EPC for HMOs: Do Shared Houses and Rented Rooms Need an EPC?

Whether a house in multiple occupation needs an EPC depends on how it is let, not on what it is called. A whole house let on a single tenancy needs one. A single room let on its own does not. Most of the confusion comes from mixing up those two, and from mixing up EPC rules with HMO licensing and planning rules.

What counts as an HMO?

GOV.UK defines a house in multiple occupation as a property rented out by at least 3 people who are not from one household, for example not one family, but who share facilities like the bathroom and kitchen.

A large HMO, one rented to 5 or more people forming more than one household and sharing a toilet, bathroom or kitchen, needs a mandatory licence in England. Smaller HMOs may need one too, depending on the area, so check with the council.

None of that is EPC law. HMO licensing and EPCs are separate regimes, and being an HMO doesn't by itself create or remove the need for an EPC.

Does an HMO need an EPC?

The government's guide to EPCs for the sale and let of homes sets out three situations:

• The whole building is let or sold. The whole building needs an EPC if it is sold or rented out. A shared house let to a group on one joint tenancy is a whole-building let.
• A self-contained unit is let. Any building unit designed or altered for separate use, for example a flat with its own entrance, kitchen and bathroom, needs its own EPC when it is sold or let.
• A single room is let. An EPC is not required for an individual room when it is rented out, because a room is not a building, or a unit designed or altered for separate use.

So a typical room-by-room HMO, where each tenant has their own tenancy for a bedroom and shares the kitchen and bathroom, does not need an EPC for each room. The same reasoning applies to a lodger renting a room in your own home.

Do I need an EPC for each room in an HMO?

No. Rooms let individually don't need their own certificates. What can need one is the building as a whole, if it is let or sold as a whole, and any self-contained flats inside it.

Many HMOs have a valid whole-house EPC anyway, because the house was sold, or let as a whole at some point, in the last ten years. A certificate lasts ten years. Check yours on the government's Find an energy certificate service.

Does the minimum EPC rating apply to HMOs?

The minimum energy efficiency standard applies to rented properties that are legally required to have an EPC. GOV.UK's rule of thumb is that a property marketed, let or modified in the past ten years will probably be legally required to have one. If a property is covered, it cannot be let below band E unless a valid exemption is registered, and the fine for breaking the rule can reach £5,000 per property.

For a whole-house let, that is straightforward: it needs an EPC, so it must meet band E. For a room-by-room HMO, whether the standard bites depends on whether the property is legally required to have an EPC, which turns on its own history and how it is let. I'm an assessor, not a lawyer: if you are relying on an HMO being outside the rules, get that checked before you rely on it. The full landlord rules, including the planned move to band C, are in my guide to EPC rules for landlords.

Birmingham: the planning rule landlords forget

Birmingham City Council's city-wide Article 4 direction came into force on 8 June 2020. It means a planning application is needed to convert a family house (use class C3) into a small HMO for 3 to 6 people (use class C4), anywhere in the city. That is a planning rule, not an EPC one, but it is the one that catches out people setting up a new shared house.

What larger rented houses in Birmingham are rated

The EPC register doesn't record whether a house is an HMO, but it does record rented houses and their size. Looking at certificates lodged since January 2021 for rented houses in Birmingham with five or more habitable rooms, the kind of house most shared houses are:

• 25,564 certificates.
• 42.3% rated C, 50.7% D, and 5.4% E or below.
• 56% sit below band C, against 44% of all Birmingham rentals.
• 58% have solid brick walls, and 43% were built before 1930.

Solid walls are the reason. A cavity can be filled cheaply; a solid wall needs internal or external insulation, which costs much more. That is worth knowing early if you are planning a shared house around the band C target for 2030.

Improving the rating of a shared house

Larger, older houses usually have the same gaps as any other home, just more of them: thin loft insulation, heating controls that don't let rooms be heated separately, and walls that can't be filled. My guide to how to improve your EPC rating goes through which measures move the score most for Birmingham homes, using the government's own register.

Getting an EPC for an HMO

An HMO is assessed like any house: every room is measured, and the construction, insulation, heating, hot water and lighting are recorded. Larger houses take longer, so ring 07365 061790 with the number of rooms and I'll give you a price before you book. You can also request a booking online. You pay on the day, by bank transfer or cash, with no booking fee.

Common questions

Do I need an EPC to rent a room to a lodger?

No. Renting out a single room is not renting out a building or a separate unit, so an EPC is not required for the room.

Does a student house need an EPC?

If it is let as a whole to a group on one tenancy, yes, and the minimum rating rules apply. If each student rents a room on a separate tenancy, the rooms don't need their own EPCs.

Do self-contained flats in a converted house need separate EPCs?

Yes. Each unit designed or altered for separate use needs its own EPC when it is sold or let.

Does HMO licensing require an EPC?

Licensing is set by the council, separately from EPC law. Check the conditions of your own licence with Birmingham City Council rather than relying on a general rule.