More than 1.8 million privately rented homes in England still fall below the proposed minimum EPC rating of C, with just three years left before the government’s anticipated 2028 deadline, according to new data analysis by LandlordBuyer. The figures, based on the latest Ministry of Housing, Communities & Local Government (MHCLG) and EPC Register data, paint a stark picture for landlords grappling with mounting retrofit costs and regulatory uncertainty.
As of Q2 2025, just 42.3% of privately rented homes in England meet the EPC C benchmark, leaving an estimated 1.82 million properties rated D or worse. With average upgrade costs running between £7,400 and £10,000 per property, many landlords could face difficult financial choices—especially those with larger portfolios or homes in older housing stock regions.
Regional EPC gaps put Northern landlords under pressure
London landlords are relatively better positioned, with 56.1% of private rentals already at band C or above. Yet even in the capital, around 310,000 rental properties remain below target. In contrast, the situation is more challenging in the North and Midlands. In Yorkshire and the Humber, just 32.8% of privately rented homes meet the standard, leaving 265,000 rated below C. The North West is in a similar state, with 33.9% compliant and 290,000 needing upgrades.
Jason Harris-Cohen, Managing Director of LandlordBuyer, warned of the scale of the problem: “With just three years to meet the government’s EPC band C target, over 1.8 million privately rented homes still fall short of the required energy efficiency standard. This represents a significant retrofit challenge for landlords, many of whom face difficult decisions between absorbing costly upgrade expenses, raising rents, or exiting the market altogether.”
With the average landlord owning 1.4 properties, LandlordBuyer estimates the total retrofit bill could easily exceed £15 billion nationally. This is not just a financial burden—it’s a policy risk. If landlords start selling up or hiking rents to cover the costs, tenants will inevitably feel the pinch.
Tenants face higher bills as landlords seek clarity
In lower-rated homes, tenants are already paying the price. Government modelling shows renters in EPC D-rated properties may be forking out £420 more per year in energy bills than those in C-rated equivalents—a serious hit during a cost-of-living squeeze.
Yet despite the pressure, Westminster has yet to finalise the legislative timeline. Harris-Cohen called for urgent action: “The regional disparities in compliance also highlight the need for targeted support and clear government enforcement timelines. Without urgent action and financial incentives, both landlords and tenants risk being caught in a difficult position.”
LandlordBuyer is urging the Department for Levelling Up, Housing and Communities (DLUHC) to clarify enforcement dates, introduce retrofit grants, and work more closely with local authorities to map out at-risk housing stock.
Navigating the retrofit road ahead
Many landlords are already adapting. Harris-Cohen added: “LandlordBuyer are committed to helping landlords navigate this evolving landscape by offering fast, chain-free sales options, enabling smarter investment and exit strategies in a rapidly changing market.”
However, without meaningful support or incentives, the EPC C target may prove more damaging than transformative. What happens to the thousands of older, rural, or traditionally built homes that are expensive—or impossible—to upgrade within a typical landlord’s budget?
If ministers are serious about reaching net zero and maintaining a viable private rented sector, they’ll need to strike a careful balance. Push too hard without offering help, and the exodus of landlords may only accelerate—further reducing available stock, driving up rents, and placing more strain on already hard-pressed tenants. The clock is ticking.
