In this guide
Can I appeal the energy efficiency rating on my EPC?
What you need to know
If you’ve recently had an energy performance certificate (EPC) carried out on your property, you may be wondering if you can appeal the energy efficiency rating. Here’s what you need to know about EPCs and how to go about appealing your energy efficiency rating.
Why might I want to appeal my home’s energy efficiency rating?
Maintaining a high energy efficiency rating for your home can be a worthwhile investment. Not only does it help you save on energy costs and make your home more sustainable, but it can also add increased value to your home.
With that in mind, there may be times when you want to appeal the energy efficiency rating of your home if you feel it is not accurately reflecting the energy savings within it.
An appeal could be based on some changes or improvements you have made which were not considered when the initial visit was done.
Furthermore, higher overall ratings can also increase the resale potential of a home should you ever wish to put it on the market in the future.
What are the steps involved in appealing an EPC rating?
The first step of this process is to contact the original assessor who did the assessment. Their details, name, phone number, and email address will be on the last page of all energy performance certificates .
Always put the query/complaint in writing, such as in an email, and the reason you are appealing the rating.
Allow the assessor up to 5 days to respond. If no response is received resend the query and back it up with a phone call to ensure that it has been received.
If the assessor’s response isn’t satisfactory or despite numerous contacts the assessor doesn’t respond, then you can escalate it to their accreditation body. You will find their details at the bottom of the energy performance certificate.
The accreditation body will then carry out an audit of the energy performance certificate. The assessor will be asked to provide the dimensions, photos and site notes used to create the EPC.
The accreditation body will then update you and the assessor with it’s finding of the audit.
Are there any risks associated with appealing an EPC rating?
There are no financial risks involved in appealing an EPC rating.
If the assessor has responded to you with the reason why they believe the energy performance certificate is correct then there is a high probability that the accreditation body will also come to the same decision.
This is because they both have to follow a set of clearly defined conventions in how to interpret the data that was gathered in the home, even though you may know it’s not accurate.
One thing that can sometimes fustrate customers is what is expected from an EPC.
The energy performance certificate is not a bible and gospel of what is in the property, but more a report of what was gathered from the property that can be supported by photographic or documentary evidence.
The top 3 reasons that lead to appealing an EPC rating
Number 3
A common reason the energy performance certificate is challenged is because of the ommision of energy efficiency improvements, in particular insulation in areas where it cant be seen, such as in:
- underfloors
- flat roofs
- sloping ceilings
In these types of situations the assessor must have documentary evidence of what was done. The document must show the address of the property and the thickness of the insulation added.
Acceptable evidence would be something like an invoice or receipt or a specification of works from the contractor detailing the work that was done.
If no evidence is produced, then that element of the home will default to the building regulations applicable at the time for that part of the home.
Number 2
A recent loft conversion rating showing as poor on the EPC.
You will need to provide your assessor with documentary evidence when the conversion was built, such as architectual plans or a completion certificate from building control.
If nothing can be produced, then it is a convention that the date of the main house must be used. In most cases this will have a negative impact on the EPC.
Number 1
The number 1 reason why people challenge the rating of an EPC is when changing from storage heaters to electric panel heaters.
They often think that the EPC rating will improve but the exact opposite happens and the rating plummets.
This sometimes drops the rating below the rating required under the minimum energy efficiency standard required for domestic private rented properties.
We have a seperate article dedicated solely to this called, “the most common improvements people make that actually lowers the epc rating”.
Frequently asked questions
Can an EPC be amended?
Yes, an EPC can be amended, but only by the accredited domestic energy assessor who did the orginal assessment. You will need to contact the assessor and advise them of what you believe to be incorrect.
The assessor will investigate the problem and if they are in agreement, the originally EPC is cancelled and a new EPC is issued with the corrections made.
How do I get my EPC reassessed
If you believe an error was made on the original EPC, contact the original assessor who’s name, contact number and email address will be at the bottom of the EPC. Tell them about your concerns, preferably in writing, and ask them to reassess it.
You won’t be able to reasses an EPC if only one item has been upgraded since the orginal visit. For example, you’ve replaced the double glazing or heating systems and now want this reflected on the EPC.
In the situation above, a new site visit will be required.
