Minimum Energy Efficiency Standards

Stonewater has submitted its response to the Government’s consultation on Minimum Energy Efficiency Standards (MEES) for socially rented homes in England.

The consultation sets out proposals to improve the energy performance of social housing stock, including the introduction of a dual metric standard and a proposed compliance deadline of April 2030.

Our response supports the ambition to decarbonise homes and reduce energy consumption.

But our response also highlights the need for clarity, flexibility and realistic timelines to ensure the sector can deliver improvements without compromising other priorities.

What did we ask for?

Supporting a dual metric approach

• We broadly supported the Government’s preferred option of a dual metric approach, combining fabric performance with a secondary metric such as smart readiness. However, we raised concerns about the lack of definition around the fabric standard and the practical challenges of assessing compliance across diverse housing stock.
• We proposed that exemptions should apply where fabric improvements exceed a reasonable cost threshold and called for guidance to be issued well in advance of the 2030 deadline.

Concerns around exemptions and timelines

• We did not support the proposed time-limited spend exemption, arguing that a fixed 10-year period would create unnecessary administrative burdens and could lead to unintended consequences, such as condensation issues from partial fabric upgrades.
• Instead, we proposed that exemptions should be based on technical feasibility and cost-effectiveness, without arbitrary time limits. We also suggested that exemptions could be capped at a percentage of a provider’s stock to ensure overall compliance.
• We expressed concern that the 2030 compliance date may be unrealistic, particularly given proposed changes to the EPC regime due to take effect by 2028. We called for a later implementation date and greater clarity on what minimum outcomes are expected for each property.

Leasehold and mixed-tenure challenges

• Stonewater highlighted the difficulties of delivering energy efficiency improvements in leasehold and mixed-tenure buildings, including the need for full consultation, access arrangements and cost recovery mechanisms.
• We recommended that Government make it easier for providers to access grant funding for leasehold properties to support retrofit works.

EPC transition and smart meter rollout

• We supported proposals to recognise existing EPC ratings of C as compliant until expiry and agreed that homes improved to EPC C by April 2028 should be considered compliant under the new regime. However, we cautioned that bringing forward investment to meet this earlier deadline may be challenging for providers with fixed business plans.
• On smart meters, we argued that the responsibility for rollout should lie with energy providers, not landlords, and suggested penalties for energy providers who fail to meet installation targets.

Planning for net zero

• Stonewater confirmed that we have substantially factored the costs of reaching net zero by 2050 into our long-term business planning. Our approach combines self-funding through existing budgets and targeted private finance, with a focus on installing low-carbon heating systems in off-grid homes and those with lower EPC ratings.

Adam Masters, Assistant Director Environment and Sustainability at Stonewater, said: “We’re committed to improving the energy efficiency of our homes, but we have urged the government to consider concerns that the current proposals raise about deliverability.

 “Without clear definitions, realistic cost thresholds and a long term solution to exemptions, there’s a risk that providers will be forced into making incomplete or inefficient upgrades.

“We want to see a framework that enables meaningful investment in homes, not one that encourages short-term fixes or forces providers to consider selling off stock that’s too costly to retrofit.

“The sector needs clarity, flexibility and time to do this properly.”