Which properties are exempt from EPC and MEES requirements?

In England, Wales, Scotland and Northern Ireland, EPC exemptions are not identical, and MEES is live only in England and Wales. The practical split is: first ask whether the building needs an EPC at all, then ask whether any MEES duty applies to a rented property with an EPC rating below the minimum.

Which properties do not need an EPC at all?

Properties that do not need an EPC at all are those outside the EPC regulations for their nation, including places of worship in England, Wales and Northern Ireland, some temporary or low-energy buildings, and some small stand-alone buildings; the exemption list is not the same across the UK. In England and Wales, the regulations exclude “buildings used as places of worship and for religious activities”, residential buildings used or intended to be used “for less than four months of the year”, and “stand-alone buildings with a total useful floor area of less than 50m².” Scotland is narrower on the 50m² point: it excludes “stand-alone buildings with a total useful floor area of less than 50m2 which are not dwellings.” Scotland also says plainly that “Places of worship and historic buildings are not subject to a general exemption in Scotland, unless they fall into one of the categories listed above.” A property without fixed heating is not automatically EPC exempt; the question is whether the building falls within the legal exemption list.

Are listed buildings exempt from EPC requirements?

A listed building is not automatically exempt from needing an EPC — Bath & North East Somerset Council calls that a common misunderstanding — because the exemption applies only where meeting minimum energy performance requirements would unacceptably alter the building’s character or appearance. The England and Wales regulation covers “buildings officially protected as part of a designated environment or because of their special architectural or historical merit, in so far as compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance.” That means a Grade II listed building may still need an EPC to sell or rent if the assessment and recommended works would not unacceptably affect its protected character. The safest practical answer for a listed rental or sale is to keep written conservation or consent evidence, because Bath & North East Somerset Council says: “Listed buildings are not automatically exempt from obtaining an EPC and this is a common misunderstanding.” Scotland does not give listed or historic buildings a general EPC exemption, and Northern Ireland’s EPC non-application list does not name listed buildings.

Do you need an EPC for a holiday let?

A holiday let needs an EPC where the relevant national rules or guidance require one, but England and Wales guidance treats many furnished holiday lets differently from ordinary tenancies while Scotland says holiday lets generally need a valid EPC. For England and Wales, government guidance says: “An EPC will only be required for a property rented out as a furnished holiday let, as defined by HMRC, where the building is occupied for the purposes of a holiday as a result of a short term letting arrangement of less than 31 days to each tenant, and is rented out for a combined total of 4 months or more in any 12 month period, and if the occupier is responsible for meeting the energy costs for the property.” The January 2026 government consultation response adds that “Currently there are no specific requirements in regulation, though guidance outlines where EPCs are required.” Scotland is clearer: “The Energy Performance of Buildings (Scotland) Regulations 2008 do not contain a general exemption for holiday let accommodation,” and short-term holiday lets are “required to provide a valid EPC.” Northern Ireland guidance says an EPC is needed when a property is rented out to a new tenant.

What are the MEES exemptions?

The MEES exemptions in England and Wales are the registered routes that allow a sub-standard domestic private rented property to be let despite failing the minimum EPC standard, including all relevant improvements made, high cost, consent refused, devaluation, and temporary new-landlord exemptions; Scotland and Northern Ireland have no live MEES duty. The core England and Wales rule is: “A landlord of a sub-standard domestic PR property must not let the property unless regulation 25, or one or more of the exemptions in Chapter 4, applies.” The domestic cost cap is £3,500, and the “all relevant improvements made” route lasts five years from registration. A high-cost exemption needs “copies of three quotations” showing the work would exceed the cap, and a devaluation exemption needs an independent surveyor’s report showing “a reduction of more than 5% in the market value.” Listed buildings are not a separate MEES category: the usual route is consent not granted, and government evaluation found that most live exemptions were no further improvements, cost-cap, or consent not granted. Scotland says “There are currently no MEES for PRS properties in Scotland.” Northern Ireland’s 2022 Act only enables future regulations concerning energy efficiency of private rented homes.

How do you find out whether a property is already EPC exempt?

You cannot look up a property on an EPC-exemption register, because EPC exemption is self-assessed against the regulations; only MEES exemptions are publicly searchable. For England and Wales, the listed-building test is still the statutory character-or-appearance test: protected buildings are outside the EPC duty only “in so far as compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance.” Bath & North East Somerset Council says there is “no requirement to register an EPC exemption in these circumstances,” so owners should keep evidence of listed-building consent or planning decisions. If the issue is uncertain, government guidance says owners may seek advice from the local authority conservation officer. You can search the EPC register to see whether a certificate already exists, because government says: “You can search for a certificate by postcode, street name and town, or certificate number.” MEES is different: the PRS exemptions register can be searched “by postcode, street name and town, the landlord’s name or exemption/penalty type.” Abodient can store the EPC certificate against a property, record its expiry, and show overdue compliance items across a portfolio.

