EPC Certificates for Listed Buildings, Different Rules for Historic Homes

Are Listed Buildings Exempt from EPC Requirements?

The short answer is: largely, but not entirely. The rules depend on what you are doing with the property, selling, letting, or occupying it, and the nature of the listing.

Under the Energy Performance of Buildings Regulations 2012, an EPC is not required for a building that is:

• Officially listed as being of special architectural or historic interest
• A scheduled ancient monument
• A building used as a place of worship or for other religious activities
• A temporary building with a planned use of two years or less
• A stand-alone building with a total useful floor area of less than 50 m²

The exemption for listed buildings is based on the principle that achieving EPC compliance may require alterations that would be incompatible with preserving the building's special character, which is unlawful under the Planning (Listed Buildings and Conservation Areas) Act 1990.

The Critical Qualification

The listed building EPC exemption only applies where compliance would unacceptably alter the character or appearance of the building. This is not a blanket exemption for all energy work.

Historic England's guidance makes clear that:

• Energy improvements that do not affect the building's character remain permissible and encouraged
• Listed building consent must still be obtained for any alterations to the fabric
• Conservation officers should be consulted early to identify acceptable approaches
• The exemption must be specifically justified, it cannot be assumed

In practice, this means a landlord cannot simply rely on listing status to avoid all energy obligations. If works are available that would improve the EPC rating without affecting the building's special interest, those works may still be expected.

Listed Buildings and MEES for Landlords

The MEES minimum EPC E requirement includes a specific listed building exemption. Landlords of listed properties do not need to register a MEES exemption on the PRS Exemptions Register if compliance would unacceptably alter the character of the building, the exemption applies automatically by regulation.

However, DESNZ guidance recommends that landlords of listed properties keep a written record demonstrating that:

Can You Voluntarily Get an EPC for a Listed Building?

Yes. Many owners of listed buildings commission an EPC voluntarily, particularly when selling or re-mortgaging, to provide prospective buyers or lenders with energy performance information. An EPC produced voluntarily has the same format as any other but should note the listed status.

Property Passport UK displays EPC data for listed buildings where a certificate exists in the national EPC register, alongside the property's listing status where available.

Improving Energy Efficiency in Listed Buildings

The absence of an EPC requirement does not mean energy efficiency work is impossible. Historic England actively encourages sensitive energy improvements and has published detailed technical guidance covering:

• Secondary glazing (instead of double glazing, to avoid altering windows)
• Draught-proofing around doors, windows, and fireplaces
• Insulating suspended timber floors from below
• Careful internal wall insulation using breathable materials such as natural hemp or wood fibre
• Upgrading heating controls and pipework insulation
• Roof insulation where the roof space is accessible and the works are reversible

The key principle for listed buildings is breathability, traditional solid walls are designed to absorb and release moisture, and trapping moisture with modern impermeable materials causes serious damage to historic fabric.

Conservation Areas

Conservation area designation alone does not trigger a listed building EPC exemption, only actual listing does. However, properties in conservation areas may face planning restrictions on external alterations, making EWI or double glazing more difficult to obtain consent for.