EPC for HMOs and Holiday Lets: Who May Need an EPC That Did Not Before
Yes, more properties are likely to need an EPC in future, but not yet. The government has said it intends to require an EPC for a whole house in multiple occupation (HMO) when even one room is let, for short term lets such as holiday lets, and for any property at the point it is marketed. None of these changes is in force today.
If you let rooms, run a holiday let or are about to list a property, it is easy to read a headline that makes all this sound settled, or to assume none of it will reach you. Both are risky. This guide explains the proposals on EPC for HMOs and holiday lets, what is still undecided, and what you can sensibly do now. It reflects the government’s published position at 12 October 2026.
What Has the Government Said About EPC for HMOs and Holiday Lets?
In its partial response to the energy performance of buildings consultation, first published on 21 January 2026, the government said it intends to update regulations in three ways.
- A valid EPC will be needed at the point a property is marketed, rather than up to 28 days afterwards.
- A valid EPC will be needed for a whole HMO when a single room is let.
- Short term rental properties, including holiday lets, will need a valid EPC whoever pays the energy bills.
The same response says the government also intends to remove the exemption for heritage properties. All of this is described as an intention, subject to parliamentary approval, so it is not law yet.
When Will These Changes Happen?
Not yet, and not in October 2026 as first planned. The government has moved the launch of its EPC reforms to the second half of 2027, following its engagement with industry on the delivery timeline. The government said it would agree a new launch date and shared implementation plan with industry by the summer of 2026, and the GOV.UK page has not yet been updated with one.
Until then, the current rules apply. The government has also said a further response will follow on the points still outstanding, and at the time of writing we have not seen it. It is worth checking the GOV.UK consultation page before you make any decisions.
Do HMO Landlords Need an EPC for Each Room?
No. The proposal is for one EPC covering the whole property, not an EPC for each room. Current guidance says an EPC is not required for the whole HMO when a single room is let, and that is the position the government intends to change.
The consultation also proposed a 24 month transitional period for HMO landlords to obtain an EPC. A majority of respondents agreed, but the government has not confirmed it. It has said it will finalise when minimum energy efficiency standards apply to properties brought into the EPC regime in its final response. Please treat the 24 months as a proposal, not a promise.
What this could mean in practice
In shared houses, the practical difficulty is usually access. An assessor needs to see every habitable room, and with different tenants in each room that takes planning. Some respondents to the consultation also noted that the calculation method may not suit very large HMOs.
Will Holiday Lets Need an EPC?
The government intends that they will. At the moment there is no specific requirement written into regulation for short term lets, although guidance sets out where an EPC is needed. The proposal would require a valid EPC whoever is responsible for the energy bills.
Holiday let owners raised understandable concerns, particularly for older and historic buildings where some improvements may be costly or impractical. The government has said it will not apply the new minimum energy efficiency standards for private rented homes to short term lets at this time, although it is keeping that under review. So the proposal is about holding an EPC, not about being required to carry out improvements.
What Does an EPC Before Marketing Mean for Sellers and Landlords?
It would mean having a valid EPC in place when marketing begins, instead of up to 28 days after. If you are selling or letting, that moves the EPC from a task you tidy up later to something you sort before the listing goes live.
A sensible habit, whatever the final rules, is to book your EPC at the same time as your photographs and professional floor plan. It means nothing holds up your listing, and an EPC you already hold stays valid for ten years.
What Is Confirmed and What Is Still Pending?
The government has confirmed its intentions, but not the detail. Here is where things stand.
Stated as intended policy:
- an EPC at the point of marketing
- a whole property EPC for an HMO when a single room is let
- an EPC for short term lets, whoever pays the bills
- the ten year validity period retained for new style EPCs, with existing EPCs keeping their ten years
Still to be settled:
- the length and terms of any HMO transition period
- when minimum energy efficiency standards will apply to HMOs, which the government will finalise in its final response (short term lets are not covered by those standards at this time, but that is under review)
- whether a new EPC will be needed when an existing one expires during a tenancy
- the exact start date, now expected in the second half of 2027
What Should Landlords Do Now?
You do not need to rush, but you can prepare calmly.
- Check whether you hold a valid EPC for each property, and when it expires, using the GOV.UK EPC register.
- Keep a valid EPC where you already have one. The government intends existing EPCs to keep their ten year validity, so there is no need to replace one early.
- If you let rooms or run a holiday let, plan how an assessor could get access to every part of the property.
- Keep your records together. Our guide to the rental property register for Milton Keynes and Northamptonshire landlords explains what landlords may be asked for, and our guide to EPC Band C for landlords covers the wider 2030 plans for private rented homes.
For the broader picture on how reform affects owners and landlords, see our article on EPC reform and what it means for homeowners and landlords.
Frequently Asked Questions
If you are not sure whether a property you let or plan to list will need an EPC, or you would like to check when your current certificate expires, Bluewire Hub carries out EPCs for landlords across Milton Keynes, Northampton, Towcester, Daventry, Buckingham and Brackley. Get in touch.
