Most landlords must ensure their rental properties meet a minimum EPC rating (currently band E in most cases). But what if your property is genuinely hard to improve – or the necessary work is refused or would be unreasonable?
That’s where EPC exemptions come in. Used correctly, they provide a legal route to let certain properties even if they fall below the minimum standard. Used carelessly, they can expose you to enforcement action.
This guide explains:
- When EPC exemptions are available for landlords
- The main exemption categories and evidence required
- How to register exemptions properly and how long they last
For the full landlord rules and 2030 context, see EPC Rules for Landlords in 2025–2030.
1. What is an EPC exemption?
An EPC exemption allows you to legally let a property that doesn’t meet the minimum EPC standard (currently band E) in specific, tightly defined circumstances.
Key points:
- Exemptions are not automatic – you must register them on the official PRS Exemptions Register.
- They usually last for a fixed period (often up to 5 years), after which you’ll need to reassess.
- Exemptions are tied to the landlord and property – selling the property typically means the new owner must either re-register or carry out improvements.
The aim is to balance energy-efficiency goals with practical realities – for example, leasehold constraints, listed buildings or disproportionate cost.
2. Do you really need an exemption?
Before relying on an exemption, it’s vital to check:
- Whether your EPC is current – see Is My EPC Still Valid?.
- Whether basic, cost-effective upgrades (like loft or cavity wall insulation) could raise the rating instead – see 27 Ways to Improve Your EPC Rating.
- Whether the property falls into a category outside the minimum standard rules.
Exemptions should be a last resort, not a shortcut to avoid reasonable improvements.
3. Main EPC exemption categories for landlords
The exact wording can evolve, but the main exemption types usually include:
a) “All relevant improvements made” (cost cap exemption)
Use this where:
- You’ve installed all cost-effective measures recommended by an EPC or survey, or
- You’ve spent up to the relevant cost cap on recommended measures,
but the property still doesn’t reach the minimum EPC rating.
Evidence typically needed:
- A list of the recommended improvements and those carried out.
- Invoices and receipts showing costs incurred.
- EPC / assessment evidence that no further relevant improvements are available within the cap.
b) “Wall insulation exemption”
Applies where an independent expert (e.g. chartered surveyor or qualified installer) advises that:
- Specific types of wall insulation (cavity, internal or external) would be inappropriate for the property – for example due to damp risk, structural issues or exposure.
Evidence typically needed:
- A written report by a suitably qualified professional explaining why wall insulation isn’t suitable.
c) “Consent exemption”
Use this when you can’t get the necessary permission to carry out works, for example:
- The tenant refuses consent for improvements that require access or significant disruption.
- A freeholder or superior landlord refuses permission in a leasehold block.
- The local authority refuses planning permission or listed building consent.
Evidence typically needed:
- Copies of letters, emails or notices showing you’ve requested consent.
- Written refusals or evidence of no response after reasonable attempts.
d) “Devaluation exemption”
This applies when a qualified independent surveyor confirms that installing certain recommended measures would reduce the property’s market value by more than a set threshold (commonly cited around 5%).
Evidence typically needed:
- A surveyor’s report detailing the likely devaluation and rationale.
e) “New landlord exemption”
In some circumstances, if you become a landlord in a way that gives you limited time to comply (e.g. inheritance or certain legal processes), you may be granted a temporary exemption period to:
- Assess the property, and
- Bring it up to standard or register a longer-term exemption.
Always check the latest government guidance and timings for this exemption.
4. Properties that might not need an exemption
Some buildings or situations fall outside the minimum standard regulations altogether. Examples can include:
- Certain listed buildings where energy-efficiency requirements would unacceptably alter the character or appearance – though this is more nuanced than many assume.
- Temporary buildings with planned use of two years or less.
- Some non-residential or mixed-use buildings, depending on how space is used.
Even if formal minimum standards don’t apply, improving EPC performance can still:
- Make the property more attractive to tenants and buyers.
- Reduce running costs and maintenance issues.
