The association says the funding model underpinning the policy risks failure before it even starts. Ministers want landlords to spend up to £15,000 per property to achieve a minimum EPC rating of C by 2028 for new tenancies and by 2030 for all tenancies.
However, the association’s research shows that once spending on improvements exceeds £7,700, the financial equation breaks down — leaving the average landlord unable to turn a profit.
A spokesperson for the association, said: “We want all rental properties to be as energy efficient as possible.
“However, this isn’t going to happen without a serious plan to support the investments needed.
“Relying on the misguided belief that every landlord has limitless reserves to fall back on is not only wrong but will not get tenants any closer to seeing their homes made energy efficient.”
He continued: “If the government is serious about its plans, it needs to engage with the sector now to develop a clear, bespoke package to help responsible landlords invest in energy efficiency works.
“That needs to start by fixing a broken tax system which does nothing to encourage proactive property improvements.”
The warning comes in the wake of the Autumn Budget, which reduced energy efficiency funding by 25% for the current Parliament — a cut flagged by the think tank E3G.
According to the Industry Association, ministers are wrong to assume landlords represent a wealthy, homogeneous group capable of absorbing the heavy costs of property upgrades.
Official HMRC data shows that unincorporated landlords earn an average annual rental income of just £19,400 — well below the equivalent of a full-time minimum wage salary.
The Association has criticised the latest Budget for failing to provide any measures specifically designed to help the private rented sector meet the government’s energy efficiency targets.
This omission comes despite the Committee on Fuel Poverty urging ministers to introduce tax incentives to support the scale of investment required.
With landlords still awaiting clarity on the final framework, the association is calling for all energy-efficiency expenditure to be made fully deductible against income tax.
It also argues that the proposed investment cap should be linked to property values, warning that a single nationwide limit would penalise lower-value homes and risk widening the economic gap between Northern and Southern areas.