Last reviewed August 2026.

Sources

• Energy Performance of Buildings (England and Wales) Regulations 2012, regulation 5 — “(b)buildings used as places of worship and for religious activities;” Source
• Energy Performance of Buildings (England and Wales) Regulations 2012, regulation 5 — “(i)for less than four months of the year, or” Source
• Energy Performance of Buildings (England and Wales) Regulations 2012, regulation 5 — “(g)stand-alone buildings with a total useful floor area of less than 50m².” Source
• Energy Performance of Buildings (Scotland) Regulations 2008, regulation 4 — “(b)stand-alone buildings with a total useful floor area of less than 50m2 which are not dwellings.” Source
• Scottish Government EPC guide — “Places of worship and historic buildings are not subject to a general exemption in Scotland, unless they fall into one of the categories listed above.” Source
• Energy Performance of Buildings (England and Wales) Regulations 2012, regulation 5 — “(a)buildings officially protected as part of a designated environment or because of their special architectural or historical merit, in so far as compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance;” Source
• Bath & North East Somerset Council, EPCs and MEES: Listed Buildings — “Listed buildings are not automatically exempt from obtaining an EPC and this is a common misunderstanding.” Source
• MHCLG EPC guidance for dwellings — “An EPC will only be required for a property rented out as a furnished holiday let, as defined by HMRC, where the building is occupied for the purposes of a holiday as a result of a short term letting arrangement of less than 31 days to each tenant, and is rented out for a combined total of 4 months or more in any 12 month period, and if the occupier is responsible for meeting the energy costs for the property.” Source
• DESNZ consultation response on EPC reform — “Currently there are no specific requirements in regulation, though guidance outlines where EPCs are required.” Source
• Scottish Government EPC guide, holiday let accommodation — “The Energy Performance of Buildings (Scotland) Regulations 2008 do not contain a general exemption for holiday let accommodation.” Source
• Scottish Government EPC guide, holiday let accommodation — “Short term lets - such as accommodation let out for holiday use - are required to provide a valid EPC (as are all types of let).” Source
• nidirect, Energy Performance Certificates — “If you are selling your building or renting it out to a new tenant it is your responsibility as the owner or landlord to make sure you have an EPC.” Source
• Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, regulation 23 — “A landlord of a sub-standard domestic PR property must not let the property unless regulation 25, or one or more of the exemptions in Chapter 4, applies.” Source
• Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, regulation 24 — “In paragraph (3) and in the Schedule, “the cost cap” means £3,500 less—” Source
• Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, regulation 25 — “Subject to paragraph (3), this regulation applies for a period of five years starting with the date on which the landlord registers information in accordance with regulation 36(2).” Source
• Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, Schedule — “(i)copies of three quotations for the cost of purchasing and installing the improvement (from installers of that improvement who meet the relevant installer standards), which demonstrate that the total cost (including value added tax) would exceed the cost cap, and” Source
• Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, regulation 32 — “This paragraph applies where the landlord has not made a relevant energy efficiency improvement because the landlord has obtained a report prepared by an independent surveyor which states that making that relevant energy efficiency improvement would result in a reduction of more than 5% in the market value of the property, or of the building of which it forms part.” Source
• Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, regulation 31 — “A landlord may rely on the exemption in paragraph (1) or (1A) only where the landlord has registered information in accordance with regulation 36(2).” Source
• Scottish Government MEES impact assessment — “There are currently no MEES for PRS properties in Scotland.” Source
• Energy Act (Northern Ireland) 2022, section 9 — “Schedule 2 contains amendments to the 2006 Order enabling the Department for Communities to make regulations concerning the energy efficiency of dwelling-houses let under a private tenancy.” Source
• DESNZ PRS MEES evaluation final report — “As of August 2023, the PRS Exemptions Register included details of a total of 16,257 exemptions.” Source
• DESNZ PRS MEES evaluation final report — “Figure 8 shows that the three grounds for exemptions which accounted for a large majority of current exemptions are there being no further improvements possible to meet the minimum E standard; the costs of making such improvements exceeds the cost cap determined by DESNZ of £3,500; and consent not being granted (by planning authorities, tenants, or others) for improvements to be made.” Source
• Bath & North East Somerset Council, EPCs and MEES: Listed Buildings — “There is no requirement to register an EPC exemption in these circumstances, so you should keep written evidence of any listed building consent or planning permission decision made, whether it is approved or declined.” Source
• MHCLG EPC guidance for dwellings — “If there is any doubt as to whether works would unacceptably alter the character or appearance of a building, building owners may wish to seek the advice of their local authority’s conservation officer.” Source
• GOV.UK, View private rented sector energy standards exemptions — “You can search by postcode, street name and town, the landlord’s name or exemption/penalty type.” Source
• GOV.UK, Find an energy certificate — “You can search for a certificate by postcode, street name and town, or certificate number.” Source