You can find a local approved assessor by going to https://www.gov.uk/get-new-energy-certificate.
Summary
If your assessor has made a genuine mistake in the data entry, or you subsequently provide additional evidence, then they will be happy to correct any errors and re-lodge a new EPC.
In the majority of cases, it is usually the lack of documentary evidence from the customer that prevents the correct information being shown on the EPC.
Unfortunately, you can’t simply tell an assessor, for example, that the floors have 100mm of insulation in and expect that they will be able to enter it into the software purely on verbal say so.
So the key takeaway here is that documentary evidence is the key and it is the customers’ responsibility to produce this.
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Rickie Dickson is an experienced and qualified domestic and non domestic energy assessor. He helps homeowners and businesses in all matters relating to energy efficiency, from meeting building regulations compliance to improving a property’s energy rating score.
I have supplied documentary evidence in the form of a signed account of the work done by the joiner who did it In it he details the level of insulation he put in the walls & floor. The assessor told me that this was
of no use to him,… he needed photographic evidence or architectural.
plans,I haven’t got photos as it was done when the house was renovated over 20 years ago, Why won’t he accept the signed statement of a joiner and builder who has a lifetimes experience in the trade?..It seems because I can’t produce photos or plans then I will be doomed to have a poor EPC
Hi Mairi
If you provided documentary evidence as you stated, this should be acceptable evidence for the assessor to enter into the software. Documentary evidence is better than photographic evidence that your assessor is asking for because with a photograph, there is no proof that the photo is of that actual property and from a photo you can determine the exact thickness of the insulation.
I would suggest that you contact the Assessors accreditation body, you will find their details at the end of the epc certificate. Explain to them the issues you are having and provide them with a copy of the information you have provided the assessor and ask them if this acceptable evidence for the assessor to use. Depending on the answer that you receive back from the accreditation body, you can then present it to the assessor.
Assessors don’t deliberately try to be awkward, they are only interested in making sure that the information they have will pass an audit if the epc is selected for an audit. If their accreditation body confirms it’s acceptable evidence, then there is no reason your assessor shouldn’t update the epc.
Good luck and let me know how you get on.
Regards
Rickie Dickson
We designed and built a PassivHaus 2003-2006. It has massive insulation, solar gain from a south facing sunroom and uses very little electricity. Our fuel bills are totally covered by P.V panels and the FIT payments and this also pays most of our council tax.
Most of the work we did ourselves including detailed drawings and many photos of the insullation being fitted.
The EPC assessor has said that our bills would be £3000 per annum, yet we have proof that they are about £1000 ( all covered by the FIT) She insists on counting our sun room area into the heating quotation yet this room is built outside the main massively insulated walls with all triple glazed doors for access. We never heat this area as it is designed to be a buffer and collects solar power to heat the rest of the house with the whole house ventilation system.
Having contacted the accreditor they seem to agree with the assessor.
We know this assessment is incorrect as we have C 72 . We have seen several houses with equal or better assessments but none with our PassiveHaus standards .We are told that because our house was built 2003-2006 then all the extra insulation and many other measures cannot be cosidered.
The Times suggests EPC’s are so inaccurate that the carbon emissions are out by between 20 and 308 % . The HomeBuilding & Renovation magazine suggest EPC ratings are “staggeringly inaccurate”.
Hi Jan
I came across your comments whilst clearing my spam folder, but yours is an interesting topic so I felt I should still respond.
Most people are not aware that there are 2 methodologies used when producing an EPCs.
First, we have what’s called RdSAP which stands for Reduced Data Standard Assessment Procedure and we have what’s called SAP, which stands for Standard Assessment Procedure.
RdSAP is the general methodology used to produce an EPC in existing properties, whereby the Assessor visits the property and obtains a set of data. In a lot of cases some of the information won’t be known because the property is existing and such things as the exact thermal elements of certain items such as the walls, roof, floors, windows etc, the software will just use the worst case scenario based on the minimum building regulations for the age of that construction.
In most cases RdSAP is adequate to produce a ballpark rating for typical existing properties. However, it is severely limited when it comes to properties that have been built to a higher spec than the current building regulations for the time.
