The Warm Homes Plan 2026 has entered a new phase. Speaking at Labour Party Conference, Energy Secretary Miatta Fahnbulleh announced that the Government’s £15 billion home-upgrade programme will be devolved to mayors, local authorities and communities through a new Great Home Upgrade programme: delivered “postcode-by-postcode, street-by-street, community-by-community”.

That local approach could make retrofit more targeted, practical and responsive to the housing stock in each area. However, it also creates new questions about funding routes, accountability and Warm Homes Agency compliance.

At the same time, a new cross-sector report from the National Residential Landlords Association (NRLA) and Energy Saving Trust is demanding urgent clarity on the reformed Minimum Energy Efficiency Standards (MEES) regime. With the proposed requirement for EPC C by 2030 for landlords, the sector cannot afford to wait for every detail before beginning to plan.

We have spent more than 15 years working hands-on as retrofit installers before moving into assessment, coordination and compliance. Our view is clear: the organisations that start building a reliable evidence base now will be best placed to manage the final four years without inflated costs, rushed installations or avoidable compliance risk.

Why the Warm Homes Plan 2026 is becoming local

The Government’s Warm Homes Plan already sets out a major expansion of domestic energy efficiency, including:

• Up to £15 billion of public investment.
• Up to five million homes upgraded by 2030.
• New minimum energy efficiency standards for rented homes.
• A proposed Warm Homes Agency to coordinate advice, delivery and consumer protection.
• Greater use of local authorities, mayors, social landlords and regional supply chains.

The Great Home Upgrade takes this principle further. Instead of treating retrofit as a series of disconnected national schemes, local areas will increasingly be expected to understand their own housing stock, identify priority streets and coordinate delivery across tenures.

That creates opportunities for councils and housing providers to combine grant funding, private finance, local skills programmes and area-based procurement. It also means that landlords and installers may face different delivery processes, evidence requirements and funding timetables depending on where a property is located.

For organisations operating across multiple regions, consistency will be essential. A strong Retrofit Coordinator and a documented PAS 2035 process can provide that consistency, even when funding is administered locally.

The MEES rulebook is still developing

The NRLA and Energy Saving Trust report, following a Parliamentary roundtable chaired by Clive Betts MP, identifies five urgent requirements:

1. A published implementation roadmap.
2. Clear exemption criteria and guidance.
3. Affordable green borrowing for smaller portfolio landlords.
4. A stronger apprenticeship and installer training pipeline.
5. Properly resourced local enforcement.

The report is right to focus on implementation. The policy direction is now much clearer, but important practical questions remain around how MEES will interact with reformed EPC metrics, the Home Energy Model, property exemptions, cost caps and local enforcement.

The Government has confirmed that privately rented homes in England will need to meet an EPC C standard across two metrics by October 2030, unless a valid exemption applies. The proposed spending cap is £10,000, with further provisions for lower-value properties and certain circumstances.

However, an EPC rating is not a retrofit plan. It is a modelled assessment and may not identify every building defect, ventilation problem or sequencing issue. It also cannot replace a detailed understanding of the property’s construction, condition, occupancy and intended improvement pathway.

This is why we recommend that landlords do not wait for the final EPC methodology before starting sensible, evidence-led scoping.

What landlords should do before the EPC model is rewritten

A property that is currently rated D or E may require several measures to reach the future standard. A property that appears close to C may still have defects, poor ventilation or limited improvement options that affect the final outcome.

A properly commissioned assessment can identify:

• The building’s construction type and condition.
• Existing insulation, heating and ventilation systems.
• Damp, mould, moisture and structural risks.
• Air leakage and potential airtightness issues.
• Suitable improvement measures and their likely sequence.
• Measures that may be eligible for funding or green finance.
• Evidence that may support a future exemption application.

A Retrofit Assessor survey and Whole House Retrofit plan should therefore be viewed as an investment in decision-making, not simply a compliance cost.

The plan can be updated as regulations, funding and technologies develop. It gives you a practical route from the property’s current condition to its long-term performance, while reducing the risk of installing one measure that makes a later measure more difficult or expensive.

Why Retrofit Coordination Services matter in a devolved market

Under PAS 2035, the Retrofit Coordinator is responsible for overseeing the retrofit process, managing risks and ensuring that the required documentation is produced. This includes the Retrofit Assessment, risk assessment, improvement option evaluation and Medium-Term Improvement Plan.

Our Retrofit Coordination Services help bring structure to projects involving multiple properties, installers, funding bodies and stakeholders.

In practice, a Retrofit Coordinator helps you to:

1. Translate assessment findings into a coherent retrofit strategy.
2. Check that proposed measures are compatible with the building.
3. Manage risks relating to moisture, ventilation, overheating and construction.
4. Coordinate designers, installers, assessors and evaluators.
5. Maintain evidence for audits, funding claims and future enforcement.
6. Support commissioning, handover and monitoring.
7. Identify and manage corrective action where work does not perform as intended.

This becomes even more important when programmes are delivered through councils and mayors. Local funding may accelerate delivery, but it will not remove the need for robust technical records or PAS 2035 Compliance.

The proposed Warm Homes Agency is expected to provide national advice and coordinate delivery while working with local partners. That does not mean it will replace the responsibilities of landlords, housing providers, installers or project coordinators. Good Warm Homes Agency compliance will still depend on competent people, reliable evidence and clear accountability at property level.

Air Pressure Testing and technical monitoring will carry greater weight

As local delivery expands, enforcement and quality assurance are likely to become more visible. Properties will not only need to show that measures were installed; landlords and delivery organisations may increasingly need to demonstrate that the work was suitable, properly commissioned and capable of delivering the intended outcome.

