Who’s Responsible for the EPC – Landlord or Tenant?
24 Oct 2026 | By David Hernon
Responsibility for obtaining and providing an Energy Performance Certificate (EPC) generally rests with the landlord. This article explains who pays for an EPC, who renews it, tenants' responsibilities, and how landlords can maintain compliance with current EPC legislation.
An Energy Performance Certificate (EPC) is a legal requirement for most residential rental properties in England and Wales. However, responsibility can become less clear when properties are managed by agents, housing providers or other organisations on a landlord’s behalf.
Landlords remain responsible for meeting the relevant EPC requirements, but tenants also have a practical role when access to the property is needed for an assessment. Here, we look at who arranges and pays for the EPC, what tenants may be expected to do, and how responsibility works throughout the tenancy.
Who Has Legal Responsibility for an EPC?
The landlord is responsible for ensuring the required EPC is in place for a residential rental property. The Energy Performance of Buildings (England and Wales) Regulations 2012 place duties on the relevant person when a building is constructed, sold or rented.
For privately rented properties, landlords must also comply with the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, commonly known as the Minimum Energy Efficiency Standards (MEES).
Landlords are responsible for:
- Arranging an EPC assessment with an accredited Domestic Energy Assessor
- Paying for the EPC assessment
- Providing the EPC to prospective tenants when required
- Arranging a new assessment when a new certificate is required
- Ensuring privately rented properties meet the applicable Minimum Energy Efficiency Standards (MEES)
Tenants are not responsible for arranging, paying for or renewing the EPC. They may, however, need to provide reasonable access for an assessment where required under the tenancy agreement and where the landlord has followed the appropriate notice and access arrangements.
When Must a Landlord Provide an EPC?
A landlord must make a valid EPC available when marketing a property for rent where the EPC requirements apply. Prospective tenants must also receive a copy of the certificate free of charge when required by the regulations.
This means the landlord should have the EPC process in place before marketing begins, rather than waiting until a tenant is ready to move in.
For certificate validity and renewal requirements, read our guide, “How Often Do Landlords Need to Renew Their EPC?”
Do Housing Associations and Managing Agents Have the Same Responsibilities?
No. Although both organisations may arrange EPC assessments and manage compliance activities, their legal responsibilities differ.
Housing associations generally act as landlords or property owners, whereas managing agents administer EPC requirements on behalf of their clients.
| Responsibility | Housing Association / Landlord | Managing Agent |
| Legal responsibility | Holds the legal responsibility for ensuring a valid EPC is available where required. | Usually acts on behalf of the landlord or property owner rather than holding the legal responsibility. |
| Arranging EPC assessments | Commissions EPC assessments and appoints an accredited Domestic Energy Assessor. | May arrange EPC assessments under the management agreement. |
| Providing the EPC | Responsible for ensuring prospective tenants receive a valid EPC where required. | May issue the EPC to prospective tenants as part of the letting process. |
| Renewing certificates | Responsible for ensuring a valid EPC is available when a new certificate is required. | Often monitors expiry dates and coordinates renewals on the landlord’s behalf. |
| Managing compliance | Ensures the property complies with the relevant EPC legislation and, where applicable, MEES. | Supports day-to-day compliance management and administration, but typically works under the landlord’s direction. |
Planned EPC assessment programmes help organisations managing large residential portfolios monitor certificate expiry dates, maintain accurate property records, and support ongoing compliance across multiple properties.
Who Pays for an EPC?
The cost of an EPC assessment is the landlord’s responsibility.
Landlords appoint an accredited Energy Assessor to inspect the property and produce the Energy Performance Certificate. The cost varies depending on factors such as the property’s size, type, location, and whether multiple assessments are conducted across a residential portfolio.
Tenants should not be charged separately for the EPC. Where the legislation requires an EPC, landlords must provide a copy of the certificate free of charge.
Does the Responsibility Change During the Tenancy?
No. A tenant does not become responsible for arranging or paying for an EPC simply because they occupy the property.
If a new assessment is required during the tenancy, the landlord remains responsible for arranging it. The tenant may need to provide reasonable access to the property in accordance with the tenancy agreement and applicable notice requirements.
Likewise, if energy efficiency improvements are carried out during or between tenancies, it remains the landlord’s responsibility to decide whether to commission an updated EPC to reflect the property’s improved energy performance.
What Happens if a Landlord Doesn’t Provide an EPC?
Failure to provide a valid EPC where one is required may result in enforcement action by the local authority. Trading Standards can issue financial penalties for certain breaches of the Energy Performance of Buildings (England and Wales) Regulations 2012, including failing to make a valid EPC available when required by the legislation.
A missing EPC may also delay the marketing or letting of a property. In most cases, landlords must have commissioned a valid EPC before advertising a residential property for rent, and prospective tenants should have access to the certificate at the earliest opportunity.
Separately, landlords must also comply with the Minimum Energy Efficiency Standards (MEES). Letting a property with an EPC rating below Band E, without a valid exemption, may result in further enforcement action and financial penalties.
