EPC Exemptions for Landlords: Every Exemption Explained (2026 Guide)

EPC exemptions allow landlords to legally let a property that falls below the minimum energy efficiency standard, provided the exemption is registered on the government's PRS Exemptions Register. There are currently six exemption types for the EPC E minimum, and the 2030 EPC C rules will introduce updated versions with a higher cost cap and longer duration. You cannot claim an exemption verbally or in writing to a tenant. It must be formally registered, or you are in breach of the MEES Regulations (SI 2015/962) and exposed to fines of up to £30,000 per property.

EPCGuide's analysis of 29.2 million EPC records shows that 55.3% of all assessed properties in England are rated below band C. A significant proportion of those properties will not be able to reach C through improvements alone, meaning exemptions will be the only legal route to continued letting for many landlords after 1 October 2030.

What is an EPC exemption?

An EPC exemption is a formal registration on the PRS Exemptions Register that permits a landlord to continue renting a property below the minimum EPC rating when specific qualifying conditions are met. The legal basis is the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015.

A registered exemption is not optional. It is the only legal defence for letting below the minimum standard. A landlord who has a genuine reason for non-compliance but fails to register it is treated identically to a landlord who has no reason at all.

What are the current MEES exemptions? (EPC E minimum)

The current minimum standard is EPC band E. These six exemptions apply to landlords whose properties cannot reach that rating. All are registered on the PRS Exemptions Register at prsregister.beis.gov.uk.

1. All improvements made exemption

A landlord who has installed every recommended energy efficiency improvement on their EPC report, up to the £3,500 cost cap (including VAT), and the property still does not reach band E, can register this exemption. It also applies where no recommended improvements exist at all.

Evidence required: Valid EPC, contractor invoices, installation certificates for completed works.

Duration: 5 years.

2. High cost exemption (cost cap)

A cost cap exemption applies when no single recommended improvement can be installed for less than the current £3,500 cap.

Critical distinction: If any recommended improvement costs less than £3,500, it must be installed first. If the property still does not reach band E after that work, the correct exemption is "all improvements made," not "high cost." This is one of the most common registration errors. See our guide on which improvements count toward the cost cap.

Evidence required: Three written quotes from different qualified installers, each confirming the cheapest recommended improvement exceeds the cap. Plus a valid EPC.

Duration: 5 years. On expiry, the landlord must re-attempt. If costs still exceed the cap, a new exemption can be registered.

3. Third-party consent refused

This exemption applies where the required improvements legally need consent from a third party, that consent was formally requested, and it was refused or granted only on conditions the landlord cannot reasonably meet. Third parties who commonly need to give consent include:

• Freeholder or superior landlord for leasehold flats requiring external wall insulation, heat pumps, or solar panels
• Local planning authority for listed buildings or properties in conservation areas
• Mortgage lender where the lease requires lender consent for structural modifications
• Current tenant where works require access and agreement during a tenancy

This exemption is most relevant to leasehold flat landlords and those with listed buildings.

Evidence required: Correspondence showing consent was required and evidence of refusal (written refusal letter, planning decision notice, or equivalent). Plus a valid EPC.

Duration: 5 years, unless the refusing party is the current tenant. If the tenant refused, the exemption expires when that tenant leaves. There is no grace period. You must carry out the improvement before the next tenancy begins. This is the most misunderstood rule in the entire exemption system.

4. Property devaluation exemption

A devaluation exemption applies where an independent surveyor confirms that the recommended improvements would reduce the property's market value by more than 5%. This typically applies where external cladding on a period property or structural modifications to a listed building would materially reduce what the property is worth.

Evidence required: Report from an independent RICS-registered surveyor specifically quantifying that the recommended improvement(s) would devalue the property by more than 5%. The surveyor must be genuinely independent, not an adviser working on the same renovation project. A general concern about value impact does not qualify; the 5% threshold must be stated explicitly.

Duration: 5 years.

5. Wall insulation exemption

This exemption applies where cavity wall, external wall, or internal wall insulation is recommended on the EPC, but a qualified expert confirms the installation would damage the fabric or structure of the property. It is most relevant for solid-walled period properties where external cladding or internal insulation would cause moisture or structural problems.

