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