Does the Boiler Upgrade Scheme Count Towards the EPC Cap?

The short answer

The government says Boiler Upgrade Scheme (BUS) funding will not count towards the planned £10,000 cost cap, but nothing here is law yet. The rules are for EPC C by 1 October 2030 in England and Wales. A statutory instrument is expected to come into force in 2027 and had not been laid when the government response was published on 21 January 2026.

So read this page as published policy that may still change. It describes policy as published, not a legal test you can rely on. If the regulations word it differently, the regulations win.

Today’s law is different and simpler. The minimum is EPC E, the cost cap is £3,500 including VAT, and exemptions mostly last 5 years. This page is only about the planned rules.

What the sources say

The primary text is the government response, and it says: “BUS funding will not count toward the cost cap of £10,000 for increased PRS MEES.” It also says landlords can still use BUS alongside their own funding to meet the standard on the heating system metric.

A second passage covers other money. In summary, third-party funding the landlord receives can be counted towards the cap, including funding from government schemes, except funding from BUS.

Both points come from the government response itself, which this page quotes directly. The regulations have not been laid, so the final rule may differ.

What the response does not do is give a worked calculation or say what records a landlord must keep. Both are left to the regulations and later guidance.

Why it matters: a worked example

Worked example (modelled, not a real project). Take a rented house that needs a heat pump to reach EPC C. Inputs:

• Installed cost before grant: £12,000, the Energy Saving Trust figure for a typical air source heat pump, updated 23 September 2026.
• Boiler Upgrade Scheme grant: £7,500, the standard air to water or ground source amount for a mains gas home.
• Landlord pays the remainder: £4,500.
• Assumption: no other works and no other funding.

Whether the £7,500 counts towards the £10,000 cap changes how far the cap is used up. The table shows both readings. Only the first matches the government response.

Reading	Counts towards the cap	Cap remaining after this job
BUS excluded (stated policy)	£4,500 of landlord money	£5,500
BUS included (not the stated policy)	£12,000	Cap passed by £2,000

The second row is shown only to explain the stakes. The stated policy is the first row: the landlord’s own £4,500 is what counts, and the £7,500 grant sits outside the cap. Do not read more into the example than that, because how the final regulations treat a partly funded job is unconfirmed.

What would change the answer

Four things could move the position before 1 October 2030:

• The wording of the statutory instrument. Policy responses often differ from final drafting. The sentence on BUS could be narrowed, widened or defined more tightly.
• Changes to BUS itself. The £7,500 amount, the £9,000 oil or LPG uplift (21 July 2026 to 31 March 2027) and scheme eligibility are set by the scheme, not by the EPC rules, and can move independently.
• How other funding is classed. The response says other third-party funding can count towards the cap. The definition of what counts as third-party funding is for the regulations.
• The metric. The planned standard is a dual metric: fabric performance first, then a heating-system or smart-readiness standard of the landlord’s choice. A heat pump affects the heating-system route, so the order and detail matter.

Spend also counts from 1 October 2025 under the response, and a 10-year exemption follows once the cap has been spent. Both are policy only until the regulations exist.

What to keep: invoices and the MCS certificate

Keep a complete paper trail for every job, because the evidence rules are not written yet and you may be asked to show how much you spent and who paid.

1. Itemised invoice. Heat pump, controls, cylinder, pipework, radiators and electrical work shown separately if possible.
2. Proof of payment. Bank statement lines matched to each invoice.
3. Grant record. The Boiler Upgrade Scheme confirmation and the amount paid. The installer applies for the grant on the owner’s behalf, and the grant reduces the invoice.
4. MCS certificate. The installer must be MCS certified for BUS, so you should receive the certificate for the installation. Check the installer on the MCS register yourself rather than trusting a claim.
5. Property details. The EPC before and after, with the lodgement date, since the response ties transitional protection to EPCs lodged before 1 October 2029.

Keep anything that splits landlord money from grant money cleanly. If the final rules count only the landlord’s own spend, a clear split is the evidence you will need.

What a landlord should do before the regulations exist

Plan for the stated policy but do not stake a purchase on it.

• Check the EPC now. The EPC deadline checker helps you see where a property stands and which deadline applies.
• Do not rush either. The planned EPC C date is 1 October 2030, so there is time to wait for the final wording before committing.
• Keep funding and spend separate. Have the installer show the grant as a line on the invoice.
• Read the cap page. The cost cap and exemptions guide sets out the planned cap in full.
• Re-check once the regulations are laid. This page will be updated when they appear.

When this is not the right question

For many rentals the first step is not a heat pump. A poorly insulated house can reach EPC C more cheaply with loft insulation, draught proofing or cavity wall fill, and the planned standard puts fabric performance first. A heat pump in a leaky home can also give a high bill: electricity is 26.32p per kWh against 7.97p for gas under the Ofgem cap for 1 October to 31 December 2026.

If a heat pump is on the table, the landlord calculator is a light way to test it, and you can send an enquiry through the quote page if you want relevant independent firms to contact you, with no charge and no obligation.