This is where Air Pressure Testing and technical monitoring become valuable.

Air pressure testing can help identify uncontrolled air leakage through gaps around windows, doors, service penetrations, loft hatches and building junctions. It can be used to establish a baseline, inform an airtightness strategy and verify the result after works.

It must also be considered alongside ventilation. Improving airtightness without checking ventilation can increase condensation, mould and indoor air-quality risks. The objective is not simply to make a building tighter. It is to achieve a safer, more comfortable and better-performing home.

Our air pressure testing service can support project teams by providing objective evidence that complements the wider retrofit record.

Independent technical monitoring is equally important. It can identify installation defects, incomplete measures, poor workmanship or departures from design intent before they become expensive disputes.

When retrofit remediation services are needed

Not every retrofit project is completed correctly the first time. Problems may only become visible through inspection, occupant feedback, monitoring or post-installation testing.

Typical warning signs include:

• Persistent damp or mould after insulation work.
• Inadequate ventilation or excessive humidity.
• Unexpectedly poor airtightness results.
• Missing or incomplete insulation.
• Thermal bridging or cold internal surfaces.
• Heating systems that do not deliver the expected comfort.
• Incomplete handover records or missing certificates.

Our retrofit remediation services can help investigate what has gone wrong, establish the cause and coordinate an appropriate corrective pathway.

Remediation is not simply about repairing a visible defect. The project documentation, risk assessment and whole-house plan may also need to be reviewed and updated. Where a project fails monitoring and evaluation, the PAS 2035 framework provides for further investigation and follow-on monitoring.

A disciplined remediation process protects residents, landlords and installers. It can also prevent a failed project from undermining wider funding programmes or creating reputational damage.

A practical four-year action plan

Whether you are a landlord, social housing provider, council or installer, we recommend the following approach.

1. Scope now rather than waiting

Do not delay every decision until the final MEES guidance or EPC model is published. Commission proportionate surveys now, especially for properties with poor ratings, damp concerns, solid walls, unusual construction or planned major works.

The final rules may alter the compliance calculation, but they will not remove the need to understand the building.

2. Build a costed, prioritised plan

Use a Retrofit Assessor and Retrofit Coordinator to develop a costed improvement pathway. Separate immediate actions from longer-term measures and record dependencies between them.

This allows you to compare grant funding, green borrowing, planned maintenance budgets and private investment with greater confidence.

3. Track the policy and finance announcements

Monitor:

• The Government’s response to the MEES consultation.
• The published implementation roadmap.
• Final exemption and cost-cap guidance.
• The Warm Homes Agency funding settlement and operating model.
• Local authority and mayoral scheme criteria.
• New lender green finance products.
• Installer training and apprenticeship opportunities.

The NRLA roundtable findings provide a useful summary of the implementation concerns currently facing the private rented sector.

4. Spread delivery across the next four years

The most significant commercial risk is a late rush before 2030. If thousands of landlords and housing providers commission works at the same time, installer availability will tighten, prices may rise and local enforcement teams could be overwhelmed.

A phased programme gives you more control over procurement, resident engagement, technical monitoring and quality assurance. It also allows lessons from early properties to improve later phases.

What does this mean for installers?

Installers entering the market or expanding into funded retrofit will need more than technical installation skills. You will need to understand your role within the PAS 2035 process, work from suitable design information, maintain records and cooperate with the Retrofit Coordinator.

Our practical background as retrofit installers means we understand the pressures on site as well as the compliance requirements behind the paperwork. We support installers, ECO businesses, national companies, councils and social housing providers across London, Tyneside, Yorkshire and Norfolk.

Key takeaways

• The Warm Homes Plan 2026 is moving towards local, area-based delivery.
• Devolution will create opportunities, but also different local processes and evidence requirements.
• The EPC C by 2030 for landlords deadline should be treated as a delivery programme, not a last-minute certificate exercise.
• A Retrofit Assessor survey and Whole House Retrofit plan can be commissioned before the final rules settle.
• Retrofit Coordination Services help maintain PAS 2035 Compliance across complex, locally funded projects.
• Air Pressure Testing and technical monitoring provide stronger evidence as enforcement develops.
• Retrofit remediation services can help rescue failed or underperforming projects.
• Spreading works across four years is safer and more cost-effective than waiting for 2030.

Frequently asked questions

Does the EPC C requirement already apply to every landlord?

The Government has confirmed the direction of travel towards EPC C by October 2030 for privately rented homes in England, subject to valid exemptions and final implementation details. Landlords should review their portfolios now rather than assume that waiting will reduce the obligation.

Should I wait for the reformed EPC model before commissioning a survey?

No. A professional retrofit assessment examines the physical building, its condition, ventilation, heating and improvement options. That evidence remains valuable even if the future EPC methodology changes.

Is a Retrofit Coordinator required for every project?

PAS 2035 projects require a Retrofit Coordinator to oversee the process. The precise route and risk pathway depend on the project, property and measures involved, so early professional advice is recommended.

Can CPH Retrofit support projects outside one local authority area?

Yes. We support clients across London, Tyneside, Yorkshire and Norfolk, providing assessment, coordination, technical monitoring, air pressure testing and wider domestic retrofit support.

Start your retrofit planning with CPH Retrofit

The policy landscape is changing quickly, but the fundamentals of good retrofit remain constant: understand the building, plan the measures properly, coordinate delivery and retain clear evidence.

With more than 15 years of hands-on experience, we provide the practical insight and professional oversight needed to deliver reliable, compliant retrofit outcomes.

Book a retrofit assessment or speak to our team about your portfolio, funding programme or PAS 2035 requirements. We are ready to help you move from uncertainty to a clear, costed and deliverable plan.