Energy Performance Certificates for Blocks of Flats

A comprehensive guide to energy performance certificate requirements for blocks of flats. Understand EPC obligations, MEES regulations, and how to improve energy efficiency in your building. Whether you are a freeholder, leaseholder, or managing agent, this guide explains the legal requirements, the practical steps for compliance, and how professional block management ensures your building meets its energy performance obligations.

What Is an Energy Performance Certificate?

An energy performance certificate is a document that rates the energy efficiency of a property on a scale from A (most efficient) to G (least efficient). It provides an assessment of how much energy the property uses, what its carbon dioxide emissions are, and what improvements could be made to reduce energy consumption and costs. Every property in England and Wales that is sold, let, or constructed must have a valid EPC, and this requirement applies equally to individual flats within blocks of flats.

The EPC is produced by an accredited energy assessor who inspects the property and records details of its construction, insulation, heating system, hot water provision, lighting, and ventilation. The assessor inputs this data into approved software that calculates the property's energy rating. The certificate includes a current energy rating and a potential rating - showing what the property could achieve if the recommended improvements were carried out. An energy performance certificate is valid for ten years from the date of issue, provided no material changes are made to the property that would significantly affect its energy performance.

For blocks of flats, the EPC relates to each individual flat rather than the building as a whole. However, the building's communal features - such as shared heating systems, the condition of the external walls and roof, and the quality of communal lighting - can all influence the energy rating of individual flats within the block. This means that improvements to communal areas and systems can benefit every flat's rating simultaneously, making building maintenance and upgrades a key factor in overall energy efficiency. For more on maintaining your building's fabric, see our building maintenance guide.

EPC Requirements for Blocks of Flats

The EPC requirements for blocks of flats differ from those for individual houses in several important ways. Each flat within a block is treated as a separate dwelling for the purposes of energy performance certification. This means that when a flat is sold or let, the seller or landlord must provide a valid energy performance certificate for that specific flat. There is no requirement for a single EPC covering the entire building, and communal areas such as corridors, stairwells, and lobbies do not need their own certificate.

Landlord obligations are clear: any leaseholder who sublets their flat must ensure that a valid EPC is in place before marketing the property or granting a tenancy. The certificate must be made available to prospective tenants free of charge, and the energy rating must be included in any property advertisement. Failure to provide an EPC when required can result in a fixed penalty of up to two hundred pounds imposed by the local trading standards authority.

The managing agent plays a practical role in coordinating EPC assessments across a block. While the legal obligation to obtain the certificate rests with the individual seller or landlord, the managing agent can facilitate access arrangements, provide assessors with information about communal heating systems and building construction, and coordinate bulk assessments to reduce costs. This is particularly valuable in larger blocks of flats where multiple landlords may need certificates at the same time.

Where a block has a communal heating system, the energy assessor must account for the type, age, and efficiency of that system when calculating each flat's EPC rating. An older, inefficient communal boiler can drag down the ratings of every flat in the building, making it harder for landlords to meet MEES requirements. Upgrading communal heating as part of a planned maintenance programme can improve ratings across the entire block.

MEES Regulations and Minimum Energy Standards

The Minimum Energy Efficiency Standards (MEES) were introduced by the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 and set a legal minimum energy efficiency standard for privately rented properties. Since April 2020, it has been unlawful for a landlord to continue to let a property with an EPC rating of F or G - whether on a new tenancy or an existing one - unless a valid exemption has been registered. The current minimum standard is an E rating.

The government has signalled its intention to tighten MEES requirements further, with consultation on raising the minimum standard to a C rating for new tenancies. While the precise timeline remains subject to legislative progress, landlords of leasehold flats should plan ahead and consider making energy efficiency improvements now rather than waiting for regulations to change. Properties that currently hold a D or E rating may need significant upgrades to meet a future C standard, and early planning allows costs to be spread and works to be coordinated with other major works programmes.

Penalties for non-compliance with MEES can be substantial. Local authorities are the enforcement body and can impose financial penalties of up to five thousand pounds per property for breaches lasting three months or more. The penalty includes a publication penalty, where details of the breach may be published on the PRS Exemptions Register for at least twelve months. For landlords of multiple flats within a blocks of flats, the financial exposure from MEES non-compliance can accumulate rapidly.

