Energy Performance Certificate (EPC) Exemption
The Minimum Energy Efficiency Regulations (the Regulations) apply to all privately rented properties in England and Wales which are legally required to have an Energy Performance Certificate (EPC), and which are let on a relevant tenancy type. See the guidance documents for the definition of relevant tenancy.
Updated 02 March 2024 – (correct going to press; terms change frequently).
The Minimum Energy Efficiency Regulations (the Regulations) apply to all privately rented properties in England and Wales which are legally required to have an Energy Performance Certificate (EPC), and which are let on a relevant tenancy type. See the guidance documents for the definition of relevant tenancy.
Overview
The PRI Exemptions Register is intended to capture situations in which a property cannot be brought up to the minimum energy efficiency standard (EPC band E) within the framework of the current regulations, and therefore a formal exemption is required to legally let the property. Exemptions are designed to be precise and time-bound, reflecting the underlying reasons why improvement to the minimum standard is not feasible or not appropriate in a given case. It is important for landlords and their agents to understand that the exemption must be registered before it can be relied upon, and that the registration process is self-certified. This means that the landlord or their agent makes a declaration that the grounds for the exemption apply and that the information provided is accurate to the best of their knowledge at the time of registration. The exemption takes effect from the date of registration, not from any earlier date, and remains in force only for the period specified in the registration, unless renewed or updated in accordance with the regulations.
When considering whether an exemption is appropriate, landlords should carefully assess whether the property is legally required to have an EPC, whether it is let under a tenancy type that falls within the relevant regulatory scope, and whether there are legitimate grounds for not achieving the minimum standard within the statutory timelines. In particular, exemptions may be relevant if there are physical or financial barriers to making improvements, if improvements would not be cost-effective, or if there are other statutory or logistical constraints that prevent compliance within the allowed period. It is also relevant to note that properties which already meet or exceed the minimum standard of EPC E do not require an exemption nor registration on the PRS Exemptions Register.
It is important to recognize that exemptions tied to F or G rated properties are subject to scrutiny and do not automatically guarantee ongoing permission to let. If a property falls outside the regulatory regime, for example because it does not legally require an EPC or is not let under a qualifying tenancy type, there is no obligation to register an exemption. Conversely, for properties already covered by the Regulations that have been improved to EPC E, no exemption should be necessary. This underscores the need for landlords to confirm their particular circumstances against the statutory framework before deciding on a course of action.
A critical consideration for purchasers or transferees is that exemptions registered on the Private Rented Sector Exemptions Register may not pass to a new owner or landlord upon sale or transfer. If a property with an active exemption is sold, the exemption will cease to be effective for the new owner, who must then decide whether to undertake further improvements to meet the minimum standard or to register a fresh exemption if applicable, in order to continue letting the property legally. This transfer limitation requires careful planning during transaction processes and timing of any potential improvements or exemption renewals.
In addition to the general guidance described above, the published summaries of exemptions provide an overview of the available categories and the nature of the supporting evidence required for each. However, it remains essential for landlords to consult the full guidance on the Minimum Energy Efficiency Regulations to gain a comprehensive understanding of all obligations, definitions, and procedural requirements that apply to their specific property and tenancy arrangements. The full guidance typically outlines acceptable forms of evidence, such as cost calculations, improvement plans, or expert assessments, and sets out the documentation that must be retained to substantiate the exemption if challenged by enforcement authorities.
Finally, landlords should be mindful of the ongoing regulatory developments and potential updates to the exemptions framework. Changes in policy or interpretation can alter the scope of exemptions, the registration process, or the evidentiary requirements. Where uncertainties arise, it is prudent to seek professional guidance or to refer to official regulatory updates to ensure continued compliance and to avoid inadvertent breaches that could lead to penalties or restrictions on letting.
Information required for all exemptions
The PRS Exemptions Register is a record for properties within the private rental sector that meet specific criteria related to energy performance. It is intended to identify properties that are legally required to have an Energy Performance Certificate (EPC), are let under a tenancy type that falls within the scope of the regulations, and, for a particular reason, cannot be improved to meet the minimum standard of EPC band E. In such cases, the exemption allows landlords to continue renting the property while pursuing appropriate steps to address the energy efficiency requirements.
