2 Essential Regulations for Historic Building EPC Assessments

Historic buildings are a valuable part of the property market, but meeting energy efficiency and energy performance requirements can be complex, particularly where heritage protections and planning controls apply.

This guide explains two core regulations that govern historic building EPC assessments, then covers the key laws, exemptions, and practical considerations that affect which energy efficiency improvements are realistic and compliant. Exemptions apply only where all relevant criteria are met and must be supported by appropriate evidence.

If you own or manage a historic property, working with an accredited energy assessor is essential. Learn more about our EPC services, including conducting EPC assessments and providing expert guidance to achieve compliance and improve an EPC rating.

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Key regulations that apply to historic building EPCs

Historic buildings are typically older or traditionally constructed properties, and may include listed buildings or be located in designated areas such as conservation areas, where upgrades must protect the building’s character.

For owners and landlords, the next question is what this means for compliance in practice. Historic building EPC assessments are mainly governed by two regulations: one that sets out when an energy performance certificate (EPC) is required, and another that sets minimum energy efficiency standards (MEES) for rented properties.

Energy Performance of Buildings (England and Wales) Regulations

This is the primary regulation governing EPCs across England and Wales.

It legally requires:

• A valid EPC when a building is sold or let
• EPCs to be produced by an accredited energy assessor
• A standardised EPC assessment methodology
• Disclosure of energy efficiency rating, energy consumption, and energy performance improvements

Historic buildings are generally required to have an EPC unless they qualify for a specific exemption. EPCs are based on visual inspection, known construction methods, and reasonable assumptions about energy usage patterns.

Importantly, the regulation does not require building owners to carry out improvements; rather, it requires accurate assessment and disclosure.

Energy Efficiency (Private Rented Property) (England and Wales) Regulations (MEES)

The MEES regulations introduce legally enforceable minimum energy efficiency standards for rented properties.

They require:

• A minimum EPC rating (currently E)
• Compliance with minimum energy performance requirements
• Registration of valid MEES exemptions where applicable

MEES primarily affects:

• Commercial landlords
• Private Rented Sector (PRS) residential landlords
• Mixed-use historic buildings

Failure to comply can result in financial penalties and properties becoming legally unlettable. However, historic buildings often qualify for exemptions where required improvements would unacceptably alter the building’s character or its historical integrity.

What else affects historic building EPC assessments? (laws, exemptions and guidance)

EPC outcomes for historic buildings are heavily influenced by planning law, statutory exemption routes, and professional guidance. For building owners and landlords, these factors often determine whether recommended energy efficiency improvements are achievable, restricted, or exempt.

Town and Country Planning (General Permitted Development) Orders (GPDO)

These orders define what building work you can carry out as permitted development, in other words, what can be done without applying for planning permission. For historic buildings, this matters because many common energy-efficiency upgrades may not qualify as permitted development, especially for listed buildings, properties in conservation areas, or other designated areas.

They’re particularly relevant for works such as:

• Solar panels
• Wall insulation
• Changes to windows and external walls
• External alterations in conservation areas and other designated environments

In practice, this means EPC recommendations may be technically sensible but not automatically achievable. If planning permission (or other consent) is required, you may need local authority approval before making improvements, so these rules directly affect which recommended energy efficiency measures are realistic and lawful.

Planning (Listed Buildings and Conservation Areas) Act

For listed buildings, this Act is often the most decisive factor in an EPC assessment. It legally protects buildings of special architectural or historic interest and requires listed building consent for works that could affect their character or appearance.

In practical terms, this means EPC recommendations such as double glazing, external wall insulation, or changes to heating systems cannot be assumed to be viable. Where improvements would unacceptably alter the building or harm its heritage value, this Act can support exemption claims under both EPC and MEES rules.

MEES exemptions and devaluation provisions (statutory)

Where minimum energy efficiency standards apply, historic buildings may qualify for statutory MEES exemptions. These include cases where consent for works is refused, where improvements would damage heritage value, or where measures would reduce the property’s market value under a devaluation exemption.

These exemptions must be properly evidenced and registered on the PRS Exemptions Register. When used correctly, they allow landlords to meet their legal obligations without carrying out inappropriate or damaging works.

Historic England guidance

While not law, guidance from Historic England plays a significant role in how EPC recommendations are interpreted and enforced. It sets out best practice for balancing energy efficiency improvements with conservation and is frequently relied on by local authorities when assessing proposed works.

For owners, this guidance helps clarify which upgrades may be considered sensitive and acceptable, and which are likely to be resisted.

Local authority policies and conservation officers

Local planning policies and advice from a local authority’s conservation officer often determine whether energy efficiency works are approved, amended, or refused. Their assessment typically focuses on whether proposals would affect a building’s character, appearance, or historic significance.

Engaging with these requirements early can help avoid delays, refused consents, and unrealistic EPC expectations.

EPC methodology and assessment rules

EPCs for historic buildings follow a recognised methodology that requires careful professional judgement. Assessors must account for original construction, building fabric limitations, non-standard heating systems, and realistic energy usage assumptions.

The purpose is to assess a building’s actual energy performance, not to penalise heritage or mandate inappropriate improvements, reinforcing why experience with historic properties matters when getting an EPC.

What energy efficiency measures are suitable for historic buildings?

With the regulatory and heritage context in mind, it’s important to identify energy efficiency measures that deliver genuine energy performance improvements without unnecessary risk or inappropriate alteration. In many cases, improvements focus on reducing energy demand and improving system efficiency rather than altering the building fabric.

Common, lower-impact energy efficiency measures that may be suitable for historic buildings include:

• Secondary glazing
• LED lighting
• Heating controls and efficient heating systems
• Insulation solutions that do not affect external walls
• Improvements that reduce energy consumption without visible alteration

Depending on the property and consent requirements, renewable energy sources such as solar panels may also be appropriate. The aim is to achieve compliant, cost-effective improvements that reduce running costs while protecting the building’s character and long-term value.

Why an accredited energy assessor matters for historic building EPCs

Historic buildings aren’t assessed in the same way as modern properties. Older construction methods, unusual heating systems, and limited evidence about how the building performs can all affect the EPC rating. On top of that, some energy efficiency improvements may not be suitable or may need consent if they would change the building’s character.

A trusted, accredited energy assessor will carry out a thorough EPC assessment, apply the correct methodology for historic properties, and provide practical recommendations that are realistic and compliant. You’ll also receive clear documentation to support sales or lettings and help meet EPC requirements and minimum energy efficiency standards (MEES), where they apply.

Summary

Historic buildings present unique challenges, but they are not outside modern energy regulation. In England and Wales, historic building EPC assessments are shaped by core regulations, alongside planning and heritage law, statutory MEES exemptions, and professional guidance.

Understanding how these frameworks work together allows building owners and landlords to:

• Meet EPC obligations with confidence
• Navigate MEES requirements and exemption routes
• Make informed, lawful energy efficiency improvements
• Protect a building’s character, heritage, and long-term value

With the right professional support, it’s possible to balance compliance, energy performance improvements, and conservation without unnecessary risk.

Book EPC assessments with Falcon Energy

If you own or manage a historic property, our accredited assessors provide compliant, professional EPC assessments for listed and heritage buildings. We’ll help you understand your obligations, navigate exemptions, and identify realistic energy efficiency improvements.

Get a free quote today and book your EPC assessment with Falcon Energy.

Frequently Asked Questions

This article provides general regulatory guidance and does not constitute legal advice. EPC obligations and exemptions should always be assessed on a case-by-case basis.