For listed or heritage properties, see How to Improve EPC on a Victorian House for fabric-first ideas that respect character.
5. How to register an EPC exemption (step by step)
The exact online process may evolve, but typically involves:
- Visiting the PRS Exemptions Register for England and Wales.
- Creating or logging into your account.
- Providing property details, including address and EPC details.
- Selecting the relevant exemption category (e.g. consent, cost cap).
- Uploading supporting documents and evidence.
- Confirming declarations and submitting the application.
You should keep:
- A secure copy of all evidence and correspondence.
- Notes of when the exemption was registered and when it will expire.
6. How long do EPC exemptions last?
Most exemptions last for a fixed period – often 5 years from the date of registration – after which you will need to:
- Re-assess the property and market conditions.
- Consider whether new technologies, grants or building works now make improvements viable.
- Re-register an exemption if still genuinely necessary and permitted.
If circumstances change before the expiry date – for example, consent is granted or prices for an improvement fall significantly – you may need to review or withdraw the exemption and carry out the relevant works instead.
7. Common mistakes landlords make with EPC exemptions
Some pitfalls to avoid:
- Assuming a listed property is automatically exempt – in reality, many improvements are still possible and expected.
- Relying on verbal advice without obtaining proper written evidence.
- Failing to register an exemption formally, then letting below the minimum standard.
- Forgetting to track expiry dates, leaving tenancies exposed as circumstances change.
Treat exemptions as a regulated process, not a quick note to file away.
8. Exemptions vs improvements: choosing the right path
In many cases, carrying out sensible improvements is better than relying on exemptions:
- You reduce regulatory risk and future uncertainty.
- Tenants get a warmer, cheaper-to-run home, which can support rent levels and lower voids.
- The property may become easier to sell or remortgage.
Use exemptions when:
- Physical, legal or financial constraints genuinely make improvements unreasonable.
- You’ve explored grants and support in Home Energy Grants UK 2025 and Boiler Grants UK 2025 (when available).
Otherwise, consider following our improvement guides for rentals:
- How to Improve EPC from E to D
- How to Improve EPC from D to C
- How to Improve EPC on a Victorian House
9. How exemptions interact with fines and enforcement
Having a properly registered exemption can protect you from penalties for renting a sub‑standard property – but only:
- For the specific property and circumstances covered.
- For as long as the exemption remains valid.
If you don’t register, or if your exemption no longer applies, you could still face:
- Civil penalties from local authorities.
- Publication of your details as a non‑compliant landlord.
For a detailed look at penalties and enforcement, see Landlord EPC Fines: Penalties for Non‑Compliance (2025 Update).
10. FAQs
Are listed buildings automatically exempt from EPC rules?
No. While some listed buildings may qualify for exemptions where required works would unacceptably alter the character or appearance, others can and should still be improved. You’ll usually need evidence (including planning/listed building advice) to support an exemption.
Can I keep renewing exemptions forever?
Not necessarily. Exemptions are time-limited and depend on conditions at the time. If technology, grant availability, planning policy or your own circumstances change, you may be expected to carry out improvements rather than renew exemptions indefinitely.
What happens if I sell a property with an exemption?
Exemptions are generally tied to the person or organisation that registered them. If you sell, the new owner cannot rely on your exemption automatically – they must either re-register one (with supporting evidence) or improve the property.
Should I use an exemption or just upgrade?
If improvements are physically and financially reasonable – especially fabric measures like loft and cavity wall insulation – upgrading is usually the safer long-term option. Use exemptions for genuinely hard-to-treat or constrained scenarios, not as a first line of defence.
What should I do next?
- Check your properties using our EPC checker to identify any below or close to the minimum.
- Read EPC Rules for Landlords in 2025–2030 to understand your overall obligations.
- Decide, property by property, whether to improve or seek an exemption, documenting every step.
Handled properly, exemptions are a useful safety valve – but they work best alongside a proactive plan to improve the underlying energy performance of your rental portfolio.