New EPC Evidence Standards From 1 October: What DEAs Need to Get Right Before They Lodge

From 1 October 2026, every EPC inspection in England and Wales has to be backed by a standardised set of minimum evidence, and from November 2026 your lodgement software will ask you to declare that you have met it. These new EPC evidence standards come from an agreement between the Ministry of Housing, Communities and Local Government (MHCLG) and the Energy Assessor Scheme Operating Board (EASOB), so they apply whichever accreditation scheme you belong to.

The test behind them is simple: could an auditor rebuild your EPC from what you left on file? If the answer relies on your memory of the property, the evidence is not there. With the new landlord register opening in December, that gap now matters to more people than just you and your auditor. This article sets out what has changed, what the declaration means, and what to check in your own practice.

The Two Dates Every DEA Needs to Know

There are two changes, one month apart. Both cover Energy Performance Certificates (EPCs), Display Energy Certificates (DECs) and Air Conditioning Inspection Reports (ACIRs) across England and Wales.

1 October 2026: the standardised minimum evidence guidelines apply to all inspections carried out on or after this date. It is the inspection date that counts, not the lodgement date.
November 2026: assessment software adds a formal declaration step. Before you lodge, you confirm that you have followed the relevant methodology, conventions and evidence standards.

Neither change is optional, and neither is specific to one scheme. If you lodge EPCs in England or Wales, both apply to you.

What the New EPC Evidence Standards Cover

The new EPC evidence standards set out, category by category, what you must capture on every inspection. They are not a general call for more photos. They fall into four areas.

Floor plan: a clear sketch of every level, with measurements and area calculations to two decimal places, window measurements and orientation, and heat loss and party walls identified.
Site notes: anything mandatory not already covered by the plan or photos, plus the reasoning behind any judgement call, such as how you dated the property, how you identified the construction, or why you amended a recommendation.
Photographic evidence: front, rear and, where relevant, side elevations; construction and insulation detail, including cavity drill patterns and loft insulation depth with an overview showing it carries across the loft; each differing glazing type; heating and hot water systems, controls and labels; ventilation, renewables and meters. Photos should be clear, date stamped and geo tagged where possible.
Documentary evidence: used where a photo is not possible or a document gives a clearer answer. Under RdSAP Convention 9.02 it must be specific to the property and detailed enough for an auditor to verify the item independently.

Documentary evidence is not a default substitute for a site visit or a photograph you could reasonably have taken. Where you use it instead of a photo, your site notes need to say why.

On a recent assessment, there was no access to the hot water cylinder, which automatically flags an assessment for audit under the smart audit rules. I made sure the evidence I did have was robust, including a narrative in the site notes explaining the situation. The audit was passed successfully. When something cannot be photographed, your site notes have to do that work instead.

For the full category by category list, see our DEA minimum evidence requirements field guide.

The November Lodgement Declaration

From November 2026, your EPC software will not let you lodge until you have confirmed that the assessment follows the correct methodology, the current conventions and the new evidence standards. In practice it is one extra step before you submit.

No specific day in November has been published yet, so keep an eye on your scheme’s bulletins and your software’s release notes over the coming weeks.

Why the declaration changes the stakes

Until now, a missing photo or a thin site note was a shortcoming an auditor might pick up months later. From November, it sits behind a declaration you made yourself at the moment you pressed submit. The work in the field has not changed; what has changed is that you are putting your name to it, formally, every time.

Why This Matters More Once the Landlord Register Opens

The evidence changes are not officially linked to the Renters’ Rights Act, but the timing matters. From 15 December 2026, the government’s Register Your Rental Property service begins a regional rollout in England, starting with the West Midlands and reaching every region by 14 November 2027.

Government guidance says landlords will be asked for their EPC details and, where the property falls below the minimum standard, details of a registered minimum energy efficiency standards (MEES) exemption. Councils will have access to that information to help target enforcement.

That turns the EPC you lodge into a document a landlord relies on to show compliance in a government system. A rating that will not stand up to scrutiny was always a risk for the assessor. Now it becomes the landlord’s problem too, and quickly. Note that the register covers England only, while the evidence standards apply in both England and Wales. For the landlord side of this, see our guide to the rental property register for Milton Keynes and Northamptonshire landlords.

Checks to Make in Your Own Practice Now

The quickest way to find your gaps is to test your recent work against the new list. These five checks cover the most common weak spots.

Review your last five lodged EPCs against the minimum evidence list. Look for loft coverage across the whole loft rather than one corner, all elevations rather than just the front, and readable labels on heating and hot water equipment.
Check your camera or app settings so photos are date stamped and, where possible, geo tagged.
Wherever you rely on documentary evidence instead of a photo, make sure your site notes record why, in line with RdSAP Convention 9.02.
If you mentor or train, make the new standard the baseline for trainee sign off from 1 October, not something to teach later.
Read your lodgement software’s release notes as November approaches, so the declaration step does not arrive as a surprise halfway through a busy week.

None of this is extra work for its own sake. It is about making sure that what you already do on site is what actually ends up on file. If you are still getting to grips with the conventions behind all this, our summary of the RdSAP 10 updates is a useful companion.