For years, the accepted wisdom was that listed buildings were exempt from needing an Energy Performance Certificate. That comfortable assumption is on its way out. Under the government’s Energy Performance of Buildings reforms, the exemption for listed and heritage properties is set to be removed — so in the coming years far more owners of historic homes in Kent will need an EPC when they sell or let. The change is not yet in force, but it is coming, and this guide explains where the rules stand today, what is changing, and what to do now.
The short answer
Often, yes — and increasingly so. Even under today’s rules, a listed building has never been automatically exempt simply for being listed: the exemption only applies where the energy improvements an EPC would recommend would unacceptably alter the building’s character, which is a narrow, case-by-case test. Many listed buildings are assessed and given EPCs anyway. And that limited exemption is now set to be removed altogether under the government’s EPB reforms — so if you own a heritage property, the safest position is to plan on the basis that an EPC will be needed.
What is changing — and when?
Since 2012, listed buildings and many conservation-area properties have been treated as exempt from EPC requirements under the Energy Performance of Buildings Regulations. In its partial response to the Reforms to the Energy Performance of Buildings consultation, the government confirmed this exemption will be removed: heritage properties will need a valid EPC when marketed, let, or sold, in the same way as any other home. The reform also brings short-term and holiday lets, and whole HMOs where a single room is let, into scope.
Timing matters here. The reform is not yet in force. After engagement with industry on the delivery timeline, the government has moved the launch of the reformed EPC regime to the second half of 2027, with the exact date still to be agreed. So the exemption still applies today — but its removal is settled policy, not a rumour, and heritage owners planning a sale or let over the next couple of years should factor it in now.
The government has also said it will tailor EPC recommendations for heritage properties so inappropriate measures are not pushed onto historic fabric, and protections remain where listed building consent for improvements is refused. The headline for owners is simple: in future, being listed will no longer, on its own, get you out of needing an EPC.
Were listed buildings ever automatically exempt?
No — and this is the misconception that has caught many owners out. Even under the old rules, a listed building was only potentially exempt where the energy-efficiency improvements recommended by an EPC would unacceptably alter its character or appearance. That is a narrow, case-by-case test, not a blanket exemption. In practice, many listed buildings were assessed and given EPCs anyway, because owners wanted the documentation and because the exemption could not be claimed without an assessment in the first place.
Do Grade II listed buildings need an EPC?
Grade II is the most common listing — the majority of listed homes in Kent fall into this grade — and the same position applies as for Grade II* and Grade I. There is no separate, easier exemption for Grade II. If you are selling or letting a Grade II listed property, plan on the basis that an EPC will be required. If you believe specific improvements would genuinely damage the building’s historic character, that is something to evidence and discuss — not something to assume.
What about MEES and rented listed buildings?
If you let a listed property, the Minimum Energy Efficiency Standards (MEES) apply to you as they do to other landlords. Rented homes must currently reach at least EPC Band E, and the required standard is set to rise. Where a genuine improvement would harm a protected feature, a MEES exemption may be available — but it must be properly evidenced and formally registered on the PRS Exemptions Register. Simply being listed does not remove your MEES obligations. Click here to access the PRS Exemptions Register.
Why get an EPC on a listed building even if you think you’re exempt?
There are strong reasons to have one regardless:
- You cannot claim any exemption without an assessment first — an EPC is what identifies which measures are recommended and whether they would harm the building.
- It gives you official documentation to evidence a future exemption if one applies.
- It demonstrates compliance when selling or letting, avoiding delays and enforcement risk.
- With the exemption being removed, having an accurate, up-to-date EPC puts you ahead of the change rather than scrambling after it.
Improvements that may affect a listed building’s character
Some of the measures an EPC might recommend can alter a historic property’s appearance and may require listed building consent or planning permission before installation. These commonly include external solid-wall insulation, replacement glazing, solar panels, and externally mounted air-source heat pumps. This is exactly why a heritage property benefits from an assessor who understands the balance between energy performance and conservation — and why it is always worth speaking to your local authority conservation officer before undertaking works.
How Hive EPCs assesses listed and historic properties in Kent
Kent has a large stock of listed and period homes — from timber-framed Wealden houses to Georgian townhouses and Victorian seafront villas — and we have assessed a great many of them since 2008. We take the time to record construction and heating detail accurately rather than defaulting to worst-case software assumptions, which matters especially for older buildings whose true performance is often better than a rushed assessment suggests. Where improvements are recommended, we explain which ones are realistic for a historic property and which could cause harm, so you have a clear, honest picture before you act.
What to do next
- If you are selling or letting a listed property in the next couple of years, plan on the basis that an EPC will be needed — the exemption still applies today but is set to be removed, expected in the second half of 2027.
- Book an assessment with an assessor experienced in historic buildings, so recommendations reflect what is appropriate for your property.
- If a genuine improvement would harm a protected feature, keep the evidence and, for rented property, register any MEES exemption on the PRS Exemptions Register.
- Speak to your local authority conservation officer before carrying out any works that could affect the building’s character.