A new regime for assessing home energy performance

While EPCs are required for homes to be rented or sold, should be valuable guides to households, and are widely used in policy to set minimum standards and target funding, the existing system is ripe for reform. The government’s proposals would replace the current single rating, based on cost, with a set of metrics to describe different aspects of the home’s performance. 

Regen supports the move to a multi-metric system, as it will enable the fabric performance and heating system to be separated from cost. However, the metrics must be simple, consistent and focused on real-world outcomes to ensure EPCs are well understood and support the government in fairly accelerating the transition to clean heat.

Getting the heating system metric right

We strongly support the introduction of a dedicated Heating System Metric. This is essential to ensure EPCs actively support the shift to low-carbon heating. The proposed approach is based on efficiency and carbon intensity, which rightly prioritises efficient electric technologies, such as heat pumps.

The proposal would ensure that direct electric heating without adequate storage is insufficient to achieve band C. This is a crucial requirement. Otherwise, there would be a real risk that landlords could switch to cheap direct electric heating to meet minimum standards, while significantly increasing energy bills for their tenants and imposing unnecessary strain on electricity networks. This would undermine both consumer trust and the wider transition to clean heat.

However, for this metric to work properly, it must reflect how the whole house behaves. This means including all energy storage and generation, as these directly affect both the cost and emissions outcomes of electric heating. Thermal and electrical energy storage should not be treated differently.

Why the smart readiness metric should be scrapped

The consultation also proposes a Smart Readiness Metric to capture the value of smart technologies, such as solar and battery storage. In practice, this metric is:

• Complex and hard to justify
• Based on assumptions about future value rather than measurable outcomes
• Likely to create unintended consequences, including opportunities to game the system and for fraud.

It would also duplicate information that the other metrics should capture more meaningfully. The benefits of smart technologies are real, but should be captured directly in the Heating System Metric and the Energy Cost Metric. Creating a separate ‘smart’ score risks confusion and weakens the overall framework. It may also lead to poor policy outcomes, where homes meet EPC requirements on paper without delivering real improvements.

A simpler and more meaningful approach would be to indicate whether a home has a smart meter. This provides useful information to consumers without introducing an artificial, potentially misleading metric that could be exploited by bad actors.