TL;DR: Landlords in most countries must meet minimum energy efficiency standards before letting — F- and G-rated properties are increasingly unlettable, and penalties for non-compliance are rising sharply.
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Energy efficiency requirements for rental properties have tightened dramatically across all seven countries in recent years. What was once a disclosure formality — hand the tenant a certificate and move on — has become a hard legal threshold. Fail to meet minimum standards and you cannot legally rent the property. In some jurisdictions you also cannot serve a valid eviction notice.
The driving force is climate policy. Residential buildings account for roughly 25–30% of total carbon emissions in most developed economies, and rental housing is disproportionately energy-inefficient because tenants have little incentive to invest in upgrades they will not own. Governments have responded by placing compliance obligations squarely on landlords.
Understanding what certificate your property needs, what rating it must achieve, and what the upgrade pathway looks like is now core landlord knowledge — not optional reading.
Every jurisdiction uses some form of energy performance certificate (EPC) or equivalent. The certificate assesses the property's energy efficiency based on insulation, heating systems, glazing, and other fixed features. It produces a rating — usually on an A-to-G scale — and typically includes a list of recommended improvements with estimated costs and savings.
Key points common to all systems:
Where jurisdictions differ is in the minimum acceptable rating — and those minimums are moving upward.
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Try it free →The UK uses the Energy Performance Certificate (EPC) on an A-to-G scale. Since April 2020, all privately rented properties must have a minimum EPC rating of E before a new tenancy begins. From April 2023, this extended to all existing tenancies.
Properties rated F or G are unlettable. Landlords who let an F- or G-rated property face fines of up to £30,000 per property.
The government has proposed raising the minimum to C by 2028 for new tenancies, though exact implementation dates have shifted. Landlords should treat a C-rating as the medium-term target.
Exemptions exist (listed buildings, properties where the cost of improvement exceeds £3,500, or where all recommended measures have been made and the property still cannot reach E). Exemptions must be registered on the PRS Exemptions Register on GOV.UK.
Official resource: GOV.UK — EPC for landlords
France uses the Diagnostic de Performance Énergétique (DPE) on an A-to-G scale. The DPE was overhauled in July 2021, making it legally binding rather than informational.
Phased prohibition on letting energy-inefficient properties:
Rent increases on F- and G-rated properties are already frozen — landlords cannot raise rents even in line with the IRL index.
Official resource: ADEME — Comprendre le DPE
Sweden uses Energideklaration (energy declaration) under the Energy Performance of Buildings Directive. The declaration uses a scale of A–G and must be registered with Boverket (the National Board of Housing, Building and Planning).
There is currently no hard minimum rental standard, but landlords must provide the declaration, and Boverket publishes energy class information publicly. Properties with very poor ratings face difficulty attracting tenants and may face increasing regulatory pressure under Sweden's climate commitments.
Official resource: Boverket — Energideklaration
Australia uses the Nationwide House Energy Rating Scheme (NatHERS) for new builds (rated in stars, 0–10) but does not yet have a national mandatory minimum for rental properties. Requirements vary by state.
ACT (Australian Capital Territory) is the leading jurisdiction: from 1 April 2023, all rental properties must have a minimum energy efficiency rating, with requirements covering ceiling insulation, heating, and other measures. Properties let without meeting these standards can be subject to orders.
Victoria, NSW, and Queensland are moving toward disclosure requirements, with minimum standards expected to follow. The Residential Tenancies Act frameworks in each state govern these requirements.
Official resource: ACT Government — Rental properties energy efficiency
New Zealand's Healthy Homes Standards (HHS), fully in force since 2021, include specific requirements relevant to energy efficiency:
Compliance deadlines have passed for private landlords — all private rentals must now comply. Penalties for non-compliance can reach NZ$7,200 per breach.
New Zealand does not use an EPC-style certificate but landlords must complete a Healthy Homes Compliance Statement when entering new tenancies.
Official resource: Tenancy Services NZ — Healthy Homes Standards
Canada has no national mandatory energy efficiency minimum for rental properties. Requirements vary by province. Ontario, BC, and Alberta have disclosure and retrofit incentive programs but no rental letting ban based on energy rating.
The Canada Greener Homes Loan and provincial programs provide interest-free financing for energy upgrades, which many landlords access voluntarily to reduce operating costs and attract tenants.
Official resource: Natural Resources Canada — Greener Homes
The US has no federal energy efficiency minimum for rental properties. The Department of Housing and Urban Development (HUD) has programs for energy improvements in subsidized housing, and many states and cities have local requirements — notably New York City's Local Law 97 (2024), which sets carbon emission caps for large buildings (25,000 sq ft+) with fines for excess emissions.
For most private landlords, energy efficiency is a market differentiator rather than a hard legal requirement. The Energy Star certification and utility rebate programs are the primary federal-level tools.
Official resource: HUD — Energy Efficiency
| Country | Certificate Type | Current Minimum | Penalty for Non-Compliance |
|---|---|---|---|
| UK | EPC (A–G) | E rating | Up to £30,000 per property |
| France | DPE (A–G) | G+ banned from Jan 2025; G banned 2028; F banned 2034 | Rent freeze; future letting ban |
| Sweden | Energideklaration (A–G) | Disclosure required; no hard minimum yet | Registration penalty |
| Australia | State-specific | ACT: minimum standards from 2023; others: disclosure only | Orders; fines (ACT) |
| New Zealand | Healthy Homes Standards | Insulation + 18°C heating required | Up to NZ$7,200 per breach |
| Canada | Provincial only | No federal minimum | Provincial penalties vary |
| USA | Local only (e.g., NYC LL97) | No federal minimum | NYC: fines per tonne CO₂ over cap |
Assessors evaluate fixed features of the building. Common improvement measures and their typical impact:
High impact:
Medium impact:
Lower impact for rating (but useful for tenants):
Preparing documentation for energy efficiency compliance — whether that is a new tenancy agreement referencing the EPC, a compliance statement for Healthy Homes (NZ), or an exemptions filing — requires care and accuracy.
MmowW Scrib🐮 can help you prepare these documents accurately across 7 countries:
MmowW Scrib🐮 is a document preparation service, not a law firm. For legal advice on your specific property's compliance obligations, consult a qualified solicitor or housing lawyer.
Q: My property is listed (historic building). Do I still need an EPC in the UK?
A: Listed buildings in England and Wales may qualify for an EPC exemption if compliance with minimum energy efficiency requirements would unacceptably alter their character or appearance. However, the exemption is not automatic — you must apply to the PRS Exemptions Register and provide supporting evidence. Many listed properties still obtain EPCs and some can achieve reasonable ratings with sympathetic improvements.
Q: In France, can I still let my F-rated property if it was already tenanted before the ban?
A: The French energy restrictions currently apply to new lettings and lease renewals. Existing tenancies that continue without a new contract may not trigger the ban immediately, but rent increases are already frozen for F- and G-rated properties regardless of tenancy start date. The G-rental ban from 2028 will eventually affect all lettings. Starting improvements now avoids a disruptive gap in rental income later.
Q: Does New Zealand's Healthy Homes heating standard mean I must install a heat pump?
A: No. The heating standard requires a fixed heater capable of achieving 18°C in the main living area based on a formula accounting for room volume and climate zone. A modern wood burner, electric panel heater, or heat pump can all satisfy the standard if correctly sized. Heat pumps are popular because they are energy-efficient, but they are not the only compliant solution. The Tenancy Services NZ heating assessment tool helps calculate the required kilowatt capacity for each property.
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