Exemptions are typically used only when there is a clearly defined barrier to achieving a minimum EPC rating. These barriers may include scenarios where full compliance would be prohibitively expensive relative to the property’s value or rental income, where essential improvements would require consent from third parties or other stakeholders, or where the improvement work is technically unfeasible due to structural or design limitations. The exemptions are designed to balance the need to improve energy efficiency with considerations of cost, practicality, and legal constraints. Tenants should be informed that the property remains subject to ongoing monitoring and that the exemption is not a permanent solution; rather, it provides a formal acknowledgment that the minimum standard cannot be met at present.
Registration of an exemption typically involves submitting information to the relevant regulatory authority, providing evidence of the reasons for non-compliance, and outlining any steps being taken toward eventual improvement. In many schemes, exemptions are time-limited and require periodic review or renewal, along with documentation of ongoing energy-saving measures or alternatives where feasible. It is important for landlords to understand their ongoing obligations, including the duty to maintain basic energy efficiency measures where possible, to engage with tenants transparently, and to keep records up to date to avoid potential penalties or enforcement actions.
Property owners and managing agents should seek appropriate professional advice to determine whether an exemption is applicable to a given property, ensure that all criteria are clearly satisfied, and understand the implications for tenancy agreements, rental values, and any forthcoming regulatory updates.
High cost’ Exemption
The prohibition on letting property below an EPC rating of E does not apply if the cost of making even the cheapest recommended improvement would exceed £3,500 (inc. VAT). This exemption is only available for domestic property and is intended to reflect cases where necessary energy efficiency measures would be disproportionately expensive relative to the property’s value or the landlord’s financial position.
If the high cost exemption applies, the landlord must register this on the PRS Exemptions Register. To support this exemption, the landlord is required to upload copies of three quotations from different installers, each showing that the cost of purchasing and installing the cheapest recommended improvement exceeds £3,500 (inc. VAT); and confirmation that the landlord is satisfied that the measure(s) exceed this amount. The exemption will be valid for five years; after this time the exemption expires and the landlord must try again to improve the property’s EPC rating to meet the minimum level of energy efficiency. If this still cannot be achieved, a further exemption may be registered.
It is important to note that this exemption should only be used where there are no improvements which can be made for £3,500 or less. In many cases, energy efficiency improvements can be achieved within this threshold; analysis suggests that the majority of EPC F and G rated properties can receive at least one improvement for £3,500 or less. If one or more recommended improvements can be made for £3,500 or less, and these improvements fail to achieve an EPC of E, then the ‘All Improvements Made’ exemption should be registered (see item number 5) where all the “relevant energy efficiency improvements” for the property have been made but the property remains sub-standard.
When considering the high cost exemption, landlords should carry out a careful assessment of all recommended measures. They should document which improvements are financially feasible within £3,500, which improvements would exceed the threshold, and the expected impact on the EPC rating. In cases where improvements are phased or staged, the landlord should include a clear plan, showing the anticipated timing and costs for each step, and how those steps would collectively meet or fail to meet the EPC requirement.
In addition to the quotations, the landlord may be asked to provide supporting evidence such as the current EPC certificate, property plans, and a brief statement explaining why the proposed measures are necessary and how they would influence energy efficiency. The goal of the exemption process is to balance the need to improve energy performance with the practical financial considerations faced by landlords, while ensuring tenants benefit from safer and more efficient housing over time.
‘7 Year Payback’ Exemption
This provision applies when a recommended energy efficiency measure for a non-domestic property does not qualify as a relevant energy efficiency improvement because the cost of purchasing and installing the measure would not meet the simple seven year payback requirement established in Regulation 28(3). It is specifically limited to non-domestic properties and does not apply to domestic properties.
Under this rule, the prohibition on letting a non-domestic property that has an EPC below a minimum energy efficiency rating of E can be avoided if the landlord can demonstrate that the cost of purchasing and installing the recommended improvement or package of improvements does not meet the seven year payback test. In other words, the expected savings on energy bills over seven years, beginning from the date the installation is completed, must be at least equal to the cost of purchasing and installing and paying for the improvement(s). If the expected energy savings over seven years are less than the cost of the improvement, the measure will fail the seven year payback test and the exemption may be applicable.
