Do all listed buildings need a commercial EPC?

No. Listed status alone does not automatically exempt a building from requiring a commercial EPC. Whether an EPC is required depends on:

• How the building is used (commercial or non-domestic use)

• Whether it is being sold or let

• Whether recommended energy improvements would unacceptably alter the building’s character

Each listed building must be assessed on its individual circumstances.

When is a listed building exempt from EPC requirements?

A listed building may be exempt only where:

• It is officially protected, and

• Compliance with minimum energy efficiency requirements would result in unacceptable alterations to its historic or architectural character

If improvements can be made without harming the building, an EPC may still be required.

Can I market a listed commercial building without an EPC?

Only if a valid exemption genuinely applies.
Marketing a listed building for sale or to let without an EPC or a valid exemption can lead to:

• Delays in transactions

• Enforcement action

• Penalties

Professional advice should always be obtained before marketing.

Does MEES apply to listed buildings?

Yes. MEES regulations still apply to listed commercial buildings unless a valid exemption is in place.
Listed status does not remove MEES obligations automatically.

Do EPC recommendations have to be carried out on a listed building?

No. EPC recommendations are advisory, not mandatory.
However, they are used to determine:

• Whether compliance is achievable

• Whether an exemption is justified

• Whether MEES requirements can be met

Any improvements must still comply with planning and conservation rules.

What if planning permission would be refused for EPC improvements?

If required energy efficiency improvements are refused by:

• A planning authority

• A conservation officer

• Listed building consent

This may support an exemption, provided refusal is documented. Evidence is essential.

Do mixed-use listed buildings require an EPC?

Often, yes.
Where part of a listed building is used commercially:

• The commercial element may require an EPC

• Residential areas are assessed separately

• Exemptions may apply to one part but not the other

Careful assessment of use and layout is required.

Can I rely on a previous EPC or old advice for a listed building?

No. EPC rules and MEES requirements have evolved.
Older EPCs or assumptions may no longer be valid, particularly where:

• Use has changed

• The EPC has expired

• MEES enforcement has increased

Updated professional advice is strongly recommended.

Do EPC exemptions for listed buildings need to be registered?

In many cases, yes.
Where an exemption is relied upon for MEES compliance, it must usually be:

• Registered on the PRS Exemptions Register

• Supported by appropriate evidence

Failure to register can invalidate the exemption.

What evidence should I keep for a listed building exemption?

Typical evidence includes:

• Conservation officer guidance

• Planning or listed building consent decisions

• Professional EPC advice explaining why improvements are unacceptable

• Supporting reports or correspondence

This evidence should be retained in case of enforcement review.

What are the risks of assuming a listed building is exempt?

Common risks include:

• Enforcement action by local authorities

• Delays in sales or lettings

• MEES penalties

• Reputational damage

Many enforcement cases arise from incorrect assumptions rather than deliberate non-compliance.

How does Commercial EPC Blackpool support listed building owners?

We provide clear, practical and honest advice tailored to heritage properties.
Our role is to:
✔ Confirm whether an EPC is required
✔ Assess whether a listed building exemption genuinely applies
✔ Provide compliant EPCs where appropriate
✔ Help manage MEES risks
✔ Reduce unnecessary cost and delay

When should I seek professional advice?

You should seek advice if:

• You are selling or letting a listed commercial building

• MEES compliance is uncertain

• The building has mixed use

• You are relying on an exemption

• You want to avoid delays or enforcement risk