The UK Government’s Warm Homes Plan, published on Wednesday 21 January 2026 is one of the most consequential policy shifts for the housing and energy efficiency landscape in recent years. Its intentions are admirable: to cut energy bills; alleviate fuel poverty and accelerate decarbonisation.
The plan puts the private rented sector (PRS) at the heart of delivery expectations—bringing both risk and strategic opportunity for landlords, brokers, lenders and industry stakeholders.
Importantly, the plan confirms that all private rented homes must achieve an EPC of C by October 2030, unless a valid exemption is registered. This is a recalibration from earlier proposals which sought an interim 2028 standard for new tenancies. Helpfully, this effectively consolidates the compliance horizon for property owners.
Through latest Landlord Leaders research, we heard that 97% of landlords have seen rising costs over the past 12 months and that 42% of professional landlords will look to borrow to fund energy efficiency changes.
Therefore, a cost cap of £10,000 per property (with certain exemptions applying for lower-value homes where the spend exceeds a percentage of valuation) will be welcome news, although details around other exemptions is lacking.
Some good news is that energy efficiency investments made from October 2025 onwards count toward this cap, and properties already meeting an EPC rating of C before October 2029 will remain compliant until their certificates expire.
What landlords need to know about the Warm Homes Plan
The strategic implications for landlords are around compliance, cost, capital allocation and competition.
For private landlords, the Warm Homes Plan finally brings clarity to a long-anticipated regulatory trajectory, but also extends a clear mandate that requires considered commercial planning:
CapEx planning becomes central to asset valuation and portfolio strategy
Meeting an EPC rating of C across a diversified property portfolio will require landlords to adopt robust capital planning practices. While the £10,000 cap provides some financial predictability, there remains significant variance in upgrade costs across building ages and types.
Allocating sufficient budget, accessing finance where needed, finding competitive supply chains for retrofit works, and prioritising interventions that deliver value both in compliance and in operational savings will be vital.
Regulatory certainty drives market risk pricing and lending behaviour
Clear regulatory timelines shape risk models across financial markets. Lenders will increasingly factor energy performance into valuation and lending criteria. Engaging with lenders in good time will be crucial to maintaining options when it comes to re-financing.
Operational disruption and supply chain considerations
Upgrading properties at scale will put pressure on an already constrained retrofit ecosystem that will take time to scale up. Skills shortages, limited installer capacity for technologies such as heat pumps or advanced insulation, and planning challenges in conservation areas could create bottlenecks.
Landlords must integrate retrofit readiness into operational plans and consider the data and information they need to engage early with supply partners, mitigate delivery risks and meet compliance deadlines. Some actions may be better implemented with a vacant property.
Exemptions and paths to compliance
The Warm Homes Plan doesn’t provide full details on the exemptions that will be available. However, it does recognise that retrofit cost versus asset value is a key determinant for Landlord decisions.
A low-value property exemption, which will lower the spending cap where £10,000 would represent 10% or more of a property’s value will be introduced, and for all priorities the most you will have to spend is £10,000.
Properties that have a valid EPC of C or above before October 2029 will be considered complaint with the regulations until that EPC expires, and any costs of incurred from October 2025 can count towards compliance at 2030.
Critical challenges to the Warm Homes Plan
Funding certainty
While government has announced grant and low-interest loan schemes that support energy improvements more broadly, clarity on targeted funding streams for the PRS remains limited. UK Finance, amongst others, has highlighted the need for sustained, long-term financial support that aligns with the compliance timeline and the scale of retrofit required.
Rely’s latest Landlord Leaders research uncovered that just over 50% of professional landlords are using savings to fund energy improvements, whilst 39% are resorting to selling some of their portfolio.
Enforcement and reporting infrastructure
A clear enforcement regime is essential to uphold minimum energy efficiency standards and create a fairer and more sustainable private rented sector.
Landlords will need reliable systems for tracking EPC data, investment spend, and compliance proof, and should keep receipts and invoices to evidence what they have spent.
Commercial asset strategy and market supply
The lack of equivalent clarity for non-domestic private rented sector standards, particularly for commercial buildings, creates a regulatory disconnect that complicates broader real estate transition planning.
Looking ahead: roadmaps and best practice
The Warm Homes Plan is not a standalone policy—it intersects with broader legislative and market shifts, from the updated Fuel Poverty Strategy to emerging reforms in EPC metrics and compliance metrics and the Renters’ Rights Act 2025. Landlords should consider the following actions:
1. Embed energy performance into investment decision making
Procurement plans, asset valuations, capex planning, and risk assessments should routinely incorporate EPC performance scenarios and upgrade pathways. This takes retrofit from a compliance cost to a value driver that can enhance tenant retention, reduce operational risk, and support decarbonisation.
2. Develop a data-driven retrofit prioritisation plan
Leveraging accurate data allows targeted planning and interventions across portfolios and particularly on high-risk assets, optimising spend and minimising disruption.
3. Engage early with tenants
Proactive tenant engagement can smooth delivery challenges, unlock grant opportunities and build trust.
The Warm Homes Plan in 2026
The publication of the Warm Homes Plan is a defining moment for the UK rental sector: the consolidation of energy performance regulation with a clear compliance horizon, tempered by mechanisms that recognise financial and operational realities. While the path forward presents execution challenges—particularly in funding certainty, supply chain capacity, and regulatory clarity—it also offers landlords a mandate to embed sustainability into business strategy and unlock shared value through enhanced living standards for tenants.
By : 
Comments
Complete the form on this page to submit your comment, and register your interest in the Landlord Leaders Community.