The precise calculation methodology and thresholds for the seven year payback test are set out in Regulation 28(3) through 28(8) and are described in chapter 2 of the non-domestic guidance. Practically, this means that landlords must quantify the total cost of the measure(s) and compare it with the projected cumulative energy bill savings over seven years, taking into account any ongoing maintenance costs, potential energy price increases, expected usage, and any other factors specified in the guidance. The calculation should be performed using the standard method described in the regulation and accompanying guidance to ensure consistency and transparency.
If a landlord intends to register an exemption based on the seven year payback rule, they must provide evidence that the measure does not meet the payback threshold. This requires uploading three quotes from qualified installers for the cost of purchasing and installing the measure, and confirmation that the landlord (or, where the landlord is not a company under section 1 of the Companies Act 2006, confirmation that a director—or, in any other case, confirmation that a person exercising management control in relation to the landlord—is satisfied that the seven year payback rule is not met). In addition, the landlord should upload the cost calculations prepared to demonstrate the payback outcome. It is important that the quotes are from installers who are appropriately qualified and experienced to install the proposed measure and that the quotes clearly separate material costs, installation labour costs, any necessary ancillary works, and any VAT considerations or other charges that may affect the total cost.
This exemption is valid for five years from the date of registration. At the end of the five-year period, the exemption will expire automatically, and the landlord must attempt again to improve the property’s EPC rating to reach the minimum energy efficiency requirement. If, at that time, the EPC rating remains below the required level and the seven year payback condition still applies, the landlord may register a further exemption, provided the new circumstances continue to meet the regulatory criteria and the process for documenting and calculating the payback is followed. The five-year validity period allows landlords time to implement feasible measures while maintaining a pathway to meet the minimum energy efficiency standard in the future.
In addition to the above, landlords should be aware of related considerations. They should ensure that any exemption does not conflict with other regulatory requirements or enforcement actions, maintain complete and accurate records of all cost estimates, energy savings projections, and the supporting documentation, and be prepared to provide access to the property for inspection or review if required. If market conditions or energy prices have significantly changed since the original calculation, landlords may need to reassess the payback calculation prior to renewal or reconsider whether alternative measures with a more favorable payback period are available. For any questions or clarifications, landlords should consult the official non-domestic guidance or contact the appropriate regulatory authority designated to administer the energy efficiency standards for non-domestic properties.
All Improvements Made’ Exemption
This provision concerns situations where all feasible energy efficiency improvements have been implemented for a rental property, or where no such improvements exist, yet the property still falls below the minimum energy efficiency standard of EPC E. In such cases the landlord may be exempt from the EPC E requirement under Regulation 25, and the exemption must be recorded on the Private Rented Sector (PRS) Exemptions Register before the property can be let to new tenants, or allowed to continue letting in the domestic sector after 1 April 2020 and in the non-domestic sector after 1 April 2023. The exemption applies to both domestic and non-domestic properties, provided the criteria are met.
The core condition is that all relevant energy efficiency improvements that can reasonably be made have been completed, or that there are no such improvements available for the property. It is important to consult the published guidance documents to determine the precise definition of relevant energy efficiency improvements, as this will inform whether the landlord qualifies for the exemption. The guidance explains which measures are considered relevant, factors that may affect feasibility, and any exceptions or limitations that may apply in particular situations, such as properties with structural or planning constraints.
If the landlord is relying on this exemption, the case must be documented and registered on the PRS Exemptions Register prior to letting the property to a new tenant or, in the domestic sector, prior to continuing to let after 1 April 2020, or in the non-domestic sector, after 1 April 2023. The registration process requires information that corroborates the reliance on the exemption, including evidence that all relevant improvements have been undertaken or that none are practicable. In many instances the landlord will use information from the property’s Energy Performance Certificate (EPC) as part of the documentation, since the EPC is one of the data elements that must be uploaded to the Register for any exemption type. If, however, the landlord’s basis for the exemption includes information contained in a separate report, a copy of that report must also be uploaded to the Register to support the exemption.
