Are EPCs required for listed buildings?

As sustainability continues to shape the UK’s property landscape, commercial landlords are increasingly focused on meeting the Minimum Energy Efficiency Standards (MEES).

A key part of this compliance process is the Energy Performance Certificate (EPC). But when it comes to listed buildings, knowledge of the rules appears to be less widespread.

So, are EPCs required for listed buildings? And how should owners navigate the fine balance between compliance and conservation? Chris Bailey, Associate in our Building Consultancy team, and specialist in historic buildings, explains.

EPCs and MEES Requirements

Introduced under the Energy Performance of Buildings (England and Wales) Regulations 2012, EPCs measure a property’s energy efficiency on a scale from A (most efficient) to G (least efficient).

Since April 2018, under the MEES Regulations, landlords in England and Wales have been prohibited from granting new leases on commercial properties with an EPC rating below E.

Since April 2023, this requirement has extended to all leases—meaning landlords must not continue letting properties with F or G ratings unless a valid exemption applies.

The MEES regime is set to tighten further over the coming years, with the government previously consulting on plans to require a minimum EPC rating of C by 2027, and B by 2030 for non-domestic lettings.

How and when to claim an EPC exemption for an historic building

If improvements needed to achieve an EPC E rating (or higher) would unacceptably alter a listed property’s character, landlords may register an exemption on the PRS Exemptions Register.

To do so, you’ll typically need to provide:

• A valid EPC (to confirm the rating and relevant recommendations)
• A heritage impact assessment  detailing  the improvements and what impact, if any, they will have on the significance of the building.
• Pre-planning advice from a conservation officer or planning authority.

To complicate matters, there are also other exemptions under MEES that may apply to listed buildings, including:

• 7-Year payback exemption: If the recommended improvements do not pay for themselves through energy savings over seven years.
• Third-party consent exemption: If the necessary consent (e.g. from a local planning authority, freeholder, or tenant) is refused.
• Devaluation exemption: Where improvements would reduce the property’s value by more than 5%.

All these exemptions must be registered and are time-limited—typically lasting for five years—after which they must be reviewed or renewed.

Where should you start?

Given the complexity of listed buildings, a feasibility report is often the best starting point when it comes to exploring energy performance improvements.

Real life data gathering and modelling of the building’s performance is a fundamental starting point to determining  what energy-saving measures are technically possible and their long term impact on the building, as well as assessing the financially viability.

Feasibility studies not only help inform whether an exemption is valid, they also provide the necessary evidence for registration. Typically, a report might outline:

• The physical constraints of retrofitting historic buildings
• The cost implications of suggested improvements
• The potential heritage impact of those changes
• Alternative approaches to improving efficiency that involve minimal intervention

In some cases, small-scale, sensitive upgrades can deliver meaningful energy savings without breaching conservation requirements, avoiding the need for an exemption altogether.

Balancing heritage conservation and legal compliance

The interplay between heritage conservation and energy efficiency regulation is a delicate one.

While EPCs and MEES do apply to listed buildings in some circumstances, there are valid exemptions where compliance would compromise a property’s character and significance.

However, exemptions are not automatic and navigating the rules requires careful planning, solid evidence and professional advice.

Investing in EPC feasibility assessments can help to protect your asset, maintain compliance with MEES Regulations, and support sustainable improvements wherever they are viable.