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Take out shower for MEES Exemption?
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I am not a landlord, just someone viewing flats and houses at the moment, but it is interesting to see how much the EPC rating now shapes what I would look at. As a buyer, a low rating makes me ask what the bills will really be and whether I will be hit with upgrade costs, so it affects price as much as it affects letting. On your actual question, removing a shower to dodge one recommendation feels a bit risky, since the point of an exemption is that you can show you have done what is reasonably possible. I would ask the assessor or your local council what evidence they need before you take anything out. And the earlier points about EPC C by 2030 sound worth planning for now rather than later.
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A few things from the gov.uk landlord guidance that might change the maths, because I don't think the order the EPC lists things in matters the way you fear:
- Under the current rules a "relevant improvement" is any recommended measure (or package) that can be installed within the current cost cap. If the shower heat recovery is the only one under the cap, the expectation is that you do it, and if you're still below E you register the "all relevant improvements made" exemption. The "high cost" exemption is for when even the cheapest recommended measure is over the cap, and that one needs three quotes from qualified installers.
- On the windows: as I read it, if the double glazing on its own would get you to E, you're compliant whatever order the measures appear in. If it wouldn't, you'd still be expected to do the under-cap measure before you could claim the exemption.
- You don't have to rely only on the EPC's list. The guidance says you can use a report from a qualified surveyor to choose measures appropriate for the property (you upload it when you register). Given your bathroom layout, it may be worth asking an assessor whether a proper report would still recommend that unit. That's a much cleaner answer than taking the shower out.
- On removing the shower: the exemption is self-registered, but councils enforce it, and "false or misleading information on the PRS Exemptions Register" is a breach with its own penalty. If the shower went back in after the EPC, I wouldn't fancy explaining that. And as others said, a bath with a hose attachment is a real downgrade for tenants.
- On 2030: the January 2026 government response confirmed a single compliance date of 1 October 2030, a "C-equivalent" standard with two parts (fabric first), a higher cost cap and exemptions lasting 10 years instead of 5. It still needs an Act of Parliament and then regulations (they're aiming for 2027), so it's decided policy but not law yet. With a higher cap, things that are out of scope for you today (like the windows) may well be in scope then, so it's worth working out your 2030 route before you spend on anything just to scrape an E now.
Both documents are on gov.uk: search "Domestic private rented property: minimum energy efficiency standard – landlord guidance" and "Improving the energy performance of privately rented homes: 2025 update".
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