Back in the early 2000s (cannot remember exact dates) there was a loophole in the Building Regs that allowed the efficiency of heat pumps to meet the CO2 emission standards whilst allowing cr*p levels of insulation and airtightness perhaps as bad as the backstop values. Heard of developers using this method and dread to think what bills the house owners were left with. The additional costs, compared to gas heating, was very obvious in the EPCs.