TL;DR
- Letting an F or G rated property has been illegal since April 2020 — this is not a future problem
- The fine is up to £5,000 per property from Trading Standards
- The £3,500 cost cap means you must spend up to this amount trying to reach Band E before an exemption applies
- Valid exemptions exist but must be registered on the PRS Exemptions Register before letting
- Solid wall properties are the most difficult and expensive to upgrade — and the most likely to qualify for the cost cap exemption
- The 2030 Band C target means a two-step upgrade journey for properties currently at F or G
If you own a rental property rated F or G, you are already in breach of the Minimum Energy Efficiency Standards unless you have a registered exemption. This is not a warning about future legislation — the ban on letting F and G rated properties has applied to all tenancies, including existing ones, since April 2020.
This article explains the legal position, the exemptions available, and the realistic upgrade options for the most common property types affected across Bedfordshire, Cambridgeshire and Hertfordshire.
The Legal Position Right Now
The MEES Regulations require all privately rented residential properties in England and Wales to achieve at least a Band E rating. Since April 2020, this has applied to all tenancies — not just new ones. Letting a sub-standard property without a registered exemption is a breach of the regulations regardless of how long the tenancy has been in place.
The penalty is a fine of up to £5,000 per property, issued by the local Trading Standards authority. Trading Standards departments across the region have become more active in energy efficiency enforcement in recent years, and referrals increasingly come from tenants, letting agents, and mortgage lenders who flag non-compliant EPCs in the course of other transactions.
Beyond the fine, there is a practical problem: a landlord who has not provided the tenant with a valid EPC may be unable to serve a valid Section 21 notice to regain possession. The intersection of EPC compliance and possession rights is a trap that catches landlords who have otherwise managed their properties carefully.
What an F or G Rating Usually Means
Properties rated F or G — SAP scores below 38 — share a recognisable set of characteristics. Across this region, the most common types are:
- Pre-1940 solid brick wall properties with no insulation on the walls at all
- Victorian and Edwardian terraces in Bedford, Cambridge, Hitchin and Stevenage where the construction predates cavity wall building methods
- Older rural properties in Hertfordshire and Cambridgeshire villages that have never had significant energy efficiency improvements
- Some ex-local authority properties that missed improvement programmes
The solid brick wall is the defining feature. A solid 225mm brick wall has a U-value of around 2.0 W/m²K — nearly ten times worse than a well-insulated modern wall. No amount of loft insulation or boiler replacement fully compensates for this, which is why these properties cluster at the bottom of the rating scale.
A Typical Case: The Hitchin Terrace
This situation represents a pattern that comes up regularly across the region.
A landlord in Hitchin owned a Victorian end-of-terrace that had been in the family for decades. The property had a relatively new gas combi boiler installed in 2021, uPVC double glazing throughout, and 200mm of loft insulation — all perfectly reasonable. But the solid brick walls had never been touched, and the ground floor was an uninsulated suspended timber floor. The EPC came back at F-33.
The assessor's recommended measures: external wall insulation (estimated cost £8,000–£12,000), internal wall insulation as an alternative (£5,000–£8,000), and floor insulation (£1,500–£2,500). Every single route to Band E exceeded the £3,500 cost cap. The landlord obtained three written quotes, all confirming costs well above the threshold, and registered a cost cap exemption on the PRS Exemptions Register. The property can now legally be let for five years under the exemption — at which point the situation must be reviewed.
This is the correct process. What the landlord had been doing before — letting the property without any exemption registration, unaware that the 2020 rule applied to existing tenancies — was not.
Your Three Realistic Options
Option 1: Carry Out the Improvements
If the work required to reach Band E would cost less than £3,500, you are expected to carry it out. For properties with cavity walls that simply have not been insulated, this is often achievable within the cap. A combination of cavity wall insulation (£500–£1,200), loft insulation top-up (£300–£600), and boiler controls (£200–£400) can move a borderline E-band property above the threshold.
For solid wall properties, getting to Band E from F or G is rarely achievable within £3,500. The cost cap exemption is the realistic route.
A landlord with a 1930s cavity wall semi in Biggleswade was in a different position to the Hitchin case. The property rated E-39 — barely above the F boundary. Three measures: cavity wall insulation (£800), loft insulation (£450), and a new boiler (£1,900). Total: £3,150. The property moved to D-58. No exemption needed, full compliance achieved, and a better rating for the next tenancy marketing.
Option 2: Register an Exemption
If you genuinely cannot reach Band E within the £3,500 cap, you can register an exemption on the PRS Exemptions Register via the government website. Valid exemptions include:
The cost cap exemption. If the recommended improvements cost more than £3,500 to implement — demonstrated with three written quotes — you can register an exemption. Valid for five years, after which it must be reviewed.
The third-party consent exemption. If improvements require consent that has been refused — planning permission for external wall insulation, or a freeholder's permission for work in a leasehold flat — you can register on this basis.
The devaluation exemption. If an independent RICS surveyor confirms the improvements would reduce market value by more than 5%, an exemption applies. Relevant occasionally for listed buildings or properties in conservation areas — there are several in Cambridge, Ely and the Hertfordshire market towns where external wall insulation would not receive planning consent.
The key point: exemptions must be registered before the property is let. An unregistered exemption does not protect you from enforcement.
Option 3: Sell
For some landlords, the economics of upgrading simply do not work — particularly where a solid wall property would require £8,000–£15,000 of wall insulation to reach Band E, and the rental yield does not justify the investment.
Selling is a legitimate exit strategy. You can sell with an F or G rating — you simply cannot let with one. The buyer may factor upgrade costs into their offer, but that is a market negotiation.
If you are considering selling, get an up-to-date EPC before marketing. If the property has had any improvements since the last assessment, the current rating may be better than you expect — and knowing the accurate figure gives you a stronger starting point.
The 2030 Complication
Getting to Band E is the immediate legal requirement, but it is not the destination. The proposed trajectory raises the minimum to Band C by 2030. For a property currently at F or G, that is a two-step journey: first to E (now), then to C within the following four years.
For solid wall properties that reach E via a cost cap exemption, the 2030 Band C requirement may require substantial wall insulation expenditure that the exemption allowed deferring. The exemption buys time — it does not eliminate the longer-term upgrade question.
Getting a Realistic Assessment
If your property carries an F or G rating — or if you are not sure of its current rating — the starting point is an up-to-date EPC. The certificate tells you the current SAP score, the potential score with recommended measures, and an itemised improvement list with estimated costs.
From that data, we can work through which route makes sense for your property, whether the cost cap exemption is likely to apply, and what the realistic path to Band C looks like over the next four years.
We cover properties across Bedfordshire, Cambridgeshire and Hertfordshire — from Bedford and Sandy through to Cambridge, Ely, Stevenage, Hitchin and the surrounding villages. Contact us to book an assessment or discuss your options.
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