Three stories today share an uncomfortable thread: the gap between what compliance is supposed to look like and what actually gets checked. A Guardian investigation catches the King and the Prince of Wales’s own estates letting scores of homes below the legal EPC minimum, a new government fund quietly opens to catch a category of building that fell outside the post-Grenfell remediation net, and Making Tax Digital turns out to have a paperwork trap built specifically for HMO landlords who assumed their letting agent already had it covered.
MEES doesn’t care whose name is on the freehold
A Guardian investigation, as reported by Letting Agent Today, found that more than 100 rental homes across the Duchy of Lancaster, the Duchy of Cornwall and the Sandringham estate are rated EPC F or G — roughly one in five of the 700-odd domestic lets the paper analysed across the three estates. Renting a home below EPC E has been illegal without a registered exemption since 2020, and fewer than one in 12 of the sub-standard properties on the estates has one on file. One tenant told the paper: “They do no repairs. My windows are so rotten I am scared they will fall out.” The Duchy of Lancaster said it placed “great importance” on being a responsible landlord and had invested “more than £3 million” in repairs and upgrades last year; Sandringham said it was “fully compliant with MEES regulations”; the Duchy of Cornwall said it had spent “£11 million on home improvements since 2022.”
My read: none of the three estates disputes the EPC data, only the interpretation of it, which tells you the ratings themselves aren’t what’s in question. What’s notable is where the compliance actually broke down — not at the standard itself, which every landlord in the country has had six years to meet, but at the exemption register, the part of the system that exists precisely to give a landlord cover while remedial work is planned. An estate with an in-house property team and the budget to spend £11 million on improvements still couldn’t get that paperwork right, which should worry anyone running a handful of lets with no compliance department at all. The direction of travel makes this worse, not better: EPC C becomes the minimum from October 2030, and on the Guardian’s own figures most of the properties it sampled across the three estates are already rated D or below, meaning today’s F and G failures are the easy end of the problem.
If you’re a landlord anywhere in the South East and you can’t recall your own property’s current EPC rating from memory, that’s the first thing to check this week, not an assumption that a letting agent or portfolio manager already has it covered. If a rating comes back F or G, register a formal exemption immediately if one genuinely applies, or get a quote for the work — a £5,000 fine for continuing to let without either is not hypothetical, and this story shows that scale and resources don’t make anyone immune to missing it.
The buildings under 11 metres just stopped being nobody’s problem
Applications opened on 17 August for the Cladding Safety Scheme’s extension to residential buildings under 11 metres in England, according to the fund overview published on GOV.UK. The window runs eight weeks, closing 9 October 2026, with applications submitted through the Building Remediation Hub. Eligible buildings need at least two dwellings, can be privately owned or social housing, and must have a Fire Risk Appraisal of External Walls carried out to the PAS 9980:2022 standard identifying a genuine fire safety risk. Homes England, which administers the fund, reviews and audits every FRAEW before confirming a grant, and funding is prioritised by risk: “buildings assessed as presenting a high cladding fire safety risk will be taken forward first.” Works that started before 9 July 2026 don’t qualify — there is no retrospective funding.
My read: this closes a gap that has been obvious since the Building Safety Act drew its funding lines at 11 metres and 18 metres. Everything above those thresholds got a route to money and a regulatory regime to match; a three-storey block of six flats with a genuinely dangerous FRAEW finding got neither, because it was too short to count as “higher-risk” and too ordinary to attract insurer or developer money on its own. That is exactly the kind of building I see across the South East — small converted blocks, 1960s and 70s low-rise, freehold split into a handful of leases with a resident management company that has no budget line for a PAS 9980 fire risk appraisal, let alone the remediation itself. The eight-week window is short for anyone starting from scratch, because a FRAEW takes real time to commission and complete before an application can even go in.
If you sit on a management company or freehold for a block under 11 metres with any history of cladding concerns, commission a PAS 9980 FRAEW now rather than waiting to see whether the window gets extended — eight weeks disappears fast once you account for surveyor availability. And don’t start remedial works to try to get ahead of the queue: the no-retrospective-funding rule means jumping the gun costs you the grant, not just the head start.
Your letting agent’s statement was never built for HMRC
HMO landlords who use a letting agent are running into an unadvertised problem with Making Tax Digital, LandlordZone reports: the agent’s monthly statement, designed to reassure an owner that rent has come in, isn’t built as an HMRC-grade digital tax record. Ben Goodall of proptech firm RentSorter put the mismatch simply: “The money arrives net and the detail stays in the agent’s PDF.” Scale is the issue — one four-bedroom HMO statement he examined contained 45 separate transactions in a single month, and a six-bedroom property generates 72 PDF statements a year once landlords are filing quarterly instead of annually. MTD for Income Tax has been mandatory since April 2026 for anyone with qualifying rental income over £50,000, and because that threshold is based on gross income rather than profit, HMO landlords hit it far more easily than a single-let landlord with the same actual margin.
My read: this is a South East HMO problem specifically, because a handful of licensed houses in a town like Crawley, Brighton or Eastbourne routinely gross past £50,000 even when the actual profit after mortgage, management and licensing costs is modest. The trap isn’t the tax itself, it’s the format — quarterly digital submission assumes the underlying records are already structured for it, and an agent’s PDF statement, however tidy, generally isn’t. Yogesh Dhanak of the ACCA put it plainly: that information “will have to be built into proper bookkeeping systems, which may require the expertise of professional bookkeepers or accountants.” That is a cost most landlords haven’t budgeted for, on top of the licensing and compliance costs already stacking up on HMOs specifically.
If you run an HMO through a letting agent and you’re anywhere near the £50,000 gross threshold, don’t wait for the next quarterly deadline to discover your agent’s statements don’t translate into MTD-ready records. Kim Lidbury of ARLA Propertymark has the right advice: “speak to their agent and accountant early to establish what information they will need.” Ask the agent directly whether their reporting format is MTD-compatible now, not in principle.
What I’d actually do
- Don’t know your own EPC rating off the top of your head? Look it up this week — the register is public, and today’s story shows that assuming compliance is not the same as having it.
- F or G rating with no exemption on file? Register a formal exemption if one genuinely applies, or get a quote for the upgrade — the £5,000 fine is real, and 2030’s EPC C minimum makes the eventual bill bigger the longer it’s left, not smaller.
- Sit on a freehold or management company for a block under 11 metres with any cladding history? Commission a PAS 9980 FRAEW now and get an application into the Building Remediation Hub before 9 October — don’t start works first, or you lose the grant.
- Run an HMO through a letting agent near the £50,000 gross threshold? Ask now whether their statements are MTD-ready, and get an accountant looking at your record-keeping before the next quarterly deadline, not after it’s missed.
If today’s notes have you checking your own EPC rating, scoping a FRAEW for a shared block, or squaring away HMO bookkeeping before the next MTD deadline, the practice offers full EPC assessments across the South East. Get in touch.
Small print. General commentary, not advice for your specific circumstances — regulations, schemes and deadlines change, and your property is not the average property. Sources linked were accurate when read on 18 August 2026.