Holiday Letting EPCs – Are they really required?
On 30th June 2011 a piece of legislation comes into effect that will ensure that an Energy Performance Certificate or EPC is required on Holiday Lettings. This will bring Holiday Lets into line with other properties that need an EPC, such as those currently required on sales and rental basis.
As of the 30th June 2011 any property that is let on a holiday basis for a combined period of four months or more in a calendar year will be required to have an Energy Performance Certificate. This change is an attempt by the Department of Communities and Local Government to improve the EPC requirements and to encourage potential improvements in holiday rentals.
However, this legislation is not without controversy. For a start it has not been well publicised. There is almost no mention of this change on the DCLG website and in many cases the first anyone has heard about this is from notifications issued from Energy Assessor accrediting bodies. This has led to general confusion within the industry for both assessors, holiday letting agents and property owners alike.
So what is the actual change? Well, it is little more than a change of one sentence in the DCLGs document “Energy Performance Certificates for Dwellings in the Social and Private Rented Sectors: A Guide for Landlords”. This is the document from which all guidance and regulations for EPCs in this sector arise.
Page 27 now reads:
Q. Will an EPC be needed for holiday accommodation?
A. An EPC will be required for a property rented out as a holiday let where the building* is occupied as a result of short term letting arrangement and is rented out for a combined total of 4 months or more in any 12 month period.
*A ‘building’ is defined as a roofed construction having walls for which energy is used to condition the indoor environment. This definition excludes caravan, tents, mobile homes etc.”
This change is very brief and gives no clear guidance when an EPC is expected in the process, for example is it required on a reasonable expectation that a property will go past four months of occupancy, or is it only required when a property has exceeded this limit?
Another question is what exactly is required by the agents handling these properties. Do they have to provide the EPC to any potential person using the property as they would do with an actual rented property? Will they have to display the graph on details? For that matter what constitutes an actual holiday let?
Within the change of text there is now a loose definition of what a building constitutes, but this doesn’t cover everything. For example, is a mobile home style park with hard standing and services to the property included or exempt in the new regulations?
There is also the question of practical enforcement by Trading Standards, how will they seek to enforce this legislation where there are clearly so many questions about how it works?
With the almost complete lack of publicity of this requirement there will be many people who own second properties that they rent for holiday purposes to friend and family who will fall foul of this legislation. Non marketed private sales require an EPC on the property, so will it be required of non marketed holiday lets?
It is hard to understand why this change has been kept so quiet and why there has been so little practical detail made available by the DCLG. Even the Accreditation Schemes are being forced to seek extra clarification. With the 30th June fast approaching and responsible assessors and agents looking to correctly inform clients as to the requirements this delay in information and practical detail is hard to believe.
With the DCLG promising to ‘tighten non-compliance’ and other improvements to EPCs, is this the shape of what we can come to expect in the future implementation?
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