For leasehold flats, MEES compliance can be complicated by the division of responsibilities between leaseholder and freeholder. Improvements to the building fabric - such as external wall insulation, roof insulation, or window replacement - may require freeholder consent and may fall within the scope of Section 20 consultation if the costs exceed the statutory threshold. The managing agent plays a critical role in advising directors and freeholders on how MEES affects the building and coordinating any necessary improvement works.

Improving Energy Efficiency in Blocks of Flats

Improving the energy efficiency of a block of flats requires a coordinated approach that considers both individual flats and the building as a whole. Common improvements that can raise EPC ratings across a block include loft and cavity wall insulation, upgrading communal boilers to high-efficiency condensing models, replacing single-glazed windows with double or triple glazing, installing LED lighting in communal areas, and draught-proofing entrance doors and windows throughout the building.

Each improvement carries different costs and delivers different levels of benefit. Insulation works - particularly to the roof and external walls - typically deliver the greatest improvement to EPC ratings and the largest reductions in energy costs for residents. Boiler upgrades and heating controls can also make a significant difference, especially in buildings with older communal heating systems. LED communal lighting is a relatively low-cost measure that reduces electricity consumption in common parts and contributes to the building's overall energy efficiency profile.

Where energy improvement works qualify as major works - for example, external wall insulation, full window replacement programmes, or communal boiler replacement - the costs may exceed the Section 20 consultation threshold. In these cases, the managing agent must follow the statutory consultation process, notifying leaseholders of the proposed works, inviting observations, obtaining competitive tenders, and providing a summary of tenders before proceeding. Our Section 20 guide explains this process in detail. Proper consultation protects the freeholder's ability to recover costs through the service charge and ensures leaseholders are fully informed about the works and their financial implications.

Funding options may be available to support energy efficiency improvements in blocks of flats. Government schemes such as the Green Deal and the Energy Company Obligation (ECO) have provided grants and subsidised finance for insulation and heating improvements in qualifying properties. The availability and scope of these schemes changes over time, so the managing agent should keep directors informed of current funding opportunities and assess whether the building qualifies. Balancing cost with benefit is essential - the aim is to achieve meaningful improvements in energy efficiency without placing a disproportionate financial burden on leaseholders. Planning energy works within a broader planned maintenance strategy helps to coordinate expenditure and maximise value.

The Managing Agent's Role in Energy Compliance

A professional managing agent plays a central role in ensuring that blocks of flats meet their energy performance obligations. While the legal duty to obtain an EPC rests with individual sellers and landlords, and MEES compliance is the landlord's responsibility, the managing agent is best placed to coordinate energy compliance across the building as a whole. At Block, our approach to energy compliance includes the following commitments.

  • Coordinating EPC assessments - facilitating access for energy assessors, providing building construction and heating system data, and arranging bulk assessments to reduce costs for leaseholders and landlords across the block
  • Advising on MEES compliance - keeping directors and landlords informed of current and forthcoming minimum energy efficiency standards, identifying flats at risk of non-compliance, and recommending improvement strategies
  • Managing improvement works - specifying, tendering, and supervising energy efficiency improvement projects including insulation, boiler upgrades, window replacements, and LED lighting installations in accordance with Section 20 consultation requirements where applicable
  • Keeping comprehensive records - maintaining a register of EPC ratings for all flats in the building, tracking certificate expiry dates, recording improvement works undertaken, and ensuring documentation is available to freeholders, directors, and leaseholders on request
  • Advising directors on obligations - providing clear guidance on how energy performance regulations affect the building, what the freeholder's and directors' responsibilities are, and how to balance compliance costs against the long-term benefits of improved energy efficiency

Energy compliance sits within the broader framework of building maintenance and statutory obligations. A well-maintained building with up-to-date insulation, efficient heating, and good-quality windows will naturally achieve better EPC ratings. By integrating energy performance into the overall planned maintenance programme, the managing agent ensures that energy improvements are coordinated with other works - reducing disruption, controlling costs, and delivering lasting benefits for residents and the building's value.

For buildings where significant energy improvement works are needed, the managing agent will also manage the Section 20 consultation process, ensuring that leaseholders are properly consulted and that the freeholder can recover costs through the service charge. Our major works guide provides further detail on how we manage large-scale improvement projects. To learn more about our approach to block management, visit our block management page.

Frequently Asked Questions About Energy Performance Certificates for Blocks of Flats

Do blocks of flats need an EPC?

