EPC exemptions: which properties are exempt?

Properties exempt from needing an EPC

The following categories of property are exempt from the requirement to have an Energy Performance Certificate. If your property falls into one of these categories, you do not need to commission an EPC when selling, renting, or constructing the building.

Listed buildings

This is the most commonly misunderstood exemption. A listed building is not automatically exempt from needing an EPC. The exemption only applies where compliance with the minimum energy performance requirements would unacceptably alter the character or appearance of the building.

In practice, many listed buildings in London can and do have EPCs. A Grade II listed Victorian terrace in Islington or a Georgian townhouse in Chelsea will typically still need one. The exemption is most likely to apply where the building has special architectural features that would genuinely be compromised by energy efficiency measures — for example, single-glazed windows that are themselves part of the listing, or walls where internal insulation would cover original plasterwork.

If you are unsure whether your listed property qualifies for the exemption, contact your local conservation officer or speak to an accredited EPC assessor. We assess listed properties regularly across London and can advise on whether the exemption applies to your specific building.

Places of worship

Buildings used as places of worship are exempt from needing an EPC. This applies to the principal place of worship itself — churches, mosques, synagogues, temples, and similar buildings. However, ancillary buildings such as church halls or community rooms that are separate structures and rented out independently may still require an EPC.

Temporary buildings

Buildings that are intended to be used for less than 2 years do not need an EPC. This applies to genuinely temporary structures — for example, a portable building brought onto a construction site for the duration of a project. If a building initially intended as temporary ends up being used for longer than 2 years, the exemption ceases to apply.

Stand-alone buildings under 50 square metres

A stand-alone building with a total useful floor area of less than 50 square metres is exempt. The key word is stand-alone. A small extension or annex attached to a main building does not count, because it forms part of the larger dwelling. A detached garden office or small outbuilding that is a separate structure and under 50 square metres would qualify.

Industrial sites, workshops, and non-residential agricultural buildings

Buildings where only a small amount of energy is used to condition the indoor climate are exempt. This covers industrial sites, workshops, and non-residential agricultural buildings such as barns, stables, and farm storage. The logic is that these buildings use very little energy for heating or cooling because of their function and construction. If a barn or workshop is converted into a dwelling, the exemption no longer applies and an EPC will be needed.

Buildings due to be demolished

If a building has been officially confirmed for demolition, it does not need an EPC. The relevant planning permissions or demolition orders should be in place. You cannot simply claim you intend to demolish a building to avoid getting an EPC — there must be documented evidence of the demolition decision.

Holiday lets rented for less than 4 months per year

This exemption is more nuanced than it first appears. A property used as a holiday let does not need an EPC if it is rented out for a total of fewer than 4 months per year. The important detail is that this refers to total availability for letting, not just actual bookings.

If you list a holiday let on Airbnb or a similar platform as available for 4 months or more per year, you need an EPC — even if you only receive bookings for 2 months. The determining factor is how long the property is offered for rent, not how long it is actually occupied. Many London property owners who let out a flat short-term during peak tourist season should check their total listing period carefully.

If you are a landlord letting a property on a standard assured shorthold tenancy (AST), this exemption does not apply. You need an EPC regardless of the tenancy length. For more on landlord requirements, read our EPCs for landlords guide.

MEES exemptions for landlords in detail

If your rental property in London has an EPC rating of F or G, you must either improve it to at least an E rating or register a valid exemption. The following MEES exemptions are available under the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015.

All improvements made exemption

If you have made all the energy efficiency improvements that can reasonably be made to the property — as recommended on the EPC itself — and it still does not reach an E rating, you can register this exemption. You need to demonstrate that every applicable recommendation from the EPC has been carried out, or that the remaining recommendations are not applicable to the property.

Cost cap exemption (£3,500)

This is the most commonly used MEES exemption. If you have spent up to the maximum of £3,500 including VAT on energy efficiency improvements and the property still falls below an E rating, you can register a cost cap exemption. You must have made all improvements that can be achieved within the £3,500 cap. If the cheapest available improvement would take total spending above £3,500, you are not required to carry it out.

You will need evidence of the work done and costs incurred. Keep invoices, receipts, and any quotes from installers. These will be needed when registering the exemption.

Devaluation exemption

If an independent surveyor determines that the energy efficiency improvements needed would reduce the market value of the property by more than 5%, you can register a devaluation exemption. This might apply where external wall insulation would significantly alter the appearance of a property, or where required works would reduce usable floor area in a way that affects value.

You need a written report from a qualified, independent surveyor (not your own surveyor or one with a financial interest) to support this claim.

Third-party consent exemption

If you need consent from a third party to carry out energy efficiency improvements and that consent has been refused, you can register this exemption. Common scenarios include needing consent from a superior landlord (in the case of a lease), a tenant who refuses to allow works, or a local planning authority that denies permission for external changes to a property in a conservation area.

You must be able to show that you have requested consent in writing and that it has been refused or given with unreasonable conditions attached.

New landlord exemption

If you have recently purchased a property that does not meet the minimum E rating, you have 6 months from the date of purchase to either bring it up to standard or register a valid exemption. This applies to new landlords who have acquired a non-compliant property and need time to assess and plan improvements.

After the 6-month window, you must have either improved the property or registered one of the other exemptions listed above. The new landlord exemption cannot be renewed.

What happens if you get it wrong?

The penalties for non-compliance depend on the type of breach.

Failing to provide an EPC when required: if you sell or let a property that needs an EPC and do not have one, you can be fined. For domestic properties, the penalty is £200. For commercial properties, the penalty is based on the rateable value with a minimum of £500 and a maximum of £5,000.

Letting a property below the minimum E rating without a registered MEES exemption: local authorities can impose fines of up to £5,000 per property per breach. They can also publish the details of the breach, including the landlord's name and the property address.

For landlords with multiple properties across London — particularly in areas like Westminster, Islington, and Kensington where property values are high and older building stock is common — the financial risk of non-compliance adds up quickly.

Not sure if your property is exempt? Get advice

If you think your property might be exempt from needing an EPC, it is worth checking before you either pay for an unnecessary assessment or assume you do not need one when you do. The exemptions are specific, and getting them wrong can lead to fines.

As accredited EPC assessors covering London and surrounding areas, we can advise on whether your property qualifies for an exemption. If it does need an EPC, we will carry out the assessment professionally and have your certificate lodged within 24 hours.

Our pricing is straightforward: studios from £69, 1–3 bedroom properties from £79, 4–5 bedrooms from £115, and 6 or more bedrooms from £140. Same-day appointments are available with a £20 call-out fee. We are accredited through Quidos and Elmhurst.

For more on what an EPC involves, how it affects selling your home, or the MEES rules for landlords, browse our guides below.

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