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The deadline is fixed: privately rented homes in England and Wales must reach EPC band C by 1 October 2030. The government’s response to its consultation, published on 21 January 2026 as part of the Warm Homes Plan, settled the two numbers landlords had been waiting for.

The numbers that matter

The cost cap is £10,000 per property, reduced from the £15,000 originally proposed. Once you have spent that on qualifying works without reaching band C, a ten-year exemption can be registered. The cost of the EPC assessment itself and of retrofit advice both count towards the cap.

There is also a property value adjustment: for properties valued below £100,000, required spend is capped at 10% of value.

Government estimates put average per-property cost at around £5,400, with fabric improvements to be prioritised before secondary measures.

For a single property that is a manageable number. For a ten-property portfolio it is a £54,000 to £100,000 capital programme with a hard deadline — and that is the planning problem.

Why this is a lending question, not just a building question

Two reasons. First, most landlords do not have that sum sitting in cash, so it has to be raised. Second, energy performance is already feeding into lending criteria and valuation. Several lenders restrict or decline on F and G rated stock, green product ranges price D-and-below differently, and a property that cannot be let lawfully after 2030 is a property a valuer will discount.

Doing the work is therefore both a compliance obligation and, on most portfolios, a protection of borrowing capacity.

The funding routes compared

Further advance from your existing lender. Usually the cheapest option if you have equity and the rent supports it. Same lender, same charge, often a simple process. Limited by interest cover, so check what the rent actually stresses to before assuming the money is there.

Remortgage with capital raising. Sensible when your current deal is ending anyway — you refinance and release the retrofit budget in one transaction, with one set of fees. Time it to the end of a fixed period to avoid early repayment charges.

Second charge loan. The right answer when you are on a legacy rate you do not want to disturb, or facing a significant ERC. Rates are higher than a first charge and the first lender’s consent is required, but on a cheap existing rate the total cost is frequently lower than remortgaging the whole balance.

Green mortgage products. A growing number of lenders offer a rate discount, a cashback, or a fee reduction where the property reaches a given EPC band, sometimes with a retrospective benefit if you improve the rating within a set period after completion. Worth checking at every refinance — the saving is modest per property but it compounds across a portfolio.

Bridging, then refinance. Where the property is currently unmortgageable or unlettable, a bridge funds the purchase and the works, and a term buy-to-let takes out the bridge once the property is improved and let. Fast and flexible, but expensive, and it needs a firm exit.

Unsecured business borrowing. For smaller works on a company portfolio, sometimes simpler than disturbing any security — but check the rate against a second charge before assuming it.

Sequence the portfolio, do not do it all at once

Work property by property, in this order:

  1. Get current EPCs. Many landlords are working from certificates that are years old and do not reflect work already done, or the assessment methodology now in use.
  2. Rank by gap. A property at D needing loft and cavity insulation is a very different job from a solid-wall Victorian terrace at F.
  3. Identify the properties that will hit the cap without reaching C. These are your exemption candidates — but you still have to spend the £10,000 to register it, so they need budgeting for too.
  4. Time the funding to fixed-rate expiries so you raise capital without paying early repayment charges.
  5. Start with the properties whose rating is restricting your borrowing now, not the ones that are furthest from C.

Do not leave this to 2029

Three reasons. Contractor capacity will tighten sharply as the deadline approaches, and prices with it. Lending on poorly rated stock is likely to keep narrowing, so raising the money gets harder the longer you wait. And a property that misses the deadline cannot lawfully be let to a new tenant — which turns a capital expenditure problem into an income problem.

Landlords who fund this over four years, aligned to their refinance dates, will do it far more cheaply than those who fund it in a rush in 2030.

Planning a retrofit programme across a portfolio? Send us the schedule with current EPC ratings and we will map the funding to your refinance dates.

Related services

Most buy-to-let mortgages, and some forms of commercial, bridging and development finance, are not regulated by the Financial Conduct Authority. Your property may be repossessed if you do not keep up repayments on a loan secured against it. Giles Finance is authorised by the Financial Conduct Authority (No. 726857) to transact regulated mortgages. Giles Finance is a trading style of Giles Finance & Consultancy Services. This article is general information, not advice.

Giles Finance · 11 Wren Road, Dagenham, Essex, RM9 5YN · 020 8088 2211
Offices: Dagenham · Putney · Rainham · Willenhall
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