Most properties require an Energy Performance Certificate when sold, let, or built. But a small number of property types fall outside this requirement. This guide explains exactly which properties qualify for an EPC exemption, how landlord exemptions work under the Minimum Energy Efficiency Standards (MEES), and what you need to do to register one.
Which Properties Are Exempt from Needing an EPC?
The government sets out the following categories of property that do not require an EPC.
Listed Buildings
Listed buildings in England and Wales do not require an EPC where meeting the minimum energy efficiency standards would unacceptably alter their character or appearance. Historic England and local conservation officers often restrict or prohibit measures such as external wall insulation, double glazing, or solid floor insulation in listed properties.
However, this exemption is not automatic. The owner must be able to demonstrate that compliance measures would genuinely harm the building’s heritage significance. A blanket assumption that all listed buildings qualify is incorrect.
Temporary Buildings
Buildings with a planned useful lifespan of less than two years do not require an EPC. This covers temporary structures such as site offices, pop up retail units, and seasonal buildings erected for a fixed short term purpose.
Residential Buildings Used Less than Four Months a Year
Holiday homes and other residential properties that owners use for fewer than four months per year, and where energy consumption falls below a relevant threshold, qualify for an exemption. The owner must be able to evidence the low and seasonal nature of use.
Small Standalone Buildings
Standalone buildings with a total useful floor area of less than 50 square metres do not require an EPC. This covers garden studios, small outbuildings converted to habitable use, and detached garages with a basic amenity fit out.
Industrial Sites, Workshops, and Agricultural Buildings
Non residential buildings that do not use energy to condition the indoor climate, meaning no heating, air conditioning, or mechanical ventilation, do not require an EPC. Agricultural barns, unheated storage warehouses, and similar structures fall into this category.
Places of Worship
Buildings used exclusively as places of worship and for religious activities qualify for an exemption.
Demolition
Where a seller or landlord can demonstrate that they have all the necessary consents and permissions to demolish the building, and that the buyer or tenant is aware of this intention, the property does not require an EPC.
EPC Exemptions for Landlords Under MEES
Separate from the general EPC requirement exemptions above, the Minimum Energy Efficiency Standards (MEES) create a distinct set of exemptions relevant specifically to landlords.
Under MEES, landlords in England and Wales must not let a property with an EPC rating below E. From April 2026, the government has confirmed that the minimum standard for new tenancies will rise, with further increases planned. Landlords who cannot meet the required standard may register an exemption on the PRS Exemptions Register.
The No Improvements Possible Exemption
A landlord can register this exemption where a qualified assessor or surveyor confirms that the property has no relevant energy efficiency improvements that are technically feasible to install. This might apply to a solid wall property in a conservation area where both external and internal insulation are prohibited or impractical.
This exemption lasts 5 years, after which the landlord must reassess whether improvements have become available.
The High Cost Exemption
Where the cheapest improvement measure costs more than £3,500 (including VAT), and the landlord cannot fund the works through third party funding such as ECO4 or the Great British Insulation Scheme, the landlord can register a high cost exemption.
The landlord must obtain at least three quotes from qualified installers to demonstrate the cost, and must show they have explored all available funding routes before relying on this exemption.
The Third Party Consent Exemption
Some improvements require consent that the landlord cannot obtain. Common situations include:
- A freeholder or head lessor refusing consent for works in a leasehold property
- A local planning authority refusing permission for external wall insulation in a conservation area
- A listed building consent refusal
The landlord must evidence that they actively sought consent and the relevant party refused. Simply not applying does not qualify.
The Recently Let Property Exemption
A landlord who purchased a property that was already let to a tenant, and where the property does not meet the minimum EPC standard, can register a six month exemption while they take steps to bring the property into compliance. This gives the landlord time to either carry out improvements or register a longer term exemption if one applies.
The New Landlord Exemption
A person who becomes a landlord through inheritance or other means not involving a commercial purchase may register a six month exemption while getting the property assessed and any relevant works arranged.
How to Register a MEES Exemption
Landlords register exemptions on the government’s PRS Exemptions Register at gov.uk. The process requires:
- Creating an account on the register
- Selecting the type of exemption that applies
- Uploading supporting evidence (assessor reports, quotes, consent refusals, planning decisions)
- Confirming the property details and EPC rating
The register is publicly searchable. Local authorities use it to check compliance when investigating complaints or conducting proactive enforcement. Landlords who let a property without a valid EPC or exemption face civil penalties of up to £30,000 per property.
Exemptions do not transfer when a property changes ownership. A new landlord buying a property with a registered exemption must independently qualify for their own exemption or bring the property up to the required standard.
Do EPC Exemptions Affect Grant Eligibility?
Yes, in some cases. Grant schemes such as ECO4 and the Great British Insulation Scheme use EPC ratings to determine eligibility. Properties with very low EPC ratings (E, F, or G) often qualify for fully funded improvements.
If a landlord registers a MEES exemption instead of carrying out improvements, they may miss out on funded measures that would otherwise be available. Before registering an exemption, landlords should check what funding they can access through a TrustMark registered, PAS 2030 certified installer, as grants can cover the full cost of works and remove the need for an exemption altogether.
Frequently Asked Questions
Does a listed building always qualify for an EPC exemption?
Not automatically. The exemption applies where compliance with energy efficiency requirements would unacceptably alter the character of the building. Many listed buildings can still accommodate improvements such as loft insulation, secondary glazing, or draught proofing without harming their character. Owners should take professional advice rather than assume an exemption applies.
Can I sell a property without an EPC if it qualifies for an exemption?
Yes. If your property genuinely falls within one of the exempt categories, you do not need to commission an EPC before marketing it. However, you should be prepared to evidence the exemption to solicitors and buyers during the transaction.
How long do MEES exemptions last?
Most MEES exemptions last five years. The recently let and new landlord exemptions last six months. At the end of the exemption period, the landlord must reassess whether improvements are now possible or fundable before re registering.
What happens if I let a property without a valid EPC or exemption?
Local authorities can issue civil penalties of up to £30,000 per property. They can also issue compliance notices requiring landlords to carry out improvements or register a valid exemption within a specified timeframe.
Can a tenant report their landlord for not having a valid EPC?
Yes. Tenants can report non compliance to the local authority, which has enforcement powers under MEES. The local authority can investigate and issue penalties where appropriate.
Do I need an EPC for a holiday let?
Holiday lets used for fewer than four months a year may qualify for an exemption from the standard EPC requirement. However, if you let the property through a short term platform and it is available for more than four months a year, you likely need an EPC. The rules for holiday lets in relation to MEES are also subject to ongoing legislative change, check the latest government guidance for your specific situation.
Information correct as of April 2026. EPC regulations and MEES standards are subject to ongoing legislative change. Always check the latest government guidance or take professional advice for your specific circumstances.