Can landlords in Wales remain EPC compliant with a gas boiler?

Thoughts from Nik Lewis, Director of Operations at CPS Homes. Nik keeps a close eye on the changes affecting landlords across Cardiff and Wales - for more regular updates, advice and opinion, follow @thecardifflettingagent on Instagram (or TikTok / Youtube).

A landlord in Wales can currently ask a tenant to pay six or even twelve months’ rent upfront. In England, new rules introduced in May 2026 restrict how much rent landlords can require before a tenancy starts.

I understand the thinking behind the changes. If you're trying to rent a property for £1,000 a month and you're asked to find £6,000 before you've even moved in, that's a huge barrier.

But I think there's another side to this that deserves some consideration.

Not everyone fits the usual referencing criteria

We sometimes meet perfectly good applicants who can afford the rent but don't tick all the usual boxes when it comes to referencing. Think international students or workers with no UK credit history or guarantor. Someone who's self-employed with an income that's harder to assess through standard checks. Or somebody whose financial position has improved but whose credit history hasn't caught up yet.

In some cases, offering several months' rent upfront has given these applicants another way to secure a property. It can provide a landlord with additional reassurance where the usual referencing process doesn't tell the whole story.

Of course, paying rent upfront doesn't remove every risk, and it won't make every applicant suitable. Landlords still need to be comfortable that the tenancy is affordable and that they're making a sensible decision.

But I do think it's important to recognise that someone who doesn't pass a standard reference isn't necessarily someone who can't afford the rent.

Could the rules have unintended consequences?

If a landlord can no longer accept several months' rent upfront, it doesn't automatically mean they'll be more willing to take a chance on an applicant who doesn't meet their usual criteria. They may simply choose somebody else whose circumstances are more straightforward. That could leave some applicants with fewer options, even when they have the money to rent the property.

There's a balance to be struck. Large upfront payments can make renting inaccessible for people who simply don't have that money available. But for others, having the option to pay in advance may be what helps them secure a home.

Removing that option doesn't necessarily remove the landlord's concerns. It may just mean there's one less way to address them.

What does this mean for landlords in Wales?

For now, Wales hasn't introduced an equivalent cap on rent in advance, so the position remains different from England. That doesn't mean it will always stay that way. We've seen changes to rental legislation in England influence discussions about housing in Wales, so it's an area I'm keeping an eye on.

If similar restrictions were introduced here, I'd want to see proper consideration given to how landlords could assess applicants who don't fit the usual referencing model.

Ultimately, good letting isn't just about whether somebody passes or fails a computerised reference check. It's about understanding the applicant's circumstances, assessing the landlord's risk and working out whether there's a sensible way forward for both. Sometimes the checks will highlight genuine concerns. Other times, they won't tell the whole story.

I think it's important we leave room for that distinction, rather than assuming that one set of rules will work equally well for every applicant.

Posts by date