This is where SAP, sometimes called full SAP, comes in. SAP is used on all new build properties because all the elements of the property are known and are documented on building plans and therefore can be correctly calculated. This means that exact u-values can be calculated for the walls, floors and roofs. Also, windows and door sizes and orientation have to be entered, so this incorporates solar gain correctly, whereas RdSAP takes no account of this. Also “full SAP” models in the thermal junctions, again RdSAP doesn’t, and full SAP can also enter a value for air tightness if a test has been carried out.
So really a nonstandard property such as yours, would have been more accurate and produced a better EPC rating using full SAP. Here’s one example why. With RdSAP, the Assessor simply puts in the year built of the property, so for example 2003 – 2006 and the software defaults to the minimum u-values of that building regulation for that period, which would be walls: 0.35, floors 0.43, and any roof areas where the exact thickness can’t be measured 0.16.
So if your property has been built to significantly lower and better u-values than the default it’s not going to be accounted for. The u-values can be changed in the RdSAP software but the u-value has to be calculated or verified by a suitably qualified person. To be deemed suitably qualified, a person should hold an OCDEA qualification (England & Wales and Northern Ireland), Level 4 Non-domestic Energy Assessor membership, or be a member of a recognised calculation competency scheme (BBA/TIMSA (UK) or any other process recognised by Accreditation Schemes/Approved Organisations and Government.
In addition, any changes to the default u-values automatically triggers a smart audit whereby the assessment is automatically audited by the accreditation body to check that all the previously mentioned criteria has been met to justify the change of the default u-value. Now most Domestic Assessors are not going to go through that many hoops for an EPC that’s probably cost less than £100.
A full SAP EPC can only be produced by an On Construction Domestic Energy Assessor (OCDEA) and a full set of construction plans must be available. Because of the additional amount of complexity this is significantly more time intensive and expensive, costing anywhere from £180 – £380 depending on the size and design of the property.
Regarding the EPC estimating running costs compared to your actual costs, the EPC uses standard occupancy based on the size of the property and standard heating hours, but in reality, family set ups and heating hours vary. So your running cost can be significantly different compared to if another family were living in the exact same house. Also, it states on the EPC that any payments from the Feed In Tariff (FIT) are not included in the calculations.
So to summarise I don’t think your existing Assessor has done anything wrong, it’s more down to the limitations of RdSAP and that your property would have been modelled better and more accurately using full SAP. This is a service we provide. If you wished to explore this further, please let me know.
We rent a property substantially rebuilt and upgraded from its original design and condition some 30 years ago. The current EPC is from March 2013, so although it is time-expired, there is no requirement for the landlord to have a new one done until a change of tenancy. However, the EPC states “loft insulation (assumed)” when there is none whatever. Moreover, the oak frame casement windows, which are double-glazed, have lost their seals and have shrunk and moved so much that many of them allow gales in, and in some cases daylight is visible through them. We have repeatedly pointed out these deficiencies over the past 3 years, but all that has been done is to stuff the eaves with glass-fibre insulation (which we suspect is contrary to building regs for reasons of adequate loft ventilation.) The original assessor is impossible to contact and may not now be operating. If we get our own EPC done, will that effectively make the current one originally commissioned by the landlord invalid? What practical remedies are we entitled to that will not end up with us being evicted, or least having to spend on legal action? We can’t afford to buy so much oil!
Apologies in the delay in replying to this post.
There are a few points to cover hear.
1. If you get a new EPC, only the lastest EPC will be valid on the EPC register, however at the bottom of that EPC will be a link to any other previous EPCs.
2. If the EPC says “Loft Insulation Assumed”, it means when the visit was carried out that the Assessor couldn’t determine the amount of insulation. This could be down to a variety of factors such as if the roof is either a flat roof or a sloping ceiling or access was not available to the loft, or the loft was fully boarded or junked. In these scenarios the software will then make an assumption on the levels of insulation that that section of the property would have been built with based on the year it was built. In general if that section of the property was built after 1960 it will assume some levels of insulation based on the building regulations for the age. If it was built before 1960 and the insulation couldn’t be determined then it will say “no insulation assumed”, as the building regs didn’t require any insulation. If you can actually see no insulation, then an assessor should be able to determine the same and the EPC should say no insulation. A lot of the early assessments when EPCs first came out a lot of Assessors didn’t bother looking in lofts and a lot of the pre 2012 assessments were of poor quality. Now Assessors are required to take photgraphic evidence for all their data entry and is generally of better quality.
