Two-thirds of HMOs already meet EPC C — but London landlords with D and E ratings should not wait for the law to change

Two-thirds of surveyed HMOs are already at EPC A to C, but any 2030 requirement to reach band C is still only a proposal. That is the point London landlords need to keep straight.

Paragon Bank’s latest HMO research, reported by Landlord Today, found 66% of surveyed HMOs already sit in bands A to C, while none were in F or G. That is encouraging, but it does not mean the legal standard has moved. A tighter Minimum Energy Efficiency Standards (MEES) regime requiring private rented homes to reach EPC C by 2030 has been proposed before; it is not law in force today.

The legal position now

For now, the existing rules remain the benchmark. Most privately rented properties need a valid EPC where one is legally required, and properties generally cannot be let at F or G unless a valid exemption has been registered. Landlords should make decisions based on that current position, not on headlines that treat a policy direction as a settled deadline.

Why London HMO landlords still need to act

The mistake would be to read “not law yet” as “nothing to do yet”. For London HMOs, the real risk is delay.

A D-rated shared house may get to C with relatively modest measures such as loft insulation, heating controls, cylinder insulation or LED lighting. An older period conversion may need costlier work: window upgrades, insulation, boiler replacement, ventilation improvements or wider heating-system changes. If regulation is tightened later, contractors, retrofit assessors and finance will all become harder to secure at the same time.

Focus on the weak assets, not the portfolio average

A portfolio-level average is almost useless for compliance planning. One difficult HMO can absorb a disproportionate share of capital expenditure, particularly in older London stock.

Landlords should review each property by:

• current EPC band and score;
• certificate expiry date;
• recommended measures on the EPC;
• likely access issues in occupied rooms and common parts;
• whether planning or conservation constraints could affect the work.

The numerical score matters as much as the letter. A property just below C is a very different budgeting problem from one deep in band E.

Upgrade costs must be property-specific

Generic claims about “typical” EPC upgrade costs are not much use in the HMO market. Construction type, layout, services, occupancy and fire-safety requirements all affect what is practical and what it will cost.

Some HMOs will need only low-cost efficiency measures. Others will need five-figure works to move from D or E to C. That is why landlords should get assessor-led advice and property-specific quotes before committing capital.

Bills-included HMOs already have a financial reason to improve

Paragon also noted that many landlords are absorbing higher energy bills rather than passing them on. In HMOs, where utilities are often included in the rent, poor energy performance is not just a future compliance issue. It can reduce margins now.

That makes lower-rated HMOs a commercial problem even before any law changes.

What to do now

1. Audit every EPC in the portfolio, including score, expiry date and recommendation report.
2. Identify every D and E-rated property and map the most realistic route to C.
3. Get quotes early for the assets likely to need substantial work.
4. Build the likely spend into 2026–2030 cashflow planning, including follow-up EPCs, access issues and possible void periods.
5. Keep a full paper trail of reports, quotes, invoices, product specifications and post-works certificates.

The sensible reading of the Paragon data is not complacency. It is that many HMO landlords may be closer to EPC C than expected, while a smaller group with weaker stock should start planning now rather than wait for a legal deadline that may arrive with very little cheap capacity left in the market.

R&S can help London HMO landlords review D and E-rated stock, line up upgrade priorities and prepare evidence files before any EPC C rule is finalised.