EPC exemptions: listed buildings, holiday lets and the PRS register

Holiday lets and short-term accommodation

Holiday accommodation has its own, separate exemption logic, distinct from the listed building rules. Broadly, a self-catering property let out for fewer than a defined number of weeks or months per year, without being someone's main residence, may fall outside the requirement for an EPC altogether, whereas a property let more regularly, or marketed as available for longer lets, is likely to need one. Owners sometimes assume any furnished holiday let is automatically exempt, which is not a safe assumption once the letting pattern moves beyond genuinely occasional short lets.

• The exemption broadly applies to accommodation let for a limited period each year, not used as a main residence.
• Properties let more frequently, or marketed for longer-term stays, are likely to fall back into needing an EPC.
• Mixed-use patterns (some holiday lets, some longer lets) generally require an EPC to be safe.
• Marketing platforms increasingly ask for EPC information regardless of the strict legal position, which can force the issue commercially even where an exemption might technically apply.

Other specific exemptions

Beyond listed buildings and holiday lets, a small number of other building types and situations have their own defined exemptions from the general requirement to produce an EPC, generally because standard energy assessment methods don't apply well to them or because of their limited or specific use.

• Places of worship used primarily for religious activities.
• Temporary buildings with a planned time of use of two years or less.
• Stand-alone buildings with a total useful floor area of under 50 square metres.
• Buildings due to be demolished, where the demolition is supported by relevant planning consent.
• Certain industrial sites, workshops and non-residential agricultural buildings with low energy demand.

MEES exemptions and the PRS Exemptions Register

Where a landlord believes a property qualifies for an exemption from the MEES minimum band E standard — whether that's a listed building measure, the cost cap, third-party consent, or devaluation — that exemption must be formally registered on the PRS Exemptions Register with supporting evidence before it can be relied upon. An exemption that exists only in the landlord's own reasoning, without registration, offers no protection if the local authority investigates the property.

• Register the specific exemption type that applies, with supporting evidence.
• For listed buildings, this typically means evidence a specific measure would be refused or unacceptable.
• Registered exemptions generally last five years before needing reassessment.
• Selling or transferring the property does not automatically transfer the exemption to the new owner.

Getting the assessment right before assuming an exemption

In our experience, owners of listed buildings and unusual properties often assume an exemption applies before an accurate EPC has even been carried out, which can mean missing genuinely available improvements that would be perfectly acceptable to a conservation officer, such as internal secondary glazing or loft insulation in a non-original roof space. Starting with a proper assessment, carried out by someone experienced with older and listed housing stock, gives an accurate picture of what's actually achievable before reaching for an exemption.