In the UK, Energy Performance Certificates (EPCs) are a legal requirement in most situations when you sell, let, or construct a property. They give buyers, tenants, and landlords an energy efficiency rating, alongside a recommendation report detailing possible energy efficiency measures to help reduce energy bills and improve comfort.
However, there are certain circumstances where an EPC is not required for residential and commercial properties. Some listed buildings, temporary buildings intended for use for less than two years, small stand-alone buildings under 50 square metres, and certain commercial or agricultural buildings with low energy demand can be exempt. Understanding these exceptions matters because failing to provide an EPC when it is legally required can result in fines, enforcement action from Trading Standards, and, in serious cases, court proceedings.
In this guide, we’ll explain what an EPC is, when an EPC is not required, address common misunderstandings, and outline the risks of getting it wrong. If you’re unsure whether your property falls under an EPC requirement, you can get professional advice from an accredited energy assessor at Falcon Energy. You can also book our EPC assessment services with our team nationwide.
At Falcon Energy, we provide professional EPC assessments and certificate services across the UK. Please email us or call 01403 253439 for a free, no-obligation quote.
Table of Contents
What is an EPC, and when is it usually required?
An Energy Performance Certificate rates how energy efficient your property is, from A (most efficient) to G (least efficient). It also estimates energy costs and suggests improvements to lower energy consumption.
EPCs are usually required when:
- Selling a property to a prospective buyer.
- Letting to a prospective tenant.
- Completing new construction that falls under building regulations.
- Making changes that affect the total useful floor area or indoor climate, such as adding air conditioning.
This applies to houses, flats, commercial property, industrial sites, and even certain non-residential agricultural buildings. If you are in any doubt, you should always check with an energy assessor.
To learn more about EPCs, read our guide ‘What Do EPC Ratings Mean?‘.
When is an EPC not required for residential property?
In certain circumstances, you don’t have to provide an EPC when selling or letting a home. These scenarios are defined in UK regulations, and each has specific conditions.
1. Listed buildings
A listed home may be exempt from needing an EPC if meeting the minimum energy performance requirements would unacceptably alter its historic character or appearance. This isn’t automatic – each case is assessed individually. You must demonstrate that the recommended energy efficiency improvements would damage the property’s historic features or appearance. If upgrades can be made without harming its significance, you will still need an EPC when selling or letting.
For more details on listed buildings and EPC requirements, see our guide ‘Do Listed Buildings Need An EPC?‘
2. Temporary buildings
If a residential property is intended for use for less than two years, an EPC is generally not required. This often applies to short-term housing solutions, temporary site accommodation, or modular homes granted temporary planning permission. The key factor is the planned duration of use – if it exceeds two years, an EPC may be required. Always keep documentation showing the intended short-term use.
3. Stand-alone buildings under 50 square metres
Small, self-contained buildings with a total useful floor area of less than 50 m² are exempt from EPC requirements. Common examples include garden annexes, small storage units, or independent outbuildings. The exemption only applies if the building is physically separate from another property. If floor space is extended above 50 m², an EPC will be required.
4. Buildings due for demolition
You don’t need an EPC if the property is due to be demolished and you have the relevant planning permission and legal documentation. This exemption only applies if redevelopment is certain and evidence, such as approved demolition notices or contracts, is in place. Marketing the property without confirmed demolition plans still requires a valid EPC.
5. Certain lease agreements
There are a few narrowly defined exemptions for very short or very long leases, but they are rare. In most cases, both rental and long-lease properties will require an EPC. These exceptions are uncommon, so always confirm your situation with an accredited energy assessor before assuming an EPC is not required.
When is an EPC not required for commercial property?
While most commercial properties require an EPC before being sold or let, there are a few exemptions under UK regulations. Some overlap with residential rules, while others are unique to commercial buildings.
1. Listed buildings
Some listed commercial properties, such as heritage offices, period shopfronts, or historic public buildings, may be exempt if the required energy upgrades would compromise their protected architectural details. This exemption is judged individually, and clear evidence is needed. If it’s possible to make improvements without altering the building’s significance, an EPC will still be required.
2. Non-residential agricultural buildings with low energy demand
Agricultural buildings used for storage or housing livestock, and which have no fixed heating or cooling, may be exempt. This is because they have genuinely low energy demand and are not designed for human comfort. However, if the building is converted for heated use, such as offices or workshops, it will require an EPC.
3. Workshops and industrial sites without heating or cooling
Workshops and industrial premises with no systems to maintain an indoor climate may not need an EPC. The exemption applies to sites with minimal energy consumption for comfort. Installing heating or cooling, even partially, removes the exemption.
4. Small stand-alone buildings under 50 square metres
Self-contained commercial buildings with a total useful floor area under 50 m² may be exempt. Examples include kiosks, storage sheds, or remote outbuildings. If the building is expanded beyond 50 m², an EPC will be required.
5. Temporary buildings
Commercial units intended for short-term use of less than two years may qualify for an exemption. This can include pop-up retail spaces, marketing suites, or temporary site offices. Once the use period exceeds two years, an EPC becomes a requirement.
6. Buildings due for demolition
Commercial properties scheduled for demolition may be exempt if all planning permissions and demolition contracts are in place. This applies where the building will be removed entirely and not occupied again. Without firm plans, an EPC will still be required before marketing.
7. Certain lease agreements
There are rare situations where short or very long commercial leases may be exempt. However, these are uncommon and should always be verified with an accredited energy assessor before assuming an exemption applies.
Are places of worship exempt from EPC requirements?
