Last updated: July 2026
For owners and landlords of listed properties, EPC compliance is not always straightforward. Some listed buildings may qualify for an EPC exemption, but this does not mean they are exempt from Building Regulations or other compliance requirements.
The key question is whether meeting minimum energy performance requirements would unacceptably alter the building’s character or appearance. An Energy Performance Certificate (EPC) records the property’s energy efficiency rating and recommended improvements, but protected buildings may be exempt from needing one where compliance would harm their character or appearance.
This guide explains how EPC requirements are assessed for listed properties, when an exemption may apply, how Building Regulations and listed building consent interact, and what owners and landlords should consider before carrying out energy-efficiency improvements.
For professional support with EPCs and building compliance for listed properties, contact Falcon Energy about our EPC services. Our OCDEA-accredited assessors work across Sussex, Surrey, Kent, and London, with extensive knowledge and experience.
What are listed buildings?
The term ‘listed building’ refers to any building protected on the basis of its special architectural or historical interest, due to which it is considered to be of national importance.
Listed buildings are categorised by their significance:
- Grade I: buildings of exceptional interest.
- Grade II*: particularly important buildings of more than special interest.
- Grade II: buildings that are of special interest.
Other notable building categorisations include those protected under ‘Article 4 Directions’; which refers to buildings officially protected due to their location within the boundaries of a conservation area.
These typically historic buildings are protected under varying degrees of restrictions, but in all circumstances their status demands that listed building consent must be applied for, as well as planning permission and building regulations approval, before changes are made that may affect their ‘special interest’.
Do listed properties need an EPC?
An Energy Performance Certificate (EPC) provides an energy efficiency rating for a property, along with recommended measures that could improve its EPC rating.
In most cases, an EPC is legally required when a property is sold, let or newly built. However, listed properties are more complex. A listed building may be exempt where meeting minimum energy performance requirements would unacceptably alter its character or appearance.
This exemption is not based on listed status alone and should not be assumed automatically. It depends on whether the recommended improvements would harm the property’s character, historic fabric or significance. For example, replacement windows may be unsuitable, whereas loft insulation, draught-proofing, or heating controls may be appropriate.
Where there is doubt, owners should speak to the local authority’s conservation officer or local planning authority before assuming a listed building exemption applies.
Why listed properties require a different approach
Listed buildings are protected because of their historic, architectural or cultural importance. Their listed status means that changes affecting the building’s character or appearance may require listed building consent from the local planning authority.
This matters because an EPC assessment does not sit in isolation and should be considered alongside wider compliance requirements. Any recommended upgrades need to be considered alongside Building Regulations, heritage restrictions and the potential need for further consent.
Traditional materials, historic windows, solid walls and breathable construction can all influence what is practical, compliant and appropriate for the building.
However, this does not mean that historic buildings cannot be made more energy-efficient. The key is to choose sensitive upgrades that improve the building’s performance while preserving its character and ensuring compliance.
How EPC assessments, Building Regulations and listed building consent work together
For listed properties, ensuring compliance means considering the EPC assessment, Building Regulations and any heritage consent requirements together, rather than treating them as separate stages.
One of the biggest challenges for owners of listed properties is understanding how the different requirements overlap. Building Regulations are the legal standards that apply to building work, covering areas such as safety, structure, ventilation and energy performance.
Alongside these, an EPC assessment, listed building consent and planning permission all serve different purposes.
| Requirement | Purpose | When it may apply |
| Energy Performance Certificate (EPC) | Measures the property’s energy efficiency and gives an energy efficiency rating | Selling, letting, new-build completion and some construction projects |
| Building Regulations | Set standards for safety, structure, ventilation and energy performance | Extensions, conversions, refurbishments and some upgrades |
| Listed Building Consent | Protects the building’s character, fabric and special architectural or historic interest | Alterations, extensions or demolition affecting the building’s character |
| Planning Permission | Controls development, external changes and land use | Extensions, external alterations and work in conservation areas or other protected settings |
This is why early advice is vital. A measure that looks sensible from an EPC rating perspective may not be acceptable from a heritage perspective. Equally, a property may still need to comply with Building Regulations even where heritage constraints limit what can practically be achieved.
In some cases, Building Control may consider alternative approaches where strict compliance with standard minimum energy performance requirements would harm historic fabric. The aim is not to ignore energy-efficiency standards, but to find a proportionate approach that protects the building while supporting compliance.
Minimum Energy Efficiency Standards and listed buildings
Minimum Energy Efficiency Standards, often shortened to MEES, are important for landlords because they link directly to a property’s EPC rating. If a privately rented property that requires an EPC falls below the required minimum, the landlord may need to carry out suitable energy efficiency improvements or register a valid exemption on the Private Rented Sector (PRS) Exemptions Register.
