Listed Buildings- guidance to property owners

Whether or not Energy Performance Certificates (EPCs) are required for listed buildings is often debated, but the Private Rental Sector (PRS) Minimum Energy Efficiency Standards (MEES) has put this back into focus.

In the absence of clear guidance, and at the request of members, Elmhurst wishes to advise property owners of the law, and our advice on satisfying it.

The Energy Performance of Buildings (England and Wales) Regulations 2012 states:

“Duties relating to Energy Performance Certificates

Application of Part 2

5.—(1) This Part does not apply to—

(a) buildings officially protected as part of a designated environment or because of their special architectural or historical merit, in so far as compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance;”

and further guidance by DCLG relating to dwelling states: 

“Buildings that don’t need an EPC .....include ....listed buildings - you should get advice from your local authority conservation officer if the work would alter the building’s character”

Both documents require the building owner to consider the recommendations from an EPC and then make judgement, seeking advice as necessary from the local authority conservation officer, as to the impact such an improvement may have on the buildings character.

As all Elmhurst members will know there are often recommendations, such as loft insulation, hot water cylinder insulation, replacement of a boiler or an upgrade on heating controls, which are unlikely to have a negative impact or contravene planning restrictions. Clearly there are some recommendations such as solid wall insulation and double glazing which may be inappropriate. As we all know each home is different and this is especially true of listed buildings, this is why the Local Authority Conservation Officer can provide specific appropriate guidance on the property in question and be able to help owners make informed choices.

Elmhurst Energy's advice to owners of Listed Properties is that;

  • they should commission an Elmhurst member to undertake an energy assessment and issue an EPC. The energy assessor should not switch off any recommendations, unless directly given written guidance by the Local Authority Conservation Officer stating that the specific recommendation would “unacceptably alter the properties character or appearance”.

  • the owner should review the recommendations and be encouraged to consider making cost effective improvements that will reduce energy consumption and make the building more comfortable. 
  • where there are improvements that may impact on planning conditions then the advice of the local authority conservation officer should always be sought.

Furthermore, where the property is subject to the minimum requirement of PRS/MEES, and the minimum standard cannot be achieved because of planning restrictions, then this could be used to justify an Exemption.


Elmhurst has formed this opinion from its 25 years of experience and in-depth knowledge of the energy efficiency regulations that come with being the largest government approved EPC accreditation body, however, this is a complex legal area and property owners are encouraged to seek independent legal advice before taking action.

Elmhurst is still not satisfied with this situation as we believe that Listed Building should be required to have EPCs and we will continue to work with government to make this a reality.

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