Phil's Real-World EPC Audits — Shropshire

Why Your Listed Shropshire Cottage

Might Be EPC-Exempt

A listed building with a low EPC rating is not automatically exempt from the minimum energy efficiency standards. The exemption is real, but it has to be applied for correctly — and doing it wrong can leave a rental property unlettable. Here's what the exemption actually covers, when it applies, and how to register it.

Phil · UK EPC Assessor·Updated September 2026

The basics

What the EPC Exemption Actually Means

The Minimum Energy Efficiency Standards (MEES) require rental properties in England and Wales to have an EPC rating of at least E before they can be let. From 2030, the proposed minimum rises to C. A landlord who lets a property below the minimum without a registered exemption faces civil penalties of up to £30,000.

The exemption that applies to listed buildings and some solid-wall properties is the 'all improvements made' exemption — specifically the variant that covers situations where the recommended improvements would unacceptably alter the character or appearance of the property. This is not automatic. It requires evidence, and it must be registered on the PRS Exemptions Register.

Listed building status does not, by itself, grant an EPC exemption. The question is whether the specific improvements needed to raise the EPC rating to the minimum standard would require listed building consent and would be refused — or would unacceptably alter the character of the building. A listed building that can be improved without affecting its character is not exempt.

When the exemption applies

The Conditions That Must Be Met

The exemption applies when: (1) the property is listed, or in a conservation area, or subject to other planning restrictions; (2) the improvements recommended by the EPC assessor would require consent under those restrictions; and (3) that consent has been applied for and refused, or the landlord has evidence that the improvements would unacceptably alter the character of the property.

For a solid-wall property that is not listed, the exemption can still apply if the recommended improvement is solid wall insulation and the landlord has obtained a written opinion from a relevant expert (such as an EPC assessor or a suitably qualified surveyor) that the improvement is not technically feasible or would cause structural damage.

The exemption lasts for five years. After five years, it must be reviewed — if the situation has changed (for example, if consent is now available or the property has been sold), the exemption may no longer apply.

Landlord Questions Answered

The process

How to Register the Exemption Correctly

1

Get a current EPC

The EPC must be valid (within 10 years) and must have been produced by an accredited assessor. It will list the recommended improvements and their estimated impact on the rating. This is the document that establishes what improvements are needed.

2

Obtain the required evidence

For a listed building, obtain written confirmation from your local planning authority or conservation officer that the recommended improvements would require listed building consent and would be refused or would unacceptably alter the character of the building. For a solid-wall property, obtain a written technical assessment from a suitably qualified person.

3

Register on the PRS Exemptions Register

Go to the government's PRS Exemptions Register (gov.uk) and register the exemption before the tenancy begins. You will need to upload the EPC, the evidence, and details of the property. The registration is free. Keep copies of all documents — you may need them if a penalty notice is issued.

4

Review after five years

The exemption expires after five years. Set a reminder to review the situation before it expires. If the property can now be improved to the minimum standard (for example, if consent is now available), the exemption will not be renewed and the improvement must be made.

Planning insulation work on a non-listed solid-wall property? Read the solid wall insulation guide for Shropshire stone cottages — it covers internal vs external options, typical costs, and ECO4 funding eligibility.

Phil's Assessor Verdict

Register It Properly — or Don't Let the Property

The exemption framework exists for a reason — some older buildings genuinely cannot be improved without damaging their character or structure. But the exemption must be registered correctly, with the right evidence, before the tenancy begins. An unregistered exemption is not a defence. If you're unsure whether your property qualifies, get a current EPC from an accredited assessor and take advice from your local planning authority before committing to a tenancy.

Want to lower your unit rates while you work through the compliance process? Take our 60-Second Bill Audit.

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