Elmhurst Energy has submitted its official response to the government’s recent consultation on the Minimum Energy Efficiency Standards (MEES) for privately rented homes (in England and Wales), calling for a practical, balanced approach that supports both landlords and the UK’s energy efficiency goals.

The Department for Energy Security and Net Zero (DESNZ) launched the consultation in early 2025, seeking views on proposals to tighten energy performance requirements for the private rented sector (PRS). The consultation followed earlier government ambitions to ensure all new tenancies reach Energy Performance Certificate (EPC) Band C by 2028, and all tenancies by 2030.

Elmhurst has welcomed the opportunity to respond and highlighted several areas where the proposals could be strengthened or refined to ensure successful delivery.

Keep Cost, Carbon and Consumption at the Core

Elmhurst’s response to the MEES consultation reaffirms a consistent position: cost, carbon, and energy consumption must remain the core metrics on EPCs, especially as they relate to future MEES policy. This approach was highlighted in the response to the government’s EPC Reform consultation earlier this year, where we called for a simple, three-metric format—similar to a food label—to help both consumers and policymakers make informed decisions.

While fabric performance, heating system efficiency and smart readiness are recognised as useful additions, Elmhurst argues these should remain secondary, supporting metrics—not headline indicators.

Retaining the focus on cost, carbon and consumption is essential,” the consultation response states. “These are the metrics that matter most to tenants and landlords alike, and they align directly with MEES’ original purpose: reducing bills, lowering emissions, and improving comfort for those who need it most.

Complex Metrics Risk Confusion Without Support

The consultation sets out multiple options for implementing new standards using a range of metrics. Elmhurst supports flexibility in approach, such as allowing landlords to meet requirements via different combinations of performance measures. However, complexity must not come at the cost of clarity. There is a risk of overcomplication, which could lead to confusion about what is required and how it can be achieved. Clear guidelines and robust support will be essential here.

Backing a Higher Cost Cap—With Safeguards

Elmhurst has expressed support for the government’s proposal to raise the MEES cost cap from £10,000 to £15,000, recognising that a higher ceiling is necessary to help landlords achieve the proposed EPC Band C target. We acknowledge that improving the energy performance of older or less efficient properties often requires significant investment, and that the existing cap may not deliver meaningful change, particularly as energy efficiency technology evolves.

However, our support for a higher cap comes with important caveats. The changes must be rolled out in a balanced way, as without proper safeguards, an increased financial burden could risk landlords exiting the market, reducing housing supply and driving up rental costs. While we’re sympathetic to the challenges this may pose for landlords (many of whom are our own members), the cap must still reflect the scale of the ambition.

To mitigate this, Elmhurst recommends several measures:

• Clear communication and education for landlords, explaining not only their responsibilities but also the potential benefits of upgrades, including improved property value and lower tenant fuel bills.

• A robust, transparent system for managing exemptions, including a requirement for exemptions to be registered by a competent person, subject to oversight and quality assurance.

• Making the exemptions register public, ensuring accountability and enabling local authorities and stakeholders to monitor compliance.

Furthermore, within our response we have also addressed the proposal to extend the cost cap exemption period to 10 years, strongly opposing it. Instead, we recommend aligning exemption periods with the new EPC validity periods expected under EPC reform. Extending the exemption too far risks undermining the drive toward improved efficiency. Exemptions should not become a loophole!

Timelines Supported—but Must Be Realistic

Elmhurst agrees with the government’s preferred timeline of 2028 for new tenancies and 2030 for all tenancies, provided that landlords are given adequate time and support to complete improvements. We also support proposals to require a new EPC before compliance work begins and to count EPC costs toward the investment cap. We further recommend making post-improvement EPCs mandatory, ensuring tenants receive accurate and up-to-date information.

Caution Over Past EPC Use During Transition

While the consultation suggests landlords could demonstrate compliance using older EPCs during the transition period, Elmhurst warns that past certificates may not reflect current property performance, especially if changes have been made. Relying on outdated EPCs, it argues, risks creating inconsistency and confusion during rollout.

Affordability and Enforcement Go Hand in Hand

Elmhurst supports the development of a genuine affordability exemption, but stresses that it must be strictly policed to prevent abuse. We also advocate for stronger enforcement mechanisms, calling for specialist training for enforcement bodies, clearer responsibilities, and ring-fenced funding to ensure compliance checks are effectively carried out.

Short-Term Lets and Agents Should Not Be Exempt

Elmhurst recommends including short-term lets in the MEES framework, arguing that any rented property should be required to have a valid EPC regardless of rental length. We also support involving letting agents and online platforms in compliance checks once the PRS property database is launched but any obligations must be clearly defined.