Buildings used primarily for worship or other religious activities are generally exempt from EPC requirements. This applies regardless of whether the property is otherwise classed as residential or commercial. Examples include churches, mosques, temples, and synagogues.
If part of the building is used for another purpose, such as commercial rental space or residential accommodation, that portion may still require an EPC.
Other rare EPC exemptions
A few additional exemptions exist, though they apply in very specific cases. Examples include certain holiday lets used for less than four months a year, military buildings, and some protected heritage structures that are not formally listed but have environmental or planning restrictions preventing energy efficiency works. These situations are uncommon, so always confirm with an accredited energy assessor before assuming an EPC is not required.
Checklist: Does my property need an EPC?
If you answer yes to any of these, you will usually need to provide an EPC before selling or letting the property. There are some narrow exemptions, but most properties fall under the requirement.
| Question | EPC Likely Required? |
|---|---|
| Is the property being sold or let to a prospective buyer or tenant? | Yes |
| Does it have a total useful floor area of over 50 square metres? | Yes |
| Is it intended to be in use for more than two years? | Yes |
| Is it a listed building where energy improvements wouldn’t alter its character or historic features? | Depends – only exempt if improvements would unacceptably change its appearance or protected features. |
| Does it have fixed heating or cooling to maintain an indoor climate? | Yes |
| Is it an industrial site or a non-residential agricultural building with low energy demand? | No – if genuinely low energy demand and no fixed heating/cooling; otherwise, yes. |
| Is it due for demolition with full planning permission and legal documentation in place? | No – if demolition is certain and evidence is available; otherwise, yes. |
Common misunderstandings about EPC exemptions
It’s easy to misinterpret EPC exemption rules, and these misunderstandings can lead to costly mistakes. Here are some of the most frequent ones:
- Believing “EPC not required” means “never required”: Many exemptions are time-limited or conditional. For example, a temporary building may become subject to EPC rules if it remains in use beyond the intended period.
- Assuming listed buildings are automatically exempt: Listed status alone doesn’t remove the requirement – you must be able to show that the recommended energy efficiency measures would unacceptably change the property’s appearance or historic features.
- Forgetting that alterations can trigger a new EPC requirement: Significant changes to construction, floor space, or the indoor climate (such as installing air conditioning or heating) can mean an EPC is needed, even if one wasn’t required before.
In short, exemptions only apply in specific, narrowly defined circumstances, and your property’s EPC status can change over time depending on its use, condition, and energy performance.
Penalties and risks of getting it wrong
Failing to provide an EPC when it’s legally required can result in consequences that include:
- Financial penalties: Fines typically range from £500 to £5,000, depending on the property’s floor space and rateable value (the official rental value used for business rates).
- Marketing or transaction delays: Without a valid EPC, you may be unable to advertise in commercial media or finalise lease agreements.
- Public naming: Trading standards can list non-compliant properties and owners publicly.
- Legal escalation: In severe or repeated cases, enforcement can be taken to court.
The simplest way to avoid these risks is to take a proactive approach: confirm early whether your property requires an EPC, and if it does, have an accredited energy assessor prepare a valid certificate before you market or let the property.
Summary: EPC exemptions
For residential property, exemptions may apply in specific circumstances such as listed buildings, temporary buildings, small stand-alone buildings, properties scheduled for demolition, and certain narrowly defined lease agreements.
For commercial property, exemptions can include non-residential agricultural buildings with low energy demand, unheated industrial sites, small stand-alone buildings, properties intended for temporary use, and some rare lease arrangements.
EPC regulations and exemption criteria can change, so it’s important to stay updated. EPC regulations and exemption criteria can change, so it’s important to stay updated via official GOV.UK guidance. Always confirm whether your property requires an EPC before selling or letting, and if it does, get it from a trusted, accredited provider to guarantee accuracy and compliance.
Book your EPC assessment with Falcon Energy
Knowing when an EPC is not required can help you save money, avoid penalty charges, and focus your budget on meaningful energy efficiency measures. However, for most property owners, an EPC will still be needed, and getting it right is essential for compliance.
If you need an EPC test, book an EPC assessment with Falcon Energy. Our accredited energy assessors work nationwide and take pride in delivering exceptional customer service. We’ll make the process straightforward and give you practical advice to improve your property’s energy performance.
EPC FAQ
How long do EPC exemptions last?
Most EPC exemptions recorded on the PRS Exemptions Register (for rental properties that don’t meet minimum EPC standards) last for five years and must then be reviewed and, if still applicable, re-registered. Other exemptions, such as those for temporary buildings or demolition, only last for as long as the original conditions apply. If the building’s use, structure, or plans change, the exemption can end immediately. Always check your circumstances before assuming an exemption still applies.
Who is responsible for arranging an EPC?
The responsibility usually falls on the property owner, whether you’re a landlord, seller, or developer. In rental situations, landlords must ensure the EPC is in place before marketing the property. For sales, the seller must have a valid EPC available for prospective buyers.
How can I check if my property already has a valid EPC?
You can search the government’s EPC register online using your property’s address or certificate number. This will show whether a valid EPC exists, its energy efficiency rating, and when it expires. If it’s expired or missing, you’ll need to arrange a new one before selling or letting.
How much does an EPC cost?
The cost of an EPC in the UK can vary depending on the type of property, its size, and location. Residential EPCs often cost less than commercial ones, as commercial assessments can be more detailed and time-consuming.
To get more insight, read our guide, “How Much Does An EPC Certificate Cost In The UK?“.