Evidence required: Written expert opinion from a professional on one of these specific accreditation registers: AABC, RICS Building Conservation Accreditation, ICE/IStructE CARE, or CIAT Directory of Accredited Conservationists. A general structural engineer's report does not qualify. The regulations name these specific registers, and if your expert is not on one of them, their report cannot support this exemption.

Duration: 5 years.

6. New landlord temporary exemption

A temporary exemption available where a landlord acquires a property unexpectedly (through inheritance, for example) and needs time to bring it into compliance. This gives a short window to arrange assessments and improvements before standard compliance obligations apply.

Duration: 6 months. This is a bridge, not a permanent solution.

What exemptions will apply under the 2030 EPC C rules?

From 1 October 2030, the minimum EPC standard rises to band C for all privately rented properties in England and Wales, both new and existing tenancies. The exemption framework is being updated to match the higher standard. The government confirmed the key changes in its January 2026 partial response to the EPB Regulations consultation.

The core exemption categories carry forward, but with significant changes to the cost cap, duration, and heritage provisions.

How does the £10,000 cost cap work?

The cost cap rises from £3,500 to £10,000 per property (including VAT). For properties valued below £100,000, an alternative cap of 10% of the property's market value applies instead.

Qualifying spending has counted from 1 October 2025. Every pound you spend on recommended EPC improvements from that date forward accumulates toward the cap, including the cost of the EPC assessment itself.

If a landlord spends £10,000 on all recommended improvements and the property still cannot reach band C, they can register a cost cap exemption and continue letting legally. The landlord must provide invoices and receipts for all qualifying works, plus a valid post-improvement EPC showing the property's current rating.

The cost cap does not excuse you from making improvements. You must carry out every recommended measure up to the cap. For a full breakdown of which improvements count, see our guide on the £10,000 cost cap.

How does the third-party consent exemption change?

The third-party consent exemption continues under the 2030 rules. But the practical impact has shifted since Section 21 abolition. Previously, if a tenant refused EPC works, you could serve notice, complete the works, and re-let. That exit route no longer exists. A tenant consent exemption now becomes a potentially indefinite deferral. See our guide on how the Renters' Rights Act affects EPC exemptions.

What about devaluation and negative impacts exemptions?

The devaluation exemption (improvements would reduce market value by more than 5%) carries forward to the 2030 framework with the same evidence requirements.

The 2030 framework also introduces a clearer "negative impacts" exemption for improvements that would damage the building fabric, structure, or historic character. This consolidates the existing wall insulation exemption into a broader category, distinct from devaluation (financial) because it covers physical harm.

How long do 2030 exemptions last?

This is one of the biggest changes. Under the current MEES rules, all exemptions last 5 years. Under the 2030 framework, the exemption duration extends to 10 years for newly registered exemptions. After 10 years, the landlord must reassess the property and either demonstrate compliance or register a new exemption based on current circumstances.

The longer duration reduces the administrative burden, but improvements that were unaffordable at registration may become viable within a decade.

Summary: current vs 2030 exemptions

What is happening to the heritage property exemption?

The government's January 2026 consultation response confirmed that the heritage exemption for listed buildings is being removed. Under the current regime, Regulation 5(1)(a) of the Energy Performance of Buildings Regulations allows listed buildings and officially protected heritage properties to avoid the EPC requirement entirely, provided compliance would "unacceptably alter their character or appearance."

In practice, this grey area was wide enough that many listed building landlords never obtained an EPC at all. The reform closes that gap. Listed buildings will be treated like any other rental property for EPC purposes.

This does not mean listed buildings have no protection. The third-party consent exemption still applies where listed building consent is refused, and the negative impacts exemption covers works that would damage historic fabric. But the blanket "I'm listed, I don't need an EPC" position is finished.

For full details, see our listed building EPC heritage exemption guide.

How do exemptions work for HMOs?

Houses in Multiple Occupation (HMOs) follow the same exemption framework as standard rental properties, but with additional complexity.

The January 2026 consultation response confirmed that HMOs require a whole-building EPC, not individual per-room assessments. This means the exemption applies to the entire property, not to individual rooms. If the whole-building EPC is below the minimum standard and you cannot reach it through improvements, you register one exemption for the property.

