Why we must rethink the UK’s obsession with the Energy Performance Certificate
Posted on: 14 November, 2025
By Jordan Turner, Senior Lecturer at the University of the Built Environment
For nearly two decades, the UK has been fixated on one measure of environmental virtue: the Energy Performance Certificate (EPC).
Introduced in 2007 under the Energy Performance of Buildings Directive, EPCs were designed to show how energy efficient a property was – and to nudge owners toward improvement. Later, the Minimum Energy Efficiency Standards (MEES) built on this idea, setting legal thresholds for landlords.
Yet as the government now plans another overhaul of EPCs, we must ask a fundamental question: are we measuring what truly matters? Because while energy efficiency has become the yardstick of progress, it’s far from synonymous with carbon reduction or sustainability.
From EPC to MEES – and beyond
When MEES arrived in 2018, it marked a significant policy shift. Residential landlords were required to achieve a minimum EPC rating of E, and commercial properties joined the framework in 2023. The logic was sound: reward energy efficiency, penalise waste, and gradually raise the bar.
New proposals suggest that properties may soon need a C – or even B – rating. On paper, that looks like progress. But beneath the surface lies a system whose reliability and enforcement are, in my opinion, deeply flawed.
A crisis of confidence in EPCs
The evidence is stark. A 2023 Switchee study of 10,000 social-housing properties found that, on average, homes rated F actually retained heat better than those rated C. In another investigation, 162 assessors were asked to rate the same commercial unit; the results varied by as much as 30 points – enough to shift a B-rated building to an E.
Such inconsistency undermines the credibility of the entire system. Yuan and Choudhary’s 2023 scholarly analysis concluded that “human error” is a significant source of EPC inaccuracy. And with training courses of wildly different lengths, costs and standards, it’s hardly surprising that two qualified assessors can produce two very different outcomes.
When confidence in the data erodes, policy built on that data becomes shaky. How can investors, developers or tenants make informed decisions when the numbers can’t be trusted?
EPC compliance ‘is largely voluntary’
Even if we overlook reliability, enforcement remains weak. Between 2020 and 2023, 23 local councils reported more than 400 breaches of MEES regulations – but issued just 26 fines. Seventeen councils imposed none at all.
RICS (2023) found that most authorities rely on landlords self-reporting breaches rather than proactive investigation. Without proper monitoring, the deterrent effect disappears – leaving compliance largely voluntary.
What EPCs don’t tell us
Even a perfectly calculated EPC only captures part of the story. It reflects insulation levels, heating systems and theoretical efficiency, but it ignores how buildings perform in real life and what materials they’re made from.
A brand-new boiler may earn a better rating than an older one – yet both burn the same fossil fuel. An ultra-insulated new home may achieve an A rating but rely on materials with high embodied carbon. In short, EPCs reward energy efficiency without addressing the true environmental cost.
If our goal is net zero, we must look beyond the energy a building uses today to the carbon it locks in over its entire life cycle.
Reform – or reinvention?
A government consultation earlier this year proposed changes to EPC metrics, adding measures such as material performance, real energy costs and smart-meter data. It also suggested including heritage buildings and shortening validity from ten years to five. These are steps in the right direction – but not enough.
The same fundamental issues remain: inconsistent training, human error, limited oversight. Without tackling these, reform risks becoming cosmetic.
We need a system that measures not just efficiency but sustainability – a tool that accounts for operational carbon, embodied carbon, and the human realities of how buildings are used. Whether that means radically re-engineering EPCs or creating a complementary framework, one thing is clear: the current model can’t deliver net zero alone.
Energy efficiency isn’t the end goal
Energy efficiency is an essential part of the story, but it’s not the whole story. Buildings should be assessed on how they reduce carbon emissions, use sustainable materials and contribute to long-term resilience.
The obsession with EPC ratings risks blinding us to what really matters: decarbonising the built environment in a way that’s fair, measurable and transparent.
Perhaps it’s time to stop asking how efficiently a building uses energy – and start asking how sustainably it performs.
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