Energy Performance Certificates are required for the sale and rental of most properties in England and Wales, but listed buildings are among the categories of property that may be exempt from this requirement. The exemption is not absolute and applying it correctly requires understanding the specific conditions under which it applies.

The EPC Exemption for Listed Buildings

The Energy Performance of Buildings (England and Wales) Regulations 2012 provide that a building is exempt from the EPC requirement where the building is a listed building or officially protected and where compliance with minimum energy performance requirements would unacceptably alter its character or appearance. This is the key qualification: the exemption applies not simply because a building is listed, but because the energy efficiency measures needed to achieve a valid EPC rating would unacceptably alter the building's character.

In practice, this means that the exemption is available to most listed buildings, because the standard energy improvement measures required to bring an older building up to the minimum rating, such as cavity wall insulation, double glazing replacement, and certain types of roof insulation, are often incompatible with the listed building's historic fabric and would require listed building consent that might not be granted.

How the Exemption Works in Practice

If you are selling or renting a listed building and wish to rely on the EPC exemption, you do not need to apply to anyone for the exemption, but you must be satisfied that the conditions for the exemption are met. In practice, most conveyancing solicitors will accept the listed building status as sufficient basis for the exemption without requiring further evidence, provided the property is on the statutory list of listed buildings.

The exemption covers the requirement to commission an EPC and to provide one to a buyer or tenant. It does not exempt the property from other energy-related requirements such as the minimum energy efficiency standards that apply to privately rented properties in England, though listed buildings also have an exemption route for those requirements through the register of exemptions maintained by the government.

When an EPC May Still Be Required or Useful

Some listed buildings, particularly those that have been substantially modernised with modern double glazing, insulation, and heating systems, may be capable of achieving a reasonable EPC rating without affecting their listed status. In these cases, obtaining an EPC may actually be beneficial as it demonstrates the property's energy efficiency to prospective buyers or tenants. The exemption is available but is not mandatory to use.

Where a listed building has been converted into flats, individual units may have their own EPC requirements and exemption status assessed separately from the overall building's listed status.

Scotland

Scotland has similar provisions for listed buildings under its own energy performance regulations. The exemption conditions are broadly comparable but the specific regulatory framework differs from England and Wales.

Summary

Most listed buildings in England are exempt from the requirement to have an Energy Performance Certificate when sold or rented, because the energy improvement measures that would be needed to achieve a valid EPC rating would unacceptably alter their historic character. The exemption is available without formal application but the conditions must be met. Listed buildings that have been comprehensively modernised may not strictly need to rely on the exemption. Consulting a solicitor experienced in listed property conveyancing confirms the position for any specific property.