The UK government has confirmed plans to introduce higher energy efficiency standards for privately rented homes from 1 October 2030. The changes are not yet in force and require further legislation. The current minimum remains EPC E.
Does an Exemption Change Who Is Responsible?
Some residential properties may be exempt from the requirement to hold an Energy Performance Certificate (EPC). Examples include:
- Certain listed buildings
- Temporary buildings with a planned use of less than two years
- Some detached buildings with a total useful floor area of less than 50m²
- Buildings due for demolition that meet the relevant criteria
Where an exemption from the EPC requirements applies, the landlord or property owner should confirm that the property meets the relevant criteria rather than simply assuming an EPC is not required.
This is different from an exemption under the Minimum Energy Efficiency Standards (MEES). MEES exemptions apply in different circumstances and may need to be registered on the PRS Exemptions Register before they can be relied upon.
For more information about the types of property that may be exempt, read our article: EPC Requirements for Landlords.
Frequently Asked Questions
An Energy Performance Certificate (EPC) is generally valid for 10 years from the date it is issued. If the certificate remains valid, landlords can normally continue using it when marketing or letting a property without commissioning a new assessment.
A landlord should normally provide a copy of the EPC to prospective tenants before a tenancy or lease begins, where required by legislation. While the absence of an EPC does not automatically prevent a tenant from moving in, landlords may be in breach of their legal obligations and could face enforcement action if they fail to provide a valid certificate.
Tenants may be required to provide reasonable access where an EPC assessment is needed, subject to the terms of the tenancy agreement and the landlord following the appropriate notice and access requirements. The landlord remains responsible for arranging and paying for the assessment.
Yes. Many commercial premises require a commercial EPC when they are constructed, sold, or let. A commercial EPC rates a building’s energy efficiency from A (most efficient) to G (least efficient), although the legal requirements, exemptions, and minimum energy efficiency standards differ from those that apply to residential rental properties.
Yes. Some properties may be exempt from the requirement to hold an Energy Performance Certificate, including certain listed buildings, temporary buildings, and some buildings due for demolition where the relevant criteria are met.
A landlord may only rely on an exemption where the property meets the applicable legal requirements and, where necessary, the exemption has been properly registered.
Related articles
-
How Often Do Landlords Need to Renew Their EPC?
Expired EPCs can delay lettings and create avoidable compliance issues, particularly across larger residential portfolios. This article explains when landlords need a new EPC, when early renewal may be worthwhile, and how planned assessments can keep certificates up to date.
-
Where Should Smoke Alarms Be Positioned?
Correct positioning of smoke alarms is essential for reliable fire detection and occupant protection. This guide explains where alarms should be installed, where they should be avoided, the legislation and Building Regulations that influence alarm positioning, and common installation mistakes.
-
Are Fire Risk Assessment Recommendations Mandatory?
Fire Risk Assessment recommendations are not automatically legal requirements, but they should never be dismissed as optional. Responsible Persons should prioritise and manage them and maintain compliance with UK fire safety legislation.
-
Fire Risk Assessment for Block Management
Fire Risk Assessments are a key part of managing fire safety in residential blocks. This guide explains who is responsible, what an assessment should cover and how managing agents and landlords should manage findings across their portfolios.
-
Fire Risk Assessment for High-Rise Buildings
Fire risk assessments for high-rise residential buildings must consider evacuation arrangements, external walls, communal areas and building-specific fire hazards. Assessments should cover and how property and compliance teams can manage findings across complex residential buildings.
-
Fire Risk Assessment for Student Accommodation
Student accommodation presents specific fire safety challenges, from shared kitchens and changing occupancy to evacuation and sleeping risk. A Fire Risk Assessment should cover how universities, landlords and accommodation providers should manage the findings.
-
How to Choose a Fire Risk Assessor
Choosing the right fire risk assessor is essential for effective fire safety management and ongoing compliance. This guide explains what makes a competent fire risk assessor, why experience and third-party certification matter, what questions to ask before appointing a provider, and how to identify a high-quality Fire Risk Assessment.
-
Smoke Alarm Requirements for HMO Landlords
HMO smoke alarm requirements are more complex than those for standard rental properties. This guide explains how HMO fire alarm requirements differ, what landlords need to provide, and how to maintain fire safety compliance.
-
Smoke Vent Testing: A Compliance Guide for Responsible Persons
Smoke vent testing helps verify that Automatic Opening Vents (AOVs) and smoke control systems remain operational throughout the life of a building. This guide explains the legal requirements, British Standards, recommended testing frequencies, Responsible Person duties, and how planned inspection and maintenance support ongoing fire safety compliance.
-
Smoke Alarm Regulations for Landlords
Smoke alarm regulations require landlords to install, test, and maintain smoke and carbon monoxide alarms in qualifying rental properties. This article explains the legal requirements, landlord responsibilities, smoke alarm testing, HMO considerations, and the differences between England and Scotland.
