Do Listed Buildings Need an EPC

Listed buildings in the UK are generally exempt from needing an Energy Performance Certificate (EPC), but this exemption comes with conditions. While most properties being sold, let or newly constructed must have a valid EPC under the Energy Performance of Buildings (England and Wales) Regulations 2012, listed buildings are treated differently due to their historic fabric and architectural importance.

The official guidance states that a listed building does not require an EPC if compliance with the minimum energy performance requirements would unacceptably alter its character or appearance. In practical terms, this means if the energy-saving improvements normally recommended in an EPC, such as double glazing, cavity wall insulation or replacing windows, would damage or compromise the building’s heritage value, then the property is exempt from requiring one.

Understanding the EPC Exemption for Listed Buildings

The exemption is based on the idea that imposing modern energy efficiency standards on historic buildings could cause more harm than good. Features like solid stone walls, original timber windows and lime plaster are vital to the building's character, and retrofitting with modern materials could lead to moisture problems, structural issues or irreversible damage.

To claim exemption, however, it is not enough to assume that a building is listed and therefore excluded. The exemption must be justifiable. For example, if energy efficiency improvements could be made in a way that does not affect the building’s character, such as upgrading heating systems or adding loft insulation discreetly, then an EPC may still be required.

When an EPC May Still Be Needed

There are circumstances where a listed building may still need an EPC, particularly when it is being rented or sold and the improvements required do not affect protected features. If the building has already undergone sympathetic upgrades that make it more energy efficient, or if there are parts of the building not considered part of the listing, then the obligation to provide an EPC might apply.

Commercial listed buildings being let or refurbished may also fall under the Minimum Energy Efficiency Standards (MEES) regulations. In such cases, landlords must demonstrate compliance or claim a valid exemption, which must be recorded on the government's PRS Exemptions Register. This process often involves obtaining advice from conservation officers, qualified assessors or heritage consultants.

Why the EPC Exemption Matters

The EPC exemption protects listed buildings from unsuitable alterations that would compromise their architectural or historical value. It recognises the importance of balancing sustainability with heritage conservation. However, the exemption does not mean that energy efficiency should be ignored. Many listed buildings can be made more efficient through careful and appropriate means such as draught-proofing, secondary glazing, or upgrading heating and lighting systems.

Owners of listed buildings are encouraged to seek advice from their local conservation officer before planning any energy-related works. While preserving heritage is a priority, improving comfort and reducing energy costs can still be achieved with the right approach.

Conclusion

Listed buildings are generally exempt from needing an EPC if the required energy efficiency improvements would unacceptably alter their character or appearance. However, the exemption must be justified, and in some cases an EPC may still be required. It is important for owners, landlords and agents to understand the specific circumstances of the property and seek expert advice where needed. Preservation and performance can go hand in hand when approached with care and knowledge.