Energy & EPC

EPC Exemptions for Rental Properties, When MEES Rules Don't Apply

The Minimum Energy Efficiency Standards require most privately rented properties in England and Wales to hold an EPC of at least E. But several legal exemptions exist that landlords can register to avoid enforcement.

Published: 16 Mar 2026 · Updated: 16 Mar 2026 · 6 min read

#EPCRating#EnergyEfficiency#MEES#EPCExemptions#Landlords#PropertyPassportUK

What are the Minimum Energy Efficiency Standards?

The Minimum Energy Efficiency Standards (MEES) require that privately rented domestic properties in England and Wales must not be let on a new or renewal tenancy unless they hold an EPC of at least E. Properties rated F or G are, in principle, unlawful to let.

MEES apply to most residential tenancies under the Housing Act 1988, including assured and assured shorthold tenancies. The rules have applied to new tenancies since April 2018 and to all existing tenancies since April 2020.

The government's longer-term policy intent is to raise the minimum to EPC C for new tenancies, though the implementation timeline has been subject to repeated revision. Landlords should monitor DESNZ announcements closely.

The Five MEES Exemptions

Where a landlord cannot, or in specific circumstances need not, achieve EPC E, they can register an exemption on the Private Rented Sector (PRS) Exemptions Register. There are five recognised exemption types:

Exemption type	Duration	When it applies
All improvements made	5 years	All relevant improvements have been made and property is still below E
High cost	5 years	Cheapest improvement would cost more than £3,500 (including VAT)
Wall insulation	5 years	Technical report confirms wall insulation unsuitable
Consent	5 years	Tenant or third party refuses consent for works
Devaluation	5 years	Written evidence that works would reduce property value by 5% or more
New landlord	6 months	Temporary exemption for newly acquired properties

The All Improvements Made Exemption

This is the most commonly used exemption. If a landlord has made all relevant energy efficiency improvements recommended on the EPC (or available through ECO4 or similar schemes) and the property still does not reach EPC E, they may register this exemption. Evidence, such as invoices and contractor confirmation, must be uploaded to the register.

The High Cost Exemption

If the cheapest single improvement that would raise the property to EPC E costs more than £3,500 including VAT (the cap), and no third-party or government funding is available to meet that cost, a landlord can register a high cost exemption. This cap has remained at £3,500 since MEES was introduced; its adequacy for solid wall insulation in particular has been widely questioned.

The Wall Insulation Exemption

Where an independent technical report from a qualified surveyor confirms that any form of wall insulation would cause damage to the property, for example, due to pre-existing damp or structural issues, a wall insulation exemption can be registered.

How to Register an Exemption

All exemptions are registered on the government's PRS Exemptions Register at gov.uk. Landlords must:

1. Complete the online registration form

2. Upload supporting evidence (technical reports, invoices, written quotes)

3. Serve the tenant with a copy of the exemption confirmation

An exemption does not transfer automatically to a new landlord. When a property changes hands, the new landlord has six months to either bring the property up to EPC E or register a fresh exemption in their own name.

Enforcement

Local authorities are responsible for enforcing MEES. They can serve compliance notices and impose civil penalty notices of up to £5,000 per property for each breach. Breaches are also publishable, local authorities may name and publicise non-compliant landlords.

Checking Your Property's EPC

Property Passport UK displays the current EPC rating for every UK address. Landlords can confirm their property's current band and review the recommendations listed on the EPC before deciding whether to make improvements or consider an exemption route.