The practical challenge for HMOs is that whole-building upgrades tend to be more expensive than single-let properties, making the £10,000 cost cap more likely to be reached. If your HMO requires freeholder consent for building-level works (external wall insulation in a converted property, for example), the third-party consent exemption applies. But if the HMO is freehold and you own the building, you cannot claim third-party consent unless the issue is tenant consent or planning authority refusal.

A 24-month transitional period applies for HMOs newly brought into scope of the whole-building EPC requirement. See our full HMO EPC compliance guide for the complete picture.

How do you register an EPC exemption?

Registration is free, instant, and self-certified on the PRS Exemptions Register. But enforcement authorities can challenge a registration retroactively if the evidence is inadequate. Have all documents ready before you start, because the portal does not save progress mid-application.

Step 1: Gather your documents

Before opening the portal, prepare:

• Valid EPC for the property (you need this for every exemption type)
• Full property address
• Exemption-specific evidence: installer quotes (cost cap), contractor invoices (all improvements made), refusal correspondence (third-party consent), RICS surveyor report (devaluation), or accredited expert opinion (wall insulation/negative impacts)

Step 2: Go to the PRS Exemptions Register

Visit prsregister.beis.gov.uk and create an account or log in.

Step 3: Enter the property address

The portal links your registration to existing EPC records for the property.

Step 4: Select the correct exemption type

Choose the exemption that matches your situation precisely. Do not select the nearest match. Selecting "high cost" when "all improvements made" is correct (because cheaper improvements exist but have not been installed) is the most common error and will fail enforcement scrutiny.

Step 5: Upload evidence

Upload all supporting documents as PDFs. Everything must be uploaded in this session.

Step 6: Self-certify and submit

Confirm the information is accurate and submit. The exemption is registered immediately with no waiting period. It appears on the publicly accessible register from the moment of submission.

For a more detailed walkthrough of each step, see our dedicated PRS Exemptions Register guide.

What happens when an EPC exemption expires?

When an exemption reaches its expiry date, it simply ends. There is no automatic renewal and the PRS portal sends no reminders.

Immediate consequence: A landlord whose exemption expires is in breach of MEES from the expiry date, carrying potential penalties of up to £30,000 per property under the 2030 rules.

What you must do before expiry:

1. Commission a new EPC assessment. Improvements that were unaffordable five years ago may now be viable.
2. Reassess qualifying improvements. New products, lower costs, or changed circumstances could mean your property can now reach the minimum standard.
3. If the situation is unchanged, register a new exemption with updated evidence. There is no limit on consecutive exemptions, provided each is supported by current, valid evidence.
4. Set a calendar reminder. The portal sends no reminders.

Key rule: exemptions do not transfer on sale. If a property with a registered exemption is sold, the exemption ceases on completion. The new owner must either bring the property to standard or register their own exemption with fresh evidence.

What percentage of rental properties could qualify for an exemption?

EPCGuide's analysis of 29.2 million EPC records shows that certain property types will disproportionately rely on exemptions:

• Solid-walled properties (pre-1930, no cavity for insulation) frequently require wall insulation costing £5,000 to £20,000+. For many, reaching EPC C within the £10,000 cap is not achievable.
• Victorian and Edwardian terraces face compounding challenges: solid walls, single-glazed sash windows (often in conservation areas), and limited loft access.
• Leasehold flats where the freeholder controls the building fabric. Landlords of individual flats cannot unilaterally install external wall insulation or modify shared areas. The third-party consent exemption will be heavily used here.

EPCGuide estimates roughly 15 to 20% of private rented properties currently below band C will be unable to reach C within the £10,000 cost cap. These landlords will need exemptions to continue letting legally after October 2030. The exact figure will depend on installation costs and uptake of grant funding through ECO4 and the Boiler Upgrade Scheme.

What are the most common mistakes landlords make with EPC exemptions?

1. Not registering at all

The single most common and most costly mistake. "My freeholder won't allow it" or "it would cost too much" is not a legal defence. Only a formal registration on the PRS Exemptions Register protects you. An unregistered exemption is no exemption.

