The EPC consultation proposes that HMO landlords might soon need to secure a valid EPC for the entire property, even if they are renting out just a single room.

For the time being an EPC is mandatory for an HMO only when the entire house is being rented out.

The consultation argues that mandating EPCs for HMOs will bring uniformity across the private rental sector.

The consultation states: “The private rented sector minimum energy efficiency standard (MEES) regulations apply to most domestic rental properties which are required to have an EPC.

“Mandating EPCs for HMOs when a single room is rented out will ensure that HMOs will need to comply with the requirements set out in the MEES Regulations if they did not have a valid EPC before this point.

“A valid EPC for an HMO when a room is rented out would ensure that a prospective HMO tenant could make informed decisions based on the energy performance of the building and an indication of potential energy costs.”

The consultation claims that requiring landlords to obtain EPCs for HMOs, will improve living conditions for tenants.

The consultation states that compulsory EPCs for HMOs will drastically improve the quality of tenants' homes.

Many HMOs are often converted Victorian buildings, now serving as self-contained units and changing EPC rules for these types of properties could make it unattainable for landlords make their properties achieve the new proposed EPC regulation.

Additionally, the EPC consultation reveals that if the government introduces a requirement for an EPC throughout the tenancy, HMOs will need to broaden their EPC compliance accordingly.

The consultation says: “For HMOs where there are often multiple separate tenancies running concurrently for a single property, this change will require an EPC to be in place at the point of marketing for the first letting, up to and including the date the final letting comes to an end.”

However despite the consultation's details it does not address the changes in the Renters' Rights Bill, which will make all tenancies periodic, it also lacks information on how these changes will align with the new EPC regulations.

The government has stated that if the proposals are implemented, HMO landlords will have a 24-month transitional period to secure a valid EPC.

The government states that, under the current guidelines, only furnished holiday lets are required to have an EPC for short-term rentals.

The consultation states: “There are no specific requirements set out in the Energy Performance of Buildings (EPB) regulations themselves.

“The current guidance states that an EPC is only required for properties rented out as a furnished holiday let, as defined by HMRC, where the building is occupied for the purposes of a holiday as a result of a short-term letting arrangement of less than 31 days to each tenant, and is rented out for a combined total of four months or more in any 12-month period, and if the occupier is responsible for meeting the energy costs for the property.”

The government says: “The Ministry of Housing, Communities and Local Government is working with the Department for Culture, Media and Sport (DCMS) to ensure that the definition of short-term rental property within the regulations aligns with DCMS’s definition of a short-term rental property.”

The government is recommending a regulatory update to mandate that short-term rental properties must have a valid EPC when rented out. This mandate will apply irrespective of whether the tenant is responsible for paying the energy costs.