For listed properties, this needs careful consideration. A listed building may qualify for an EPC exemption if the necessary works would unacceptably alter its character or appearance, but this does not mean every listed property is automatically exempt from MEES requirements.
Where an exemption is being relied on, landlords should keep appropriate evidence and, where required, register it on the PRS Exemptions Register.
Common energy efficiency improvements for listed properties
Following an EPC assessment, where one is required, owners of listed properties may be advised to consider a range of energy efficiency improvements. However, any recommended measures must be reviewed against Building Regulations, listed building consent requirements and the potential impact on the building’s character.
Common energy efficiency improvements may include:
- Draught proofing around doors, windows and floorboards
- Loft insulation where roof spaces allow
- Secondary glazing rather than replacement windows
- Heating system upgrades and controls
- Low-energy lighting
- Breathable insulation where suitable
- Careful consideration of solar panels where they will not harm the building’s character or appearance
The right approach depends on the building. A Georgian townhouse, a converted barn, a Victorian terrace, and a rural cottage may all need different solutions.
The goal is to improve energy efficiency while respecting the property’s character. Poorly chosen measures can cause more harm than good, especially in historic buildings where trapped moisture or unsuitable insulation can lead to long-term damage.
This is why any proposed improvement should be considered as part of the wider compliance process. Once the most suitable measures have been identified, owners need to understand whether the work also triggers Building Regulations, listed building consent, or further approval from the local planning authority.
Building Regulation compliance during renovation projects
For listed properties, improving energy performance is rarely just a case of carrying out the recommendations in an EPC report. Many upgrades, including insulation, heating replacements, extensions, conversions or window changes, may also need to comply with relevant parts of Building Regulations.
Part L of the Building Regulations deals with the conservation of fuel and power. Its purpose is to improve energy performance and reduce carbon emissions, but for historic buildings, these standards need to be applied carefully to avoid damaging the building’s fabric or character.
For example, an extension to a listed property may need to meet modern minimum energy performance requirements, while the existing historic structure may need a more sensitive approach. Improving insulation in one area may be appropriate, while another part of the building may need an alternative method to protect the historic fabric.
As energy performance standards continue to evolve, there is an increasing focus on improving the efficiency of existing buildings. Listed and historic properties are part of that conversation, but improvements must be carefully planned so they support compliance without compromising the building’s character.
Why experienced EPC assessors matter for listed buildings
A standard EPC assessment can be straightforward for a modern property, but EPC assessments for listed properties require more careful consideration. Older buildings often have traditional construction methods, solid walls, unusual layouts, older heating systems, and materials that behave differently from those in modern building fabric.
An experienced assessor can help identify suitable energy-efficiency measures and explain how the recommendations may affect the EPC rating. They can also help owners understand where further advice or consent may be needed, and where improvements may risk affecting the property’s character.
We recently carried out EPC and MEES compliance services at the 3500 acre, 150 property Knepp Estate who instructed us to assess and provide guidance with regards to ensuring all buildings were in line with relevant regulations.
If you’re planning work on a listed property or need professional EPC advice, Falcon Energy can help with accurate assessments and compliance support.
Summary
Listed property EPC assessments require more careful consideration than standard assessments because energy-efficiency recommendations must be balanced against Building Regulations, listed building consent and the building’s historic character. Some listed buildings may not need an EPC where meeting minimum energy performance requirements would unacceptably alter their character or appearance, but this should never be assumed automatically.
For landlords, MEES requirements may also apply where a privately rented property requires an EPC. The safest approach is to review the property, the recommended improvements and any consent requirements together, so energy performance can be improved where appropriate while keeping the building compliant and protected.
Book an EPC assessment for a listed property
If you need an EPC assessment for a listed property, or you’re unsure whether an EPC is required, Falcon Energy can provide clear, practical advice. Our professional assessors can help you understand your EPC requirements before selling, letting or carrying out improvement works.
Contact Falcon Energy today for advice or to book your EPC assessment.
FAQ’s
Does every listed building need an EPC?
No. Some listed buildings may not need an EPC if meeting minimum energy performance requirements would unacceptably alter their character or appearance. However, the exemption is not automatic, so owners should seek advice before assuming an EPC is or is not required.
Are listed buildings exempt from MEES regulations?
Not automatically. If a listed property is privately rented and requires an EPC, the landlord may need to improve the EPC rating or register a valid exemption on the Private Rented Sector (PRS) Exemptions Register.
What energy efficiency measures are suitable for listed properties?
Suitable measures vary, but common options include draught-proofing, secondary glazing, heating controls, loft insulation, and sensitive heating upgrades. More visible changes, such as replacement windows or solar panels, may need listed building consent.
This article is for general discussion only. Owners and landlords should seek professional advice and consult the relevant local planning authority or conservation officer where required.