The Minimum Energy Efficiency Standard (MEES) regulations mean that privately rented properties must achieve an Energy Performance Certificate (EPC) rating of E at the minimum. 

If you are the owner and/or landlord of a non-compliant rental property in breach of the Energy Performance of Buildings (England and Wales) Regulations you can be liable to a financial penalty of up to £5,000 per breach and/or per property.


Listed buildings or buildings within a conservation area are only exempt from the requirement to have an EPC where compliance with the minimum requirements would unacceptably alter their character or appearance. 

This is not a blanket exemption and many buildings can have energy efficiency measures installed which will not adversely affect the character or appearance of the building.

If your property qualifies as exempt you must register an exemption if it is currently rented out.

To register an exemption you may need to prove or show evidence that all the recommended measures would unacceptably alter the character or appearance of the building. You would need to demonstrate to us that advised energy efficiency measures are unsuitable for your type of property.

Background on historic buildings and energy efficiency

Historic buildings were designed to absorb moisture and release it gradually via breathable materials. In contrast modern buildings are generally designed to be impervious. 

Historic buildings were heated by open fires and needed to have good natural ventilation. Modern buildings generally need draughts to be eliminated for their heating systems to be effective.

Potential risks with energy efficiency improvements

Many historic buildings have had works done to improve energy efficiency (most often this has meant having double glazed windows fitted). 

Whilst these changes can result in lower energy bills, the use impervious materials can effectively create a ‘hermetically sealed box’ which can be problematic for the building over a period of time. Interstitial condensation can build up behind dry-lined walls. This can cause mould growth and lack of ventilation can harm timber which can sweat and lead to dry-rot.

These problems can have a detrimental effect on a listed building which may have statutory protection because of its architectural and historic interest. Any positive benefits of energy saving measures on a listed building will need to be considered against the harm to the building. 

This includes any harm that:

  • is visual 
  • involves a loss of fabric
  • causes the structure to be jeopardised in some way

You would need to get the most intrusive measures assessed by requesting advice relating to listed building consent (submit a pre-application enquiry). We many refuse consent if we think that a proposed measure would cause harm to the buildings special interest.

Choosing alterations to improve energy efficiency 

As an owner or landlord you must take all necessary steps to improve the EPC rating to as close as owners possible to an E rating. This may be via third party funding or a personal contribution, currently capped at £3500.

Examples of alterations that may be unacceptable in the majority of listed properties include:

  • Double glazing
  • New doors and windows
  • External wall insulation
  • External boiler flues

Measures to consider

Most of the following measures would not require listed building consent, unless they involved the disturbance of historic fabric and collectively might help achieve an acceptable EPC rating. 

Providing insulation in the roof void

  • Take care not to block ventilation for the roof timbers

Draught-proofing windows and doors

  • Make sure they remain operable for ventilation in summer

Secondary glazing

  • This could be added where it will not damage historic internal features such as shutters or fine plasterwork


  • If there a single system serving the whole building consider whether individual systems would be more efficient
  • If it is a gas system consider whether it would be easy to convert to electricity 
  • Consider whether you could provide/replace a wet radiator system with electric heating or storage heaters 
  • Consider whether existing open fires can be used

Hot water 

  • If there is a storage tank consider whether it would be more energy efficient to have direct heated water instead
  • Consider whether the water system could be controlled more efficiently


  • Use low energy bulbs
  • Make sure the light fittings are in the best positions to light the room 

However if all of these measures together would not meet the minimum requirements then a building may be able to qualify for exemption. 


Our Conservation Officer can provide guidance on what work will be permitted and the relevant listed building consent. If you have any questions, you can submit a pre-application enquiry.

We advise that you submit a pre-application enquiry before any works begin.

Our Conservation Officer may get in contact to discuss your enquiry further.