EPC Exemptions UK 2026 — Complete Landlord Guide to the PRS Exemptions Register

Why exemptions exist — the MEES cost cap and practical limits

MEES Regulations 2015 impose a spending cap on landlords' obligations to improve energy efficiency. Above that cap, or where specific barriers exist, exemptions are available:

• The £3,500 cost cap (England): English MEES regulations impose a maximum spending obligation on landlords of £3,500 per property (inclusive of VAT) to carry out energy efficiency improvements. If the cheapest combination of recommended measures that would bring the property to EPC E exceeds £3,500, the landlord is not required to spend more than £3,500. A landlord who has spent £3,500 on improvements but the property remains below EPC E can register a 'high cost' exemption. The £3,500 cap applies to the combined cost of all measures — a single measure costing £3,500 is the limit; multiple cheaper measures must be combined until the cap is reached. The cap may be increased in future consultation if MEES is extended to require EPC C
• Wales — MEES cost cap and differences: Wales operates its own MEES regime with some differences from England. Welsh landlords should check the current Welsh MEES position and the applicable cost cap — the regime has developed separately following devolution of housing matters. The Renting Homes (Wales) Act 2016 also imposes a property fitness standard (the 'adequate' standard) which interacts with energy efficiency requirements. Welsh landlords with sub-standard EPC-rated properties should seek specific Welsh guidance
• Situations where improvement is not possible: Beyond the cost cap, there are situations where specific barriers prevent improvement: the property's structure may be unsuitable (traditional stone walls where external insulation would be planning-prohibited; no loft space for insulation; solid floor preventing underfloor insulation); consent may be required from a third party who refuses; a RICS surveyor may have determined that the improvement would devalue the property. The exemption framework accommodates each of these barriers
• Temporary exemptions — new landlord and recently let: New landlords who have recently acquired a property through a distressed sale (probate; repossession; court order) receive a 6-month transitional exemption — time to assess and improve the property before the MEES standard fully applies. This reflects the reality that a new landlord may not have had time to carry out improvement works before the tenancy was inherited or re-let. The 6-month period runs from the date the landlord became the landlord of the property

The five exemption types — criteria and evidence required

Each exemption type has specific criteria that must be met and evidence that must be submitted to the PRS Exemptions Register:

• All improvements made: The landlord has carried out all relevant energy efficiency improvements that can be made within the cost cap, and the property still cannot achieve EPC E (or the minimum standard). Evidence required: a valid EPC showing the property's current rating; evidence that all recommended improvements have been carried out (receipts; invoices; contractor confirmation); a statement from the landlord confirming all improvements have been made and the property still cannot reach EPC E. This is the most common long-term exemption for landlords of inherently inefficient properties (pre-1919 solid-wall construction; traditional rural cottages; listed buildings where improvement options are severely limited). Duration: 5 years from registration
• High cost: The cheapest measure (or combination of measures) that would bring the property to EPC E would cost more than the £3,500 cap. Evidence required: a valid EPC showing the property's current rating; at least 3 quotes from qualified contractors (or a report from a qualified assessor) confirming the cost of the cheapest recommended measure(s) exceeds £3,500. If the landlord has spent some money on improvements but the remaining measures exceed the balance of the cap, only the unspent portion of the cap is relevant — the landlord cannot claim a high-cost exemption until they have spent £3,500 on relevant measures. Duration: 5 years from registration
• Third party consent: The landlord has been unable to obtain necessary consent from a third party whose permission is required for the improvement works. This arises where: (a) the mortgage lender has refused consent for structural works (for example, external wall insulation that affects the surveyor's valuation); (b) the freeholder has refused consent for works to leasehold property (installation of external insulation; solar panels; new heating system); (c) the local planning authority has refused planning permission or listed building consent for the proposed works; (d) the tenant has refused to allow access for the works during the tenancy. Evidence required: written evidence of the refusal from the relevant party (the lender's letter; freeholder's refusal; planning decision notice; tenant's refusal in writing). Duration: 5 years from registration (unless consent is subsequently obtained — the exemption must then be deregistered and works carried out)
• Devaluation: A RICS-qualified surveyor has confirmed in writing that carrying out the recommended improvement measures would devalue the property by more than 5%. This exemption is intended for situations where the specific character or location of the property means that certain improvements (external cladding on a period terrace in a conservation area; solar panels on a prominent roof visible from the street) would materially reduce the sale or rental value. Evidence required: a report from a RICS-qualified surveyor (member of the Royal Institution of Chartered Surveyors) confirming the specific improvements would reduce the market value by more than 5%. The surveyor must specify the measures assessed and the estimated valuation impact. Generic assertions are not sufficient — the report must be property-specific and measure-specific. Duration: 5 years from registration

