Introduction

Listed buildings present unique challenges when it comes to Energy Performance Certificates (EPCs). While many owners assume that listed status automatically removes the need for an EPC, this is not always the case. In reality, EPC requirements for listed buildings depend on how the building is used, what improvements are recommended, and whether those improvements would unacceptably alter the building’s character.

At Commercial EPC Blackpool, we regularly advise landlords, businesses and local authorities on EPC obligations for listed and protected buildings, helping clients remain compliant while respecting heritage constraints.

Do Listed Buildings Require an EPC?

A listed building is not automatically exempt from requiring an EPC.

An EPC may still be required where:

• The building is sold or let

• It is used for commercial purposes

• Energy efficiency improvements can be made without materially affecting the building’s character

An EPC may be exempt where:

• The building is officially protected (listed or within a conservation designation), and

• Compliance with minimum energy performance requirements would unacceptably alter its character or appearance

This exemption is assessed case by case, not by listing status alone.

Understanding the Listed Building EPC Exemption

The listed building exemption applies where recommended EPC improvements would result in unacceptable changes to:

• Historic fabric

• Architectural features

• Materials or finishes

• Appearance or setting

Typical examples might include:

• Replacement of historic windows

• Insulation methods that damage original walls

• Alterations restricted by conservation requirements

If energy efficiency improvements can be made sensitively and without harm, an EPC may still be required.

Commercial Use and Listed Buildings

Listed buildings used for commercial or non-domestic purposes are commonly affected by EPC regulations.

Examples include:

• Listed retail premises

• Offices in historic buildings

• Hotels, pubs and hospitality venues

• Medical practices or professional offices

• Mixed-use listed properties

Where a listed building is used commercially, EPC requirements must be assessed carefully. Commercial use does not remove EPC obligations, even where residential areas within the same building may be treated differently.

Mixed-Use Listed Buildings

For listed buildings with mixed use (e.g. retail at ground floor with residential above):

• The commercial element may require an EPC

• Residential parts are assessed separately

• Exemptions may apply to one part but not the other

Clear identification of use and floor areas is essential to avoid incorrect assumptions.

EPC Recommendations & Heritage Constraints

Commercial EPCs include recommendations for improving energy efficiency. For listed buildings, these recommendations are:

• Advisory, not mandatory

• Subject to planning and conservation constraints

• Used to assess whether compliance is achievable or exempt

Typical low-impact measures that may be acceptable include:

• Improved heating controls

• Efficient lighting upgrades

• Draught management

• Building management improvements

More invasive measures may not be acceptable under conservation rules.

MEES Regulations and Listed Buildings

Under MEES (Minimum Energy Efficiency Standards), most commercial properties must achieve a minimum EPC rating of E to be legally let.

For listed buildings:

• MEES still applies unless a valid exemption exists

• Exemptions must be justified and registered

• Listed status alone is not sufficient

Failing to assess MEES implications properly can expose landlords to enforcement action.

Registering a Listed Building EPC Exemption

If a listed building cannot meet EPC or MEES requirements due to heritage constraints, an exemption may need to be:

• Supported by evidence

• Registered on the PRS Exemptions Register

• Reviewed periodically

Common evidence includes:

• Conservation officer advice

• Planning restrictions

• Professional assessments explaining why improvements are inappropriate

Common Misunderstandings (and Risks)

❌ “All listed buildings are exempt”
❌ “We don’t need an EPC because planning would refuse changes”
❌ “Residential rules apply to commercial listed buildings”

These assumptions can lead to:

• Delays in sales or lettings

• Enforcement notices

• Financial penalties

• Reputational risk

Best Practice for Owners of Listed Commercial Buildings

✔ Obtain professional EPC advice early
✔ Assess whether improvements are genuinely unacceptable
✔ Keep evidence and documentation
✔ Avoid marketing assumptions
✔ Review compliance regularly

How Commercial EPC Blackpool Helps

At Commercial EPC Blackpool, we specialise in non-domestic EPCs, including complex and heritage properties. Our role is to provide clear, balanced advice, not unnecessary assessments.

We:
✔ Assess whether an EPC is required
✔ Identify whether exemptions genuinely apply
✔ Provide compliant EPCs where appropriate
✔ Help manage MEES risks for listed buildings
✔ Work with landlords, agents and public-sector clients

When to Seek Advice

You should seek professional advice if:

• You are selling or letting a listed commercial building

• MEES compliance is uncertain

• Improvements may affect protected features

• The building has mixed use

• You are relying on an exemption

Early guidance can prevent costly mistakes.

If you own, manage or are responsible for a listed commercial property, we can help you understand your obligations clearly and confidently.

Call Commercial EPC Blackpool on 01253 486 919 and speak to a fully accredited non-domestic EPC assessor for expert advice.