EPC Rating D to C: Freeholder Permission & Exemptions

We're considering purchasing a flat with an EPC rating of D. The EPC says it can be made C, but the first step is to provide cavity wall insulation. To do this, I believe we would need the freeholder's permission.

What is the situation regarding the requirement for a rating of C or above from 2025 if the freeholder won't provide this permission?

The freeholder is the local council, so I doubt they will be ready to upgrade the entire estate. At the same time, we would be happy to fund it.


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Energy Efficiency Improvements

A tenant is allowed to reasonably ask for a relevant energy efficiency improvement. From 1 April 2018, all rented property let on assured shorthold tenancies, regulated tenancies under the Rent Act 1977 and four types of agricultural tenancy, which is to have a new tenancy must have an EPC rating of at least "E".

Energy Performance Certificates (EPC)

Since 1 October 2008, landlords have been required to make an Energy Performance Certificate (EPC) available to prospective tenants when a property is being advertised for sale or let. The purpose of the EPC is to show prospective tenants the energy performance of the dwelling they are considering renting.