How Long Should EPCs Be Valid For?

In December 2024, the government published the long-awaited consultation on EPC Reform, titled Reforms to the Energy Performance of Buildings regime. The consultation details a number of proposed changes to the EPB framework, including changes to the validity period of Energy Performance Certificates (EPCs) and Display Energy Certificates (DECs).

Elmhurst has carefully reviewed the consultation and proposals specifically concerning Domestic and Non-Domestic EPCs (DEC validity is covered in its own article) and has shared our insights on the direction we believe reforms for these energy certificates should take.

When 10 years is too long

Since first publishing our Almanac in 2019, Elmhurst has firmly advocated that an EPC should only be valid for 3 years. This is driven by the fact that properties can (and do) change within this time period, particularly sale properties, when new owners (especially buy-to-let landlords) make improvements upon taking ownership.

10 years is far too long a validity period for anything requiring useful information for a viewer or key stakeholder. Its even worse if you need to use that information or data for something useful or regulatory.

Currently, properties can transact using a (up to) 10 year old EPC. This could potentially contain out of date information, such as property features, recommendations, carbon factors and running costs and savings. This almost entirely negates the value of the EPC for the buyer or renter. Additionally, the methodology used to produce the EPC will have changed in that time period. Indeed, we are about to see the launch of two new methodologies this year, in RdSAP 10 for existing dwellings and the Home Energy Model (HEM) for new dwellings. These will produce greater accuracy in EPCs with different costs, and also recommendations with updated savings.

The validity period is also crucial to all stakeholders when considering the requirements in other legal contexts, such as property misdescriptions. The longer the validity, the more out of date/inaccurate the descriptions on the EPC and the greater the risk of falling fowl of this legal provision.

As a side note, the Scottish Government has recently responded to their own EPC consultation and concluded that they are adopting a 5-year validity period. We may be entering a period in a few years time where England, Wales and Northern Ireland have a different validity period to Scotland, and as far as Elmhurst are concerned, this should be absolutely workable and reasonable.