EPC Exemptions: Complete Guide to Buildings & Landlord Exemptions
Not all properties require an Energy Performance Certificate, and landlords may be able to rent properties rated F or G with a valid exemption. This guide explains which buildings are exempt from EPC requirements and how landlords can register MEES exemptions across England, Wales, Scotland, and Northern Ireland.
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Understanding EPC Exemptions
There are two distinct types of EPC exemptions in the UK:
Buildings Exempt from Needing an EPC
Certain property types don't require an EPC at all when being sold or rented. These include places of worship, temporary buildings, and some listed buildings.
MEES Exemptions for Landlords
Landlords with F or G rated properties may register an exemption to continue letting legally if they cannot improve to the minimum E rating.
Buildings Exempt from Needing an EPC
The following types of buildings do not require an Energy Performance Certificate when being sold, rented, or constructed in England and Wales:
Places of Worship
Buildings used primarily for religious activities and worship, such as churches, mosques, temples, and synagogues.
Converted religious buildings (e.g., church to home) DO require an EPC.
Temporary Buildings
Structures with a planned use of 2 years or less, such as temporary site offices, marketing suites, or pop-up retail spaces.
If use exceeds 2 years, an EPC becomes required.
Small Standalone Buildings
Non-residential buildings with a useful floor area of less than 50 square metres, such as small outbuildings or sheds.
Dwellings (homes) of any size still require an EPC.
Buildings Due for Demolition
Properties sold or rented where the buyer/tenant intends to demolish the building, with relevant planning permission and documentation in place.
Low-Energy Agricultural Buildings
Non-residential agricultural buildings, workshops, and industrial sites with low energy demand, not used for residential purposes.
Listed Buildings (Conditional)
Listed buildings or those in conservation areas where compliance with EPC requirements would unacceptably alter the character or appearance of the property.
Not an automatic exemption - assessment required. See section below.
Seasonal Residential Properties
Residential buildings intended for use less than 4 months of the year, with specific conditions around energy responsibility.
Rooms in Larger Buildings
Rooms for residential purposes in hostels, hotels, boarding houses, or halls of residence are not classified as dwellings.
Self-contained units within these buildings may still need an EPC.
Listed Buildings & Conservation Areas
Listed buildings are NOT automatically exempt
It's a common misconception that Grade I, II*, or II listed buildings are automatically exempt from EPC requirements. This is not the case.
Listed buildings and properties in conservation areas may be exempt from having an EPC only if "compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance."
Likely Exempt
- • Replacing period sash windows with double glazing
- • External wall insulation on historic façade
- • Solar panels on prominent roof
Not Exempt
- • Upgrading internal lighting to LED
- • Loft insulation
- • Boiler replacement
Contact your local authority's conservation officer for advice on whether improvements would unacceptably alter your listed building's character.
MEES Exemptions for Landlords (England & Wales)
If your rental property is rated F or G, you may be able to register an exemption on the PRS Exemptions Register to continue letting legally. There are seven types of exemption available:
High Cost Exemption
Applies when the cost of the cheapest recommended improvement exceeds £3,500 (including VAT). Landlord must obtain 3 quotes from different installers.
Evidence required:
Three quotations from different installers showing costs exceed £3,500
All Improvements Made Exemption
All relevant energy efficiency improvements have been made (or none can be made), but the property still cannot achieve an E rating.
Evidence required:
Valid EPC plus any reports showing no further improvements possible
Wall Insulation Exemption
Cavity, external, or internal wall insulation is not appropriate due to potential negative impact on the fabric or structure of the property.
Evidence required:
Written report from RICS Building Surveyor or architect on Conservation Register
Third-Party Consent Exemption
Required consent from a third party (e.g., tenant, planning authority, freeholder, mortgage lender) has been refused or granted with unreasonable conditions.
Evidence required:
Correspondence showing consent request and refusal
Devaluation Exemption
An independent RICS-registered surveyor has determined that improvements would reduce the property value by more than 5%.
Evidence required:
RICS surveyor report stating >5% devaluation impact
New Landlord Exemption
Temporary exemption for those who have recently become landlords of an already-let property through specific circumstances (e.g., inheritance, relationship breakdown).
Evidence required:
Date of becoming landlord and narrative explanation of circumstances
7-Year Payback Exemption (Commercial Only)
For non-domestic properties where improvements would not pay for themselves through energy savings within 7 years.
Evidence required:
Three quotes and calculations showing payback exceeds 7 years
How to Register an Exemption
All MEES exemptions must be registered on the government's PRS Exemptions Register before letting or continuing to let a sub-standard property.
- Gather evidence: Collect all required documentation for your exemption type (quotes, surveyor reports, correspondence, etc.)