3. Regarding the windows, the EPC is not a condition report, so any defects will not be accounted for or show on the EPC. Any defects you would have to take up directly with the landlord.
4. The landlord is only legally required to make energy saving improvements to the property if the EPC is rated F or G. Currently the minimum energy rating for rental is an E rating. The government were proposing to raise this minimum rating to a C in 2025. However they did a U turn last September 2023 where they stated that it will remain an E. I’m guessing it’s because many politicians are landlords and only realised the costs involved in getting all rental properties to a C rating. Its a fine line betweeen providing enough rented properties without excessive legisation on landlords because of the general absence of affordable housing.
I haven’t even hired assessor to carried out EPC inspection. Someone produced EPC without owner’s consent.
You can have a look at the last page of the EPC which will show you the contact details of the person that carried out the EPC. You can address any queries to them. You can find your epc online by going to : https://www.gov.uk/find-energy-certificate and follow the straightforward instructions.
I have had an immersion removed and a new combi condensing boiler put in for hot water.The EPC assessor said he could not include it in the assessment.
I was supprised at this. Is he right?
Hi Ken
No I don’t think the assessor is right. This is not a very common scenario and I’m assuming that the main property is heated by electric or another non gas system, and you’ve then installed the gas condensing boiler to provide the hot water only. Strangely I came across the same thing last week. I had to look at my RdSAP conventions (this is a guidance document for Assessors). Below is an exact extract from the conventions in how to enter that set up into the software:
6.04 Separate Boiler or Heat Pump for DHW (Domestic Hot Water)
Issued March 2011, amended April 2015
Sometimes there is a separate boiler or heat pump providing domestic hot water (DHW) only. A generic boiler can be selected from the water heating options. If the boilers or heat pumps are located in the database then specify two main heating systems with:
– Main heating system 1 is the one providing space heating (e.g 100% of heat)
– Main heating system 2 is the one providing DHW (e.g 0% of heat)
The RdSAP software will then realise that main heating 2 is serving 0% of space heating and will therefore assume water heating only.
If both main heating systems supply space heating only, a generic DHW-only boiler can be selected from the water heating options…End
I hope this helps.
Regards
Rick
Just got rid of a Nibe f470 and had a new vaillant heat pump fitted with a MVHR set at 25%. Got an epc done and house is now a d instead of the c it was when built.
I take monthly meter readings and the house is more efficient but epc says it is not. What gives?
Hi Julian
There may be a few reasons for this. If the original EPC was the first new build EPC which has now been upgraded, have a look at item 5 in the following article https://epchome.co.uk/why-has-my-epc-rating-gone-down/ which explains things in more details. It could be that the new heat pump is not in the database that the assessor chooses the model from, in which case a default heat pump is chosen which will always show the worst case scenario and be the lowest efficiency for a heat pump. Also with having a MVHR most people think this will improve the rating whereas it will always lower the rating, because the running costs will be higher.
If not of the above sheds anymore light on the situation, drop me a private email at [email protected] with the full address and I can have a look at both epcs for you.
Regards
Rick
My wife and I own an end-of-terrace house in Suffolk, bought, newly built, in 2010. It has:
• triple-glazed windows throughout;
• 100mm cavity wall insulated external walls throughout;
• 100mm thick attic insulation;
• Roof mounted solar thermal panels for hot water generation;
• Air source heat pump (ASHP) for central heating (underfloor on ground floor, radiators on 1st and 2nd floors);
• ‘low energy’ LED lighting throughout.
In May 2010 an EPC awarded:
• B for Energy efficiency (current 84, potential 86)
• B for Environmental Impact (current 89, potential 91)
We were content with this assessment, though surprised that the inspector had erroneously assumed that only some, not all, of the lighting was ‘low energy’ (which it is).
The report stated that, were we to replace the solar thermal panels with solar voltaic panels, the Energy Efficiency and Environmental scores would improve to A (94) and A (97) respectively.
In June 2021, having upgraded the ASHP to a newer and even more efficient unit, we commissioned a new EPC which was carried out by a different consultant. Except for the new ASHP all the features listed above remained the same as originally.