2. Selecting the wrong exemption type

Using "high cost" when "all improvements made" applies, because cheaper improvements exist but have not been installed. The threshold tests are different. Enforcement authorities audit exemption types against uploaded evidence.

3. Treating a tenant consent exemption as a 5-year protection

If the third-party consent exemption was registered because the tenant refused works, it expires when that tenant leaves, not after 5 years. Re-letting without completing the improvements is an immediate breach. With Section 21 now abolished, this trap is more consequential than ever.

4. Letting the exemption expire without tracking the date

No reminders are sent. Under periodic tenancy (now the default), there are no natural renewal points. Set your own reminder.

5. Using a non-accredited expert for the wall insulation exemption

The regulations name specific accreditation registers: AABC, RICS Conservation, CARE, CIAT. A general structural engineer's report does not qualify. Verify accreditation before commissioning the report.

6. Getting quotes from non-independent installers

The high cost exemption requires three quotes from different, qualified installers. Quotes from the same company under different names can be challenged.

7. Assuming the exemption transfers to a new buyer

It does not. The new owner starts from scratch.

8. Registering a false or misleading exemption

Under the 2030 rules, providing false information on the register carries a fine of up to £30,000. Local authorities are expected to increase scrutiny of registrations as the deadline approaches.

Frequently Asked Questions

Can I claim an EPC exemption without spending any money on improvements?

Only in limited circumstances. The high cost exemption applies if every recommended improvement exceeds the cost cap, meaning no affordable improvement exists. The third-party consent exemption applies if a third party refuses permission for the works. But in most cases, you must install all affordable recommended improvements first. If the property still does not reach the minimum standard after that, the "all improvements made" exemption covers you.

How much does it cost to register an EPC exemption?

Nothing. Registration on the PRS Exemptions Register is completely free. There is no fee for submitting an exemption or for registering multiple properties. The costs involved are for obtaining the evidence: EPC assessments (typically £60 to £120), installer quotes, and professional reports if needed.

Can my letting agent register an exemption on my behalf?

Yes. Letting agents can use the PRS Exemptions Register portal to register on a landlord's behalf. The registration must record the landlord as the property owner. The landlord remains legally responsible for ensuring the exemption type is correct and the evidence is valid.

Do EPC exemptions apply in Scotland and Northern Ireland?

No. The MEES Regulations and PRS Exemptions Register apply to England and Wales only. Scotland has its own energy efficiency framework with different requirements and exemption rules. Northern Ireland operates separately. See our guides for Scottish landlords and Northern Ireland landlords.

What if my property is in a conservation area?

Conservation area status does not provide an EPC exemption. The heritage exemption under Regulation 5(1)(a) applied only to individually listed buildings, not to properties merely located within a conservation area. If your property is in a conservation area but not itself listed, standard EPC rules have always applied. However, if the conservation area restricts the improvements you can make (external wall insulation, window replacement), the third-party consent exemption may apply if planning consent is refused.

Can I register the same exemption twice in a row?

Yes. There is no limit on consecutive exemptions. If your property still cannot reach the minimum standard when your current exemption expires, you can register a new one immediately, provided you have fresh, current evidence. The five-year (or ten-year, under 2030 rules) clock resets with each new registration.

What happens if a council challenges my exemption?

Local authorities have the power to review and challenge exemption registrations. If a council determines that your exemption was registered incorrectly (wrong type, inadequate evidence, or false information), it can revoke the registration and issue a compliance notice. Failure to comply with the notice, or the underlying false registration, can result in financial penalties. Wandsworth Council's 2026 enforcement action against over 550 non-compliant properties shows that councils are already conducting proactive audits.

Not sure whether your property qualifies for an exemption? Use the EPCGuide exemption checker to assess your situation, or check your current rating with the EPC predictor. For the full picture on the 2030 deadline, costs, and what to do now, see our complete guide to the EPC C deadline and our guide on the cost of improving your EPC rating.

This article was last updated on 13 May 2026. EPCGuide's data analysis covers the full domestic EPC register for England and Wales (29.2 million records). For methodology and interactive data, visit the EPCGuide Research Hub.