warning about the stock most likely to need attention again. A property that was brought from F or G to E for the previous rules may still require a more involved retrofit before it can be let under the next standard, unless an exemption applies.
Most earlier upgrades stopped at the former minimum
Morningstar DBRS used an address-stripped EPC dataset of around 27 million records, covering inspections to 31 October 2024. Its analysis focused on homes with repeated records after EPCs became a requirement and identified the properties that appeared to remain in the private rented sector.
Among rentals that began at F or G, 31.3 percent reached band D and 8.3 percent got to C or above. The equivalent owner-occupied pattern was stronger: 28.2 percent stopped at E, while 39.4 percent reached D and 15.9 percent achieved C or above.
The timing was also concentrated around the old compliance dates. Of rental homes that improved from F or G to E or better, 68.1 percent had their final assessment between 2018 and 2020, when the minimum standard applied first to new tenancies and then to existing ones.
EPC C could turn a past fix into a new project
The figures do not show that every band E rental needs the same work. Construction type, existing heating, insulation, ventilation and the assessment methodology all affect the route to a higher rating. They do show why landlords should avoid assuming that an earlier compliance job has settled the question for the next rules.
This follows Landlord Knowledge’s report on HMO landlords moving ahead on energy upgrades, which found a more proactive approach among some shared-home investors. Landlord Knowledge’s analysis of homes still rated D or below also highlighted how much of the housing stock sits short of the proposed new rental threshold.
A band E certificate is not, by itself, a works specification. Before committing money, landlords should obtain advice on the property, check the certificate’s age and recommendations, and consider whether planned repairs or a void period can be used to combine measures efficiently.
Cash flow and reletting risk are part of the calculation
Morningstar DBRS said a property needing work before reletting could create a gap in rental income for buy-to-let borrowers. It also warned that homes requiring upgrades at a forced sale could appeal to buyers looking for a discount. Those are credit-risk observations, not a forecast for every landlord, but they are a useful challenge to leaving work until the last possible point.
Landlords planning a refinance, sale or tenancy change before 2030 have an opportunity to identify lower-rated homes early. The Morningstar DBRS research makes the limitation of the previous compliance cycle plain: it removed much of the F- and G-rated stock, but it did not produce a broad move to EPC C.
What this means for landlords
- If a rental is rated E: check the current EPC, its expiry date and the practical route to C before a tenancy change or refinance forces a rushed decision.
- If work is already planned: combine energy measures with repairs, renewals or a void period where the property-specific advice supports it.
- Watch for: the final regulations, exemptions and implementation detail, because the 2030 EPC C proposal has not yet become the operative standard.
- Bottom line: the prior upgrade may have met MEES, but 51.8 percent of the tracked F- and G-rated rentals only reached band E and may face another compliance decision.
Editor’s view
The previous rules changed landlord behaviour because they set a firm floor. The risk now is treating that floor as a finish line. Early property-by-property planning is likely to be cheaper and less disruptive than discovering an EPC C gap when a home is empty or finance is due.
Author: Editorial Team – UK landlord & buy-to-let news, policy, and finance
Published: 25 September 2026
Sources: Morningstar DBRS
Related reading: Paragon: HMO landlords are ahead on EPC upgrades
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