The exemption, once granted and registered, is valid for a period of five years. At the end of this five-year period, the exemption expires and the landlord has a renewed obligation to seek improvements sufficient to raise the property’s EPC rating to at least E. If it proves impossible to achieve an EPC E rating after attempting reasonable improvements, a further exemption may be submitted and registered. Landlords should plan for re-evaluation before the expiry date and maintain up-to-date documentation to demonstrate ongoing compliance or the justification for any continued exemption.
In practice, this means landlords should conduct a thorough assessment of the property’s current energy performance, identify all measures that would fall within the scope of “relevant improvements,” and document either the completion of those measures or the reasons why they are not feasible. Typical examples of relevant improvements may include upgrading insulation, installing more efficient heating systems, upgrading windows, modernizing lighting, and other measures described in the guidance as appropriate for the property type. Where improvements have been implemented, records such as installation dates, specifications, responsibilities (landlord versus contractor), and cost considerations should be kept as part of the exemption file.
It is also prudent to verify any external constraints that could affect the feasibility of improvements, including building regulations, planning permissions, structural limitations, or access issues. In cases where the landlord cannot demonstrate that all possible improvements have been made because they are not feasible, it is essential to document the specific constraints and provide supporting evidence when submitting the exemption claim.
Finally, landlords should be mindful of the implications for tenants and recruitment of new occupants. While the exemption allows continued letting without meeting EPC E, tenants must be informed that the property remains below the standard and that an exemption is in place, with the understanding that the exemption is time-limited and subject to renewal pending feasibility assessments. Clear communication and accurate record‑keeping will facilitate compliance with the regulatory framework and help avoid potential disputes or penalties.
Wall Insulation’ Exemption
This provision recognises that while cavity wall insulation, external wall insulation, or internal wall insulation on external walls can be effective energy improvements, there are circumstances where applying these measures could be detrimental to the fabric, structure, or long-term integrity of the building. The exemption is designed to allow landlords to proceed with alternative strategies to improve the property’s energy efficiency without compromising the building’s stability or heritage values, when a qualified professional has advised that the insulation would have a negative impact.
The exemption applies to both domestic and non-domestic properties, and the funding requirements referenced differ between these property types. When assessing options, landlords should consult the relevant guidance documents to understand the specific funding criteria and any limitations that may affect eligibility or uptake for a given property.
To qualify for the exemption, the insulation measure being considered must be one of the following: a cavity wall insulation installation, an external wall insulation system, or an internal wall insulation system for external walls. In addition, the landlord must obtain written expert advice from one of the specified independent professionals stating that the proposed measure is not appropriate for the property due to potential adverse effects on the fabric or structure of the property, or the building of which the property forms a part. The list of eligible experts includes architects registered on the Architect Accredited in Building Conservation register; chartered engineers registered on the Institution of Civil Engineers’ and the Institution of Structural Engineers’ Conservation Accreditation Register for Engineers; chartered building surveyors registered on the Royal Institution of Chartered Surveyors’ Building Conservation Accreditation register; or chartered architectural technologists registered on the Chartered Institute of Architectural Technologists’ Directory of Accredited Conservationists. If advice from one of these experts cannot be obtained, the landlord may instead obtain advice from an independent installer of the wall insulation system who meets the installer standards for that measure as set out in Schedule 3 to the Building Regulations 2010.
When registering such an exemption, the landlord must upload to the register a copy of the written opinion from the relevant expert confirming that the property cannot be improved to an EPC E rating because the recommended wall insulation would have a negative impact on the property or the building of which it is a part. This documentation is essential to support the exemption and to establish the basis for the decision.
Once the exemption is registered, its effect lasts for five years. During this period, the property does not need to meet the EPC E rating through the excluded insulation measure, but the landlord should continue to explore alternative measures that could improve energy efficiency within the constraints identified by the expert advice. At the end of the five-year period, the exemption expires, and the landlord must attempt again to improve the property’s EPC rating to meet the minimum energy efficiency level. If achieving the required rating remains not feasible, a further exemption may be registered, subject to the provision that new expert assessment may be required to confirm continued justification for exemption based on the property’s circumstances at that time.
