EPC for Listed Buildings London — Grade I, II & II* Guidance

Yes, if the building is sold or let. The EPB Regulations 2012 do not exempt listed buildings from the EPC requirement itself. The exemption that does exist is from MEES — the minimum band floor — not from the EPC requirement. Letting a listed building without any EPC is a £200–£5,000 breach of the EPB Regulations.

Yes, where the improvements needed to reach the band floor would unacceptably alter character or appearance. The exemption is registered on the PRS Exemptions Register and is time-limited (5 years). The test is property-specific: it is not granted because the building is listed, it is granted because the specific improvements needed for this specific listing would unacceptably alter character. The assessor's reasoned statement is the evidence base.

Heritage England guidance considers: visible external changes (replacing sash windows with double-glazed UPVC, external wall insulation that obscures stucco or brickwork), removal of original internal fabric (lath-and-plaster, panelling, cornices) to install internal wall insulation, replacement of original cast-iron radiators with modern panel radiators where the originals contribute to character, and any change that would require listed-building consent and is reasonably likely to be refused.

A reasoned statement from a qualified assessor identifying each candidate improvement, why it cannot be installed without unacceptable character alteration, and (where relevant) confirmation that listed-building consent has been sought and refused or that the case is reasonably likely to be refused. The pack uploads to the PRS Exemptions Register and the exemption runs for 5 years before requiring re-application.

Secondary glazing is almost always allowed because it is reversible and internal — the original sash or casement remains visible from outside. It typically does not need listed-building consent, though some Grade I and II* properties do require it. Secondary glazing gives 1–3 SAP point gain and is one of the best £-per-point interventions for Georgian and Victorian listed stock. We always recommend trying secondary before claiming a glazing exemption.

Internal wall insulation (IWI) is the high-value MEES intervention for solid-wall stock — but in listed buildings it almost always requires listed-building consent because it alters internal fabric (skim removal, batten attachment, possible cornice and skirting reinstatement). Conservation officers are often resistant. The realistic case is borough-specific: Camden and Westminster tend to refuse IWI on listed terraces; outer-London boroughs are more pragmatic. We assess case-by-case.

Yes — through the accreditation scheme (Elmhurst, Stroma, Quidos). Listed buildings frequently get under-rated because the assessor applied default U-values for solid walls or original sash windows where evidence of upgraded thermal performance exists (secondary glazing, lime-render insulation, thatch reinstatement). We can review a third-party EPC and manage the appeal where there is a genuine evidence-based discrepancy.

Five years from the date of registration on the PRS Exemptions Register. After 5 years the property must be re-assessed and the exemption re-applied. If circumstances change — for example new sympathetic insulation products become available that conservation officers will approve — the exemption may no longer stand on re-application. We diary the 5-year cycle alongside the EPC 10-year expiry.