The June 2021 EPC awarded:
C for Energy Efficiency (current C (76) with a potential rating of B (83). There was no Environmental Impact rating.
The main adverse feature (allegedly) was under the heading of “Main Heating” described as “Air source heat pump, radiators, electric” and rated “Poor”!
I queried this assessment.
The assessor’s response was “The EPC classes ASHPs as poor as they run on electricity which is the most expensive way to heat a property” and “the underfloor heating is overridden in the software if radiators are also present in the property”
My questions are:
1: Are the assessor’s two explanations (which stunned my wife and me at the time) correct?
2: Is there a deadline for objecting to his assessment, which should surely have been at least as positive as its predecessor given that the only changed circumstances was an improved ASHP?
Thank you in advance for any advice you can give.
David Argent
Hi David
The answers to your first question that the “The EPC classes ASHPs as poor as they run on electricity” is not correct, however there is a reason why it may be saying poor which I will explain further. Regarding “the underfloor heating is overridden in the software if radiators are also present in the property” is actually correct, but this would not affect the rating of the EPC, just the description on the EPC.
The answer to the 2nd question is there is no deadline for objecting to an assessment. An Assessor has to keep all notes and photos relating to an EPC for a period of 15 years in case it is ever challenged.
Without looking at the exact EPCs I can only comment on what I think is happening here. If you wish to send me the address outside of this thread to [email protected] I can be more specific.
I think there may be 2 issues why your EPC is rating lower than you expect.
The first is that you say the property was built in 2010, so the first EPC would have been done from the building plans, where every single thermal element of the property would be known and the u-value would be showing on the old EPC. So for example you would see an actual u-value as shown in this example:
Compared to the new EPC where you would see a description that simply says: Walls – insulation assumed, Floors – Insulation assumed etc.
The original new build EPC uses a methodology called full SAP (Standard Assessement Procedure), this as I mentioned is because the make up of every construction element is known.
Any subsequent EPCs uses a methodology called RDSAP (Reduced Data Standard Assessment Procedure). This is because when an Assessor visits an existing property, certain construction elements usually can’t be seen. This would normally be the levels of insulation in the walls, floors, sloping roofs, flat roof as examples. In this case the software would then use the minimum u-value for the building regulations based on the age of the property.
The problem arises if the builder had built the property to a higher spec than the building regs, which happens in many cases. So in the image example above it says the walls u-values is 0.16 W/m2K. However when this EPC is updated you won’t see any u-value on the EPC but the software will actually be using the default u-value for that age of 0.28 W/m2K in the background. The lower the u-value the more energy efficient that element is. So any increase in the u-value assumption, will result in a lower rating on the EPC.
An Assessor can’t change the default u-value unless they are qualified to calculate u-values and have the exact construction make up to do so.
Another difference between SAP and RDSAP is that with SAP, the property usually has an air tightness test done, whereas in an existing property using RDSAP a default value is used of 15 m³/h.m². Most new build properties acheive an air tightness result of between 4 and 8 m³/h.m².
You should look at your old EPC and see which methodology was used. Towards the bottom of the EPC it will say “About This Assessment”. If it says “SAP”, any subsequent EPCs will normally result in a lower EPC rating of between 2 and 4 points. See example below:
Regarding why your EPC is saying “Poor” for the Heat Pump description could be down to a variety of reasons.
An EPC Assessor has 2 ways of entering the type of heating.
The first and best way is entering the exact make and model of the heat pump from the software database. This will calculate the exact efficiency of that Heat Pump and if that model is in the database, the description will normally say Average or Good, depending on the exact efficiency of that heat pump and the flow temperature.
If the model is not in the database the Assessor can use a default air to water heat pump and the software will use the worst possible efficiency for a heat pump. This will result in the “Poor” description mentioned on your EPC.
The EPC software gets the efficiency of heating systems from the PCDF database. To be in this database, a manufacturer has to have their product independently tested by the BRE (British Research Establishment) to confirm that their product “does what it says on the tin”. If a manufacturer chooses not to have their product tested, then it won’t be in the database and the Assessor has no alternative but to use a default heat pump system. Most products are in the database.
You can check to see if your make and model is in the database by checking the PCDF Database Here
If you find your exact model, then you will need to get back to your assessor.
I hope this information has been of use to you.
Regards
Rick