London landlords are rushing to hit the government’s EPC C deadline. Most have no idea that EPC renovation work in pre-2000 buildings triggers asbestos compliance obligations (and that one of those obligations quietly changed in 2025).
New research carried out by London Asbestos Help has found that the majority of London landlords planning EPC upgrades are unaware of two asbestos compliance obligations that apply the moment a contractor touches a pre-2000 building. One of those obligations changed in 2025.
With all private rental properties required to reach EPC C by October 2030, an estimated 2.5 million homes in England need improvements. In London, that means insulation installs, Artex ceiling skim-overs, loft conversions and pipe-lagging replacements across Victorian, Edwardian and post-war stock, i.e. exactly the materials most likely to contain asbestos.
The regulatory change most landlords have missed
Artex textured coatings, applied widely in UK homes from the 1960s through to the late 1990s, were until recently treated as low-risk, non-licensed work when removed or sanded down. A 2025 update now classifies mechanical scraping or sanding of Artex as Notifiable Non-Licensed Work (NNLW), carrying specific notification and record-keeping requirements. The HSE has simultaneously increased spot inspections of domestic renovation projects.
Artex manufactured before 2000 typically contains one to four per cent chrysotile (white asbestos), which cannot be confirmed by sight. Only UKAS-accredited lab analysis determines whether asbestos is present. Standard homebuyer surveys do not include asbestos assessment, so many landlords have no documentation of what their building contains.
The broader compliance gap
Separately, a refurbishment and demolition survey is legally required before any structural work begins in a pre-2000 building. Carrying out EPC renovation work without one is a breach of the Control of Asbestos Regulations 2012. Any existing management survey must also be reviewed whenever significant building changes are planned — a heat pump installation or new insulation qualifies. With over 2.5 million asbestos-containing items identified across 400,000 UK properties in a 2022 to 2024 survey dataset, and no national register to check, the responsibility sits entirely with the landlord.
What to do before works begin
Before any contractor begins ceiling, loft or pipework improvements in a pre-2000 property, a refurbishment and demolition survey should be commissioned from a BOHS P402-certified surveyor using a UKAS-accredited laboratory. Residential surveys typically cost £250 to £500, a fraction of the government’s £10,000 EPC spending cap. Failure to have one in place, if a contractor or occupant is subsequently exposed to asbestos fibres, carries unlimited fines and the risk of prosecution.
London’s EPC upgrade wave is necessary and largely well-intentioned. But the compliance gap it is creating is not, and the 2025 regulatory changes mean the consequences of getting it wrong are now more serious than they were a year ago.