Individual flats within a block need their own Energy Performance Certificate whenever they are sold or let. The EPC relates to the individual dwelling, not the building as a whole. Communal areas such as corridors, stairwells, and lobbies do not require a separate EPC. However, the energy characteristics of communal parts - including shared heating systems, communal lighting, and the building fabric - can influence the EPC rating of individual flats within the block. If a flat is neither being sold nor rented, there is no legal requirement to obtain an EPC, but having a current certificate is useful for understanding the property's energy efficiency and planning any improvement works.

Who pays for the EPC in a leasehold flat?

The cost of obtaining an Energy Performance Certificate for an individual leasehold flat is the responsibility of the person selling or letting the property - typically the individual leaseholder or the landlord if the flat is sublet. The EPC is not a communal cost and should not be charged to the service charge. However, if the managing agent coordinates bulk EPC assessments across multiple flats in a block - for example, when several landlords need certificates at the same time - there may be economies of scale that reduce the cost per unit. The freeholder or managing agent is not legally obliged to arrange EPCs for individual flats, but many do so as a practical service to leaseholders and landlords within the building.

What is the minimum EPC rating for renting a flat?

Under the Minimum Energy Efficiency Standards (MEES) introduced by the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, the minimum EPC rating for renting a flat in England and Wales is currently an E rating. It is unlawful for a landlord to grant a new tenancy or renew an existing tenancy of a property with an EPC rating of F or G unless a valid exemption has been registered on the PRS Exemptions Register. This applies to all privately rented domestic properties, including leasehold flats that are sublet. The government has consulted on raising the minimum standard to a C rating for new tenancies, with further tightening expected in the coming years. Landlords of leasehold flats should monitor these developments closely and plan improvement works accordingly.

Can the managing agent arrange EPCs?

Yes, a managing agent can arrange Energy Performance Certificates for individual flats within a block, although this is typically provided as an additional service rather than a core management function. The managing agent is well placed to coordinate EPC assessments because they hold access arrangements for communal areas, understand the building's construction and heating systems, and can liaise with accredited energy assessors on behalf of multiple leaseholders simultaneously. Coordinating bulk assessments can reduce costs and minimise disruption to residents. The managing agent can also advise leaseholders and landlords on the implications of their EPC ratings under MEES regulations and recommend improvements that could raise the property's rating.

How do communal heating systems affect EPC ratings?

Communal heating systems can have a significant impact on the EPC ratings of individual flats within a block. Where a building is served by a centralised boiler system or district heating network, the efficiency of that system directly affects the calculated energy performance of each flat connected to it. An older, inefficient communal boiler will typically result in lower EPC ratings across all flats in the building, even if the individual flats are well insulated and have modern windows. Conversely, upgrading the communal heating system to a more efficient condensing boiler, heat pump, or combined heat and power (CHP) unit can improve EPC ratings for every flat in the block simultaneously. The energy assessor must take the communal heating system into account when producing the EPC, using data about the system type, age, and efficiency provided by the managing agent or freeholder.

What happens if a flat has an F or G EPC rating?

If a flat has an EPC rating of F or G, it cannot be legally rented out under the Minimum Energy Efficiency Standards (MEES) unless the landlord has registered a valid exemption on the PRS Exemptions Register. Before the property can be let, the landlord must make cost-effective energy efficiency improvements to bring the rating up to at least an E. Cost-effective improvements are generally those that can be funded through the Green Deal or other third-party finance and that will pay for themselves through energy savings within their expected lifetime. If all relevant improvements have been made and the property still cannot reach an E rating, the landlord may register an exemption - but the exemption lasts only five years and must then be renewed. Local authorities are responsible for enforcing MEES regulations and can impose financial penalties of up to five thousand pounds for non-compliance. Landlords of leasehold flats should also be aware that certain improvements may require freeholder consent or may fall within the scope of Section 20 consultation if they affect the building's communal fabric or systems.

Expert Energy Compliance for Your Block

Whether you need help with energy performance certificate coordination, require advice on MEES compliance for your blocks of flats, or are looking for a managing agent that takes energy efficiency seriously, Block is here to help. We manage energy compliance for blocks of all sizes across England and Wales, ensuring your building meets its obligations under current and forthcoming regulations. From coordinating EPC assessments to managing major improvement works and electrical safety compliance, our comprehensive approach to block management covers every aspect of your building's performance.