Landlords should be mindful of additional considerations, such as the impact of the exemption on tenants, potential effects on property insurance or warranties, and any local or transitional regulatory updates that may influence the validity or scope of the exemption. It may also be prudent to document any alternative energy efficiency measures pursued in parallel, such as upgrading heating systems, improving air sealing, or enhancing renewable energy provisions, to demonstrate ongoing commitment to improving overall energy performance while respecting the constraints identified by the expert adviser. Regular review and prompt renewal applications, supported by current expert opinions where circumstances evolve, will help ensure continued compliance and transparent communication with tenants, regulators, and other stakeholders.
Consent Exemption
Third party consent exemption under Regulation 31(1) and Regulation 36(2) covers both domestic and non-domestic properties. Depending on the circumstances surrounding a property, certain energy efficiency improvements may legally require consent from third parties before installation can proceed. These improvements can include works such as external wall insulation, solar photovoltaic systems, or other changes that may affect structural, financial, or tenancy arrangements. Consent may be required from local planning authorities, mortgage lenders, a superior landlord when the landlord is themselves a tenant, the current tenant, or other tenants depending on the terms of the tenancy or tenancies.
Because the range of potential consent requirements depends on the specific facts of each case, it is not practical to provide an exhaustive list of all situations in which third party consent may be necessary. Information about when and where consent is required will be found in the relevant documentation for the property, such as the landlord’s lease or mortgage conditions, tenancy agreements, and any covenants governing the property. It is important for landlords to review these documents carefully and, where needed, to obtain professional legal or surveying guidance to interpret the obligations that apply to a proposed energy efficiency measure.
Information required to register an exemption of this type: when initiating a registration, the landlord must upload to the register any correspondence and/or relevant documentation that demonstrates that consent for the relevant energy efficiency measure was required and that consent was sought, together with evidence of whether consent was refused or granted subject to a condition that the landlord was not reasonably able to comply with. The documentation should clearly identify the measure in question, the parties from whom consent was sought, the dates of requests, any conditions imposed, and the outcomes of those requests. Where there is correspondence indicating partial consent or conditional consent, the landlord should provide a full explanation of why compliance with those conditions was not reasonably feasible.
Operational implications and timeline: once an exemption is registered, it will generally last for five years. At the end of the five-year period, the landlord is expected to take reasonable steps to improve the property’s EPC rating to meet the minimum required level. If achieving the minimum level is not possible, the landlord may apply for a further exemption. It should be noted that exemptions cannot be used to bypass valid prohibitions or unreasonably prolong the installation of improvements. In particular, where improvements cannot be made because consent could not be obtained from the current tenant, the exemption will remain valid only for as long as that tenant remains in occupation. When the property is next let under a new tenancy, the landlord will need to address the improvement requirement before or in conjunction with the new tenancy, or seek a fresh exemption if appropriate and applicable under the regulations.
Practical considerations for landlords: early and proactive engagement with all affected parties is strongly advised. This includes confirming whether planning consent, building regulations approvals, or other regulatory permissions are required, and whether funding or financial covenants constrain the project. Keeping a clear record of all attempts to obtain consent, including dates, contact details, and responses, will support the exemption registration and any future renewals. Where consent cannot be obtained, landlords should consider alternative measures that may be permissible under the property’s lease, tenancy agreements, or applicable law, or explore staged or part-installation approaches that could reduce the scope of consent required. In cases where an exemption is pursued, landlords should also assess any potential impact on tenants, service charges, and the overall occupancy strategy, and communicate clearly with tenants about timelines and expectations.
Additional notes: the exemption regime is designed to balance the need to improve energy efficiency with respect for third party rights and contractual covenants. Where there are disputes or uncertainties about whether consent is required, or about the validity or scope of an exemption, landlords may wish to seek guidance from the relevant regulatory body, consult with planning authorities, or obtain legal advice to ensure compliance and to minimise the risk of challenge or redress options by affected parties.
