Proving a listed building is EPC exempt if in fact it is?

Proving a listed building is EPC exempt if in fact it is?

11:36 AM, 1st February 2018, About 6 years ago 8

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I have a few Grade II buildings and have always worked on the basis that they are exempt from EPCs. However, I have heard that as part of the EPC standard (i.e. must be E or above to let) that comes in in April, all exempt properties need to be registered. So, not knowing if listed buildings are automatically registered, I googled the relevant page and was surprised to find the below statement which shows that a) they may not be automatically exempt and, b) somehow, we need to prove it.

From the Government site:
“You don’t need an Energy Performance Certificate (EPC) if you can demonstrate that the building is any of these:
– listed or officially protected and the minimum energy performance requirements would unacceptably alter it.”

As such, it seems we need to prove that any energy upgrades would unacceptably alter it (which is surely the call of English Heritage)…so, how would one go about proving this. And…do we really need to?


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Neil Patterson

11:41 AM, 1st February 2018, About 6 years ago

Hi Rebecca,

From the .Gov page >>

The National PRS Exemptions Register

Where a landlord believes that an F or G EPC rated property they rent qualifies for an exemption from the minimum energy efficiency standard, an exemption must be registered on the National PRS Exemptions Register. The register service is currently running as a pilot. Landlords who wish to register an exemption for a domestic or non-domestic property as part of this pilot should e-mail the BEIS minimum standards team at

John Dace

9:17 AM, 2nd February 2018, About 6 years ago

The entire EPC thing is a total nightmare. A sensible idea - executed poorly - so we end up with an expensive cock-up to try and work with. Cant believe more mention not made. E.g. -
All electric town - Invest £7000 on solar panels reducing costs for 5 tenants. Makes no difference to EPC rating - still band F! By spending £4000 more on improvements EPC doc says can save £1300 per year! Thats more than entire bill now - So no energy cost then? Clearly whole thing seriously flawed. No tenant has ever expressed any interest in what EPC rating is anyway. More complaints must surface once landlords realise.
Escpecially in couple of years when it really bites at band D.

Mike Tighe

10:59 AM, 2nd February 2018, About 6 years ago

Like you Rebecca I have some listed buildings and have been following the recent developments. For anybody else interested it is well worth downloading the Gov. guide linked in Neil's reply. The nightmare is that we DO now have to have an EPC done, and then if we object to the recommended works we have to register an exemption. Stupidly the exemption only lasts 5 years and cannot be passed on to a new owner and the onus is on us to prove the reasons for it. The good news is that almost all works which we might object to would require listed building consent and conservation officers (CO's) will almost certainly advise/object to the required works, which would justify the exemption. Due to cuts they of course are now generally overwhelmed with their work load so will not welcome a potential cascade of new applications for alterations to listed buildings. My CO has suggested that a letter from them advising against the works would be enough to satisfy the requirements of the exemptions register. It is interesting to note that it is not just listed buildings which can be covered by an exemption - it can include buildings in conservation areas as well, and any building where the proposed works could cause potential damage. (Where new double glazing is recommended though, most conservation officers would not object to internal secondary glazing which is reversible). Of great concern among many professionals in the world of historic buildings is the pressure to install wall insulation and many believe it is a time bomb in the making with potential damage to the building fabric being caused in future (mostly from trapped moisture), possibly decades hence. If a surveyor or architect specifies that wall insulation could adversely affect your building (any building, listed or not) then you could register an exemption. There is a special section in the Gov. guide covering this and you may want to search through the website of the Society for the Protection of Ancient Buildings , or call their tech helpline.
The other sort of good news for us, is that it is local authorities who will have to enforce the new legislation and since there is no new funding coming from central Gov many will just ignore it – I have unofficially been told that in my area they have no plans to take any notice of the new regulations at all, and it is unclear who if anybody will be actually looking at the exemption register which is a self certified system.
Good luck. Mike

Paul Maguire

13:08 PM, 2nd February 2018, About 6 years ago

I have a B Listed double upper in Edinburgh where the exemption doesn't apply. I boosted the loft insulation and changed all light bulbs to LED. Top floor is double glazed but the floor below [with larger windows] isn't. No wall insulation [Georgean building] but an A-Rated boiler. You jump up a level if there's property below which is sometimes missed by the assessor and to my surprise I got a C rating [a few months ago].

Mandy Thomson

21:08 PM, 4th February 2018, About 6 years ago

Hi Rebecca

I just attended a course on this with David Princep.

Firstly, check for any listed building exemptions.

You might also want to get a green deal assessment done; this costs around £40 and you don't have to eligible for funding.

You may still need to get an EPC, if only to prove exemption; if you are given a list of improvements, you have to apply for funding with the government backed schemes either for all the items on the list or work your way through in order of priority - you can't skip an item.

If you believe the EPC rating is too low, you should get another one done by another provider, certainly if you had one done before November 2017, when more reliable software (RDSAP) was brought in.

If funding is unavailable or your tenant isn't eligible (for most schemes, your tenant must be on a low income or claiming benefit), you can then register as exempt, without paying a penny. However, government are currently consulting on bringing in an upfront amount for landlords to pay which will come in next year. This is currently proposed to be £2,500, but could more if certain lobby groups get their way.

Be warned that if you do register as exempt, your local council can pick properties from the exemption register for improvement under HHSRS.

Monty Bodkin

9:10 AM, 5th February 2018, About 6 years ago

Reply to the comment left by Mike Tighe at 02/02/2018 - 10:59
"The other sort of good news for us, is that it is local authorities who will have to enforce the new legislation and since there is no new funding coming from central Gov many will just ignore it –"

They'll ignore it right up until you try to evict under section 24.

Monty Bodkin

9:50 AM, 5th February 2018, About 6 years ago

Woops! Freudian slip, meant try to evict under section 21 of course.

Martin S

22:10 PM, 10th February 2018, About 6 years ago

There is one EPC exemption not mentioned here, and that is for detached buildings which have a usable floor space less than 50sq/m. I have one of these, built around 1900, which at 30sq/m I believe to be the smallest occupied detached house in the UK, and tenants have always been happy with their micro home!

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