Written by Tim Holman – Head of Consultancy, MSc, MEng, CEng, MEI
Tim directs TEAM’s consultancy practice, applying 25+ years in strategy, audits, metering and compliance to deliver robust, audit‑ready results for clients
The UK Government has released a partial response to its wide‑ranging consultation on reforms to the Energy Performance of Buildings (EPB) regime. This marks a significant milestone in a multi‑year modernisation effort aimed at improving the accuracy, usability and regulatory alignment of energy performance tools such as Energy Performance Certificates (EPCs), Display Energy Certificates (DECs) and Air Conditioning Inspections.
The partial response addresses what EPCs should measure and when EPCs should be required, with further elements due in a later publication.
This briefing summarises the UK Government’s published response to the Energy Performance of Buildings (EPB) regime reform consultation.
Context and Purpose of the Reform
The EPB framework, originally introduced between 2007 and 2012, now underpins a wide array of UK housing, net‑zero and energy policy. However, the Government recognises that the system is no longer fit for purpose, with outdated metrics, inconsistent data quality, and limited usefulness for consumers and building owners.
Between 4 December 2024 and 26 February 2025, the Government conducted an extensive consultation that received over 1,600 responses, covering landlords, homeowners, energy assessors, financial institutions, consumer groups and heritage building representatives.
The Government states that reform is essential to support:
- Net zero emissions by 2050
- Reduced fuel poverty
- Higher building performance standards
- Better decision‑making for consumers and property professionals
Update: Delay to Implementation (March 2026)
On 9 March 2026, following industry engagement, the Government confirmed that the rollout of reformed domestic EPCs has been delayed to the second half of 2027. It will work with industry and devolved administrations to agree a new launch date and a shared implementation plan by summer 2026.
This delay acknowledges the scale, complexity and supply‑chain demands of transitioning to an entirely new assessment methodology.
How Commercial EPCs are Affected
For commercial properties, the Government will retain the single carbon‑based Environmental Impact Rating (EIR) as the headline metric, given its established role in emissions reporting and regulatory compliance.
This provides stability for organisations relying on Commercial EPCs for ESG reporting and investment planning.
When Commercial EPCs Will Be Required
The partial response outlines several proposals to tighten the circumstances under which EPCs must be provided:
a) Commercial EPCs before marketing
A valid Commercial EPC would be required before a property is marketed (currently EPCs can be obtained within 28 days of marketing). This aims to ensure immediate access to energy performance information.
b) Commercial EPC validity period
Despite calls for shorter intervals, the Government intends to maintain the 10‑year validity period for both existing and reformed EPCs.
c) Wider coverage
The partial response also signals stricter and clearer EPC obligations for:
- HMOs (Houses in Multiple Occupation)
- Short‑term lets
- Buildings previously exempt under heritage rules.
These clarifications are intended to improve consistency across the rental sector.
DECs and Air Conditioning Inspections
A further Government response, to be published later in 2026, will address Display Energy Certificates (DECs), including DEC rating methodology, data quality and transparency, and how organisations interpret and use DEC ratings.
Integration of TM44 Frequency
Reforms are expected to strengthen the quality and usefulness of air conditioning inspections, which may influence how organisations plan and schedule TM44 air conditioning inspections, including reviewing and optimising their TM44 Frequency as part of a wider compliance and maintenance strategy. This reflects the Government’s intention to enhance the reliability and impact of ACIRs.
What Happens Next
The Government continues to develop regulatory proposals, including:
- A forthcoming response covering DECs, EPC/DEC data, ACIRs and quality assurance
- A shared implementation plan for the delayed EPC reforms
- Alignment with the upcoming Home Energy Model.
In the meantime, the modernised EPB framework remains central to UK net zero and building safety policy, and organisations should prepare for more detailed, data‑rich and performance‑oriented certification requirements.
Conclusion: A Transformational Shift in Building Energy Regulation
The Government’s partial response shows a decisive move toward a more sophisticated, data‑driven EPB regime. With new EPC metrics, strengthened reporting expectations, and forthcoming changes to DECs and air conditioning inspections, including potential implications for TM44 Frequency, organisations should begin reviewing portfolios, data readiness and compliance processes now.
TEAM Energy will continue to monitor policy developments and provide guidance to help organisations stay compliant and capitalise on the opportunities presented by a reformed EPB framework.
From our experience supporting organisations with EPCs, DECs and TM44 compliance, the key practical impact of the Government’s response is likely to be increased emphasis on data quality and certificate validity rather than immediate metric changes.
Updated February 2026: Reflects the Government’s latest response following the EPB regime reform consultation.