Registering an exemption — the PRS Exemptions Register process

Registration must be completed on gov.uk before the property is let (or before a new tenancy starts on a property already let without a valid exemption):

• Registration portal — gov.uk: Exemptions are registered at gov.uk by searching for 'register an exemption private rented sector' and completing the online form. The landlord provides: property address; EPC reference number (from the national EPC register); the type of exemption being claimed; the landlord's contact details; and the required supporting evidence (uploaded as documents). The registration creates a record on the publicly searchable PRS Exemptions Register — anyone can search by address to check whether a property has a valid exemption
• Timing — register before letting sub-standard property: The exemption must be registered before the sub-standard property is let (or before a new tenancy begins on a property where the minimum standard is not met). A landlord who lets a sub-standard property without having registered an exemption is in breach of the MEES Regulations from the date the tenancy commences — not from the date the local authority discovers the breach. Register first; let second. Where a landlord is already letting a sub-standard property without a registered exemption, they should register immediately (if they have grounds) to limit the period of unlawful letting
• Exemption duration — 5 years or 6 months: All improvement-based exemptions (all improvements made; high cost; consent; devaluation) last 5 years from the date of registration. The new-landlord exemption lasts 6 months from the date the landlord became the landlord. At the end of the exemption period, the landlord must either: (a) carry out further improvements (or obtain consent from the third party) and re-assess whether the property can now meet the standard; (b) register a new exemption if the circumstances have not changed; or (c) bring the property up to the minimum standard. An exemption that expires without renewal leaves the property unlawfully let from the expiry date
• Exemption not transferable to new landlord: If a property is sold or the landlord changes, the existing exemption does not transfer to the new landlord. The new landlord has a 3-month period to register their own exemption if the property cannot meet the standard — or to carry out improvements to meet it. A landlord who purchases a property with an existing registered exemption should factor in the time and cost of either registering a new exemption or improving the property to EPC E (or the applicable minimum standard) within 3 months of acquisition. Failure to do so within 3 months exposes the new landlord to the same enforcement penalties as any other MEES breach

MEES enforcement and proposed EPC C — planning ahead

Local authorities enforce MEES compliance; the proposed EPC C minimum standard changes the landscape for exemptions:

• Local authority enforcement — compliance notice and penalties: Local housing authorities (district councils; London boroughs; unitary authorities) enforce MEES compliance. An authority that suspects a property is being let below the minimum standard without a valid exemption can serve a compliance notice requiring the landlord to provide evidence of compliance. If the landlord cannot demonstrate compliance (either a valid EPC at or above the minimum, or a valid exemption registration), the authority can impose a penalty of up to £5,000 for a breach of less than 3 months; up to £5,000 for a breach of 3 months or more (there are two separate penalty bands). The penalty is a civil penalty, not a criminal sanction. In addition, the breach is published on a public register — reputational damage alongside the financial penalty
• Penalty regime — per property, per breach: Penalties apply per property, per breach. A landlord with 10 properties all letting below EPC E without valid exemptions faces up to £50,000 in penalties (10 × £5,000). The MEES Regulations provide for both financial penalties and publication of the breach on a public register maintained by Trading Standards. The public register is searchable — letting agents, prospective tenants, and buyers can check whether a property has been subject to MEES enforcement. Publication can affect lettability and sale price
• Proposed EPC C minimum — implications for current exemptions: The Government has proposed raising the MEES minimum to EPC C — with new tenancies required to achieve EPC C from 2028 and all tenancies (including existing ones) by 2030 (subject to consultation and legislation). Current exemptions registered under the EPC E regime will not automatically satisfy the new EPC C minimum if and when it comes into force. Landlords who have registered a 'high cost' exemption at £3,500 (sufficient for EPC E compliance) may need to carry out additional improvements and register a new exemption under the EPC C regime if the property cannot achieve EPC C within a higher spending cap. The cost cap for EPC C is expected to be higher than £3,500 — Government proposals have suggested up to £15,000
• Practical planning for landlords with sub-standard properties: Landlords should: (1) obtain a current EPC for every property (EPCs are valid for 10 years but should be refreshed after improvement works); (2) identify which properties are below EPC E and ensure a valid exemption is registered; (3) budget for improvement works as exemptions expire — stagger improvements across a portfolio to manage cash flow; (4) note that many improvement works qualify for funding through the ECO4 Scheme (government-funded energy efficiency grants for privately rented properties); (5) plan for EPC C transition — a property that cannot reach EPC C and has no viable exemption path may need to be sold rather than let after the proposed 2028/2030 deadline

Frequently asked questions