THE WARREN REPORT


The costly consequences of EPC delay


Despite promises to the contrary, the government continues to delay raising EPC standards for non-residential buildings. Andrew Warren shares his frustrations about the cost of inaction and highlights some of the other potential health and environmental benefits that remain neglected.


H


ere is a policy now worth £12.2 billion in economic growth terms for UK business. Introducing it will


add not one penny to government expenditure. Actioning it simply requires a signature. That windfall figure is not based


upon some academic theory. It is an entirely official calculation. It is drawn from that most rigorous holy of holies, an economic impact assessment actually created by and published by government itself. In a sane and logical world genuinely concerned to stimulate economic growth, these benefits should have long since been rolling in. That they haven’t is entirely due to unprecedented ministerial dithering and delay, endured now for approaching seven years. These calculations were


undertaken for a public consultation held back in 2019. The consultation set out a proposed timetable to require increased minimum energy performance certificate (EPC) standards for all new contracts in leased non-residential buildings.


Minimum standards Since 2018, all such lettings have had to be of minimum E standard. This is under legislation introduced by the coalition government in 2011, with intended changes reconfirmed within the Conservative government’s Clean Growth Strategy published in 2017. Strengthening this was


deliberately designed to address “market failures that lead to under investment in energy efficiency… the sector is not delivering savings required to meet the mandated UK carbon budgets”. The timetable is to improve these


EPCs to a C rating by 2027 and to a B rating by 2029.


Back then, the official economic 10


assessment reckoned the changes would deliver an NPV (net present value) gain to business of £8.4bn in 2014 money. In the interim, according to the Bank of England calculator, inflation has increased by 45.3%. Real energy prices have risen even more, meaning that the original calculations of the growth benefits that would accrue to UK business has grown right up to that massive £12.2 billion. But these start only once implemented. Since that public consultation, there has been absolutely no official statement whatsoever regarding confirmation or denial of either proposal or timetable. Total omerta. This inertia has been raised


regularly in Parliament. In 2022 MPs were told to expect decisions later that year. In 2023, a commitment was given to publish all responses received, both to the 2019 and a further related consultation held in 2021. That never occurred. In 2023 a decision was again


promised “shortly”. A year ago, concern at this absurd tardiness was raised by Liberal Democrat energy spokesperson Pippa Heylings MP, but Business Minister Sarah Jones then responded by saying yet again, “responses… are being reviewed”. This review was apparently “with the aim to publish in the early part of 2025". Another deadline hopelessly missed. Again.


In the dark Understandably, the British Property Federation has long had enough of the dithering. “The sector has a critical role to play in tackling climate change, yet the government continues to keep owners and investors in the dark about future minimum energy efficiency standards,” Rob Wall, assistant


director told The Times a year ago. “Lack of response to the consultation is hugely frustrating and making a tough situation worse. We support higher minimum standards. We are seeing improvements in the EPC ratings of commercial buildings, but progress is slow. We need clarity from government now.” Wall was recently quoted again in the Times, furious that “ministers have kicked the can down the road again”. Last summer, Daniel Zeichner


became the seventh different minister to claim, yet again, that “we are currently reviewing the policy situation”. It remains unclear why it was down to the (then) agriculture minister – rather than a buildings, industry or even an energy minister – to undertake this review. Members of my Federation were


repeatedly formally assured last year that the new timetable decision would finally emerge as part of the (long promised) Warm Homes Plan. Finally issued last month, it contained welcome policy decisions regarding higher EPC standards for rented homes, but absolutely nothing at all about rented non-residential


buildings. Because, guess what, the energy department press office is still repeating the mantra that “we will update in due course”.


Other benefits It is worth recalling that this remarkable £12.2 bn growth includes no calculations regarding the whole range of other benefits accruing, beyond saving businesses in leasehold buildings lots of money on fuel bills. The government acknowledges that implementing this policy would provide a whole string of identified, but curiously not financially evaluated, health and productivity benefits, including air quality improvements. For landlords, there will be increases in tenant satisfaction, hence reductions in void periods and in maintenance costs – all making subsequent lettings both more valuable and easier to achieve. And definitely an ESG Plus. In energy policy terms, it would


In a sane and logical world genuinely concerned to stimulate economic growth, these benefits should have long since been rolling in


produce estimated reductions of 49.5 million tonnes of CO₂ equivalent, plus an increase in security of energy supply. And many more jobs in the construction industry. The property industry is fed up with the uncertainty this appalling delay is causing them. As Pippa Heylings MP has said: “This is a thoroughly nonpartisan sensible measure which will benefit everyone. It is yet another example of a government that talks big about improving efficiency. But continuously fails to implement identified policies that would save, on their own estimate, £ billions of waste, whilst improving working conditions.”■


Andrew Warren


Chairs the British Energy Efficiency Federation


EIBI | FEBRUARY 2026


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