- Visit the register: Go to the PRS Exemptions Register
- Complete the form: Enter your property address, select the exemption type, and upload supporting evidence
- Receive confirmation: The exemption is registered immediately upon successful submission
Important Notes:
- • Registration is free
- • Most exemptions last 5 years (except New Landlord: 6 months)
- • Exemptions are linked to the landlord, not the property
- • If you sell, the new owner must register their own exemption
- • You must re-register or improve the property when the exemption expires
Regional Differences Across the UK
EPC requirements and exemptions vary significantly across the UK nations:
England & Wales
- • MEES regulations apply: minimum E rating for rentals
- • Exemptions available via PRS Exemptions Register
- • Current cost cap: £3,500 (domestic)
- • Proposed 2030: minimum C rating with £10,000 cost cap
Scotland
- • No current minimum EPC requirement for private rentals
- • EPCs still required when selling or renting
- • Places of worship are not exempt from EPC requirements
- • Listed buildings follow the same rules as England/Wales
- • Confirmed October 2030: minimum C for all tenancies, with exemptions register
- • New EPC system coming October 2026 with 5-year validity
Northern Ireland
- • No MEES regulations currently
- • EPCs required when selling or renting, but no minimum rating
- • Same building exemptions as England/Wales apply
- • Penalties: up to £500 for not providing EPC copy to tenant
- • MEES legislation expected to align with rest of UK
Upcoming Changes: 2030 MEES Regulations
In January 2026, the UK government confirmed significant changes to MEES regulations for private rentals in England and Wales:
Key Changes from October 2030:
- Minimum rating rises to EPC C for all tenancies
- Cost cap increases to £10,000 per property
- Spending from 1 October 2025 counts towards cost cap
- Properties under £100,000 value: cost cap of 10% of property value
- Expanded PRS Exemptions Register to capture all in-scope properties
The existing exemption types (consent, devaluation, wall insulation) will remain available under the new regulations.
Penalties for Non-Compliance
Landlords who breach MEES regulations face significant financial penalties enforced by local authorities:
Domestic Properties
| Breach Type | Duration < 3 months | Duration ≥ 3 months |
|---|---|---|
| Letting sub-standard property | Up to £2,000 | Up to £4,000 |
| Providing false/misleading information | Up to £1,000 | |
| Maximum penalty per property | £5,000 | |
Commercial Properties
| Breach Duration | Penalty |
|---|---|
| Less than 3 months | 10% of rateable value (min £5,000) |
| 3 months or more | 20% of rateable value (min £10,000, max £150,000) |
Note: Penalty notices may be published on the PRS Exemptions Register for up to 12 months, publicly identifying non-compliant landlords.
Holiday Lets & Seasonal Properties
Holiday lets have specific rules around EPC requirements:
The 4-Month Rule
In England and Wales, holiday accommodation rented out for less than 4 months per year does not require an EPC, provided:
- • It meets HMRC's definition of a furnished holiday let
- • The landlord (not the guest) is responsible for energy bills
- • The property is let under a licence to occupy
Important: If your holiday let is rented for 4+ months per year, an EPC is required. Keep records of rental activity to demonstrate exemption eligibility.
Scotland: All holiday homes require an EPC regardless of rental duration.
Frequently Asked Questions
How do I know if my listed building is exempt from EPC requirements?
Listed buildings are not automatically exempt. An exemption only applies if the improvements needed to achieve an EPC would "unacceptably alter" the character or appearance of the building. Contact your local authority's conservation officer for guidance on specific improvements.
How long do MEES exemptions last?
Most MEES exemptions last for 5 years from registration. The only exception is the New Landlord Exemption, which lasts 6 months. After expiry, you must either improve the property or register a new exemption if conditions still apply.
What happens if I sell a property with an exemption?
Exemptions are linked to the landlord, not the property. If you sell a sub-standard property, the new owner cannot use your exemption. They must either improve the property to the minimum standard or register their own exemption.
Does Scotland have MEES exemptions?
Scotland does not currently have MEES regulations, so there's no minimum EPC requirement for private rentals. However, proposed regulations from 2028 will introduce a minimum C rating with exemptions similar to England and Wales.
Can I register multiple exemptions for the same property?
Yes, you can register multiple exemption types for the same property if different grounds apply. For example, you might have both a wall insulation exemption and a consent exemption registered.
What evidence do I need to register an exemption?
Evidence requirements vary by exemption type. Generally, you'll need a valid EPC plus supporting documentation such as quotes (for cost cap), surveyor reports (for devaluation), or correspondence (for consent refusals).
Is there a penalty for false exemption registration?
Yes, providing false or misleading information when registering an exemption can result in a penalty of up to £1,000. Penalties may also be published on the PRS Exemptions Register.
Do holiday lets need an EPC?
In England and Wales, holiday lets rented for less than 4 months per year don't require an EPC if the landlord pays energy bills and it's let under a licence to occupy. Properties rented for 4+ months per year do need an EPC. In Scotland, all holiday lets require an EPC.
What is the cost cap for exemptions?
Currently, the cost cap is £3,500 (including VAT) for domestic properties in England and Wales. From 2030, this increases to £10,000, with spending from October 2025 counting towards the cap. Properties valued under £100,000 have a cap of 10% of property value.
Can I rent an F or G rated property in Northern Ireland?
Yes, Northern Ireland does not currently have MEES regulations, so there's no minimum EPC requirement for rental properties. However, you still need a valid EPC when marketing the property.
Check Your Property's EPC
Find out if your property needs an EPC and what rating it has.
Key Facts
- •Most exemptions last 5 years
- •Current cost cap: £3,500
- •2030 cost cap: £10,000
- •Max penalty: £5,000 (domestic)
- •Exemptions linked to landlord, not property
- •Registration is free