Devaluation Exemption
This exemption provides a specific pathway for landlords who cannot meet the minimum energy performance standard due to the potential negative impact on property value as determined by an independent RICS surveyor. It is applicable to both domestic and non-domestic properties and is designed to ensure that property owners are not compelled to implement measures that would reduce market value to an unjustified extent. The decision to grant such an exemption must be based on a formal assessment by a surveyor who is on the Royal Institution of Chartered Surveyors register of valuers, and the report must clearly demonstrate that the installation of the recommended energy efficiency measures would cause the market value of the property, or the building it forms part of, to fall by more than five percent.
To support the exemption, the surveyor’s report must explicitly list all the energy efficiency measures that would lead to the devaluation, with a clear explanation of how and why each measure contributes to the reduced value. The report should also consider the broader market context, potential alternative improvements, and any mitigating factors that might influence value, such as the availability of financing, the presence of other energy efficiency initiatives, or changes in local property demand. It is important to note that the exemption is not a blanket exemption from improvement requirements; landlords remain obliged to install any energy efficiency measures that are relevant to their property and are not excluded by the exemption. If a measure is recommended by the surveyor but falls outside the scope of the exemption, the landlord must proceed with those improvements unless another exemption applies.
When registering an exemption, the landlord must upload to the register a copy of the independent RICS surveyor’s report that provides evidence of the potential devaluation. The documentation should be current and dated, with the surveyor’s professional qualifications and the basis for the valuation clearly stated. It is advisable to ensure that the report includes an assessment of the timing and feasibility of implementing the measures, and any conditional factors that could alter the impact on value, such as future market changes or anticipated policy shifts.
Once the exemption is registered, it typically remains valid for a period of five years. At the end of this period, the landlord must reassess the property’s EPC rating and the feasibility of achieving the minimum standard. If the property still cannot meet the minimum energy efficiency rating without incurring a devaluation, the landlord may apply for a further exemption, subject to updated evidence and a new independent assessment. It is prudent for landlords to plan for interim improvements that do not fall under the exemption, or to pursue partial upgrades that raise the property’s rating while maintaining the exemption’s justification.
Landlords should also be aware of the possibility of changes in regulations or in the interpretation of the exemption criteria, and should monitor any guidance issued by the relevant regulatory authority. If market conditions improve or if new technologies emerge that alleviate the devaluation concern, the exemption may no longer be appropriate, and the owner would need to re-evaluate the property and potentially pursue upgrades to meet the standard. In parallel, the landlord should maintain thorough records of all communications, assessments, and upgrade activities to support compliance and to facilitate any future reviews or audits.
New Landlord Exemption
This document provides an overview of the temporary exemption provisions that apply when a person has recently become a landlord under Regulation 33(1) and Regulation 36(2). It is intended to acknowledge that there are limited, exceptional circumstances in which an immediate full compliance with energy efficiency and sub-standard property prohibitions would be unreasonable due to the sudden transfer of landlord responsibilities. The exemptions apply to both domestic and non-domestic properties and are designed to give new landlords a six month window to arrange the necessary improvements or to rely on an alternative exemption where applicable.
The scope of the exemptions covers several specific scenarios. These include situations where a lease has been granted due to a contractual obligation, including contracts entered into on a contingent basis, regardless of whether they were formed before or after the regulations came into force. It also covers cases where the tenant becomes insolvent and the landlord has acted as the tenant’s guarantor, in which case the guarantor becomes the landlord upon taking over the lease. Additional circumstances include situations where a landlord has acted as a guarantor or as a former tenant who has exercised the right to obtain an overriding lease under section 19 of the Landlord and Tenant (Covenants) Act 1995; where a new lease has been deemed created by operation of law; where a new lease has been granted under Part 2 of the Landlord and Tenant Act 1954; and where a new lease has been granted by a court order, other than under Part 2 of the 1954 Act. These provisions are designed to reflect the realities faced by new landlords when immediate compliance would be disproportionate.
From 1 April 2020, a further six month temporary exemption applies from the date a person becomes the landlord in a situation where the minimum standard applies to all privately rented properties occupied by tenants, and the landlord has become the owner of a property that is currently let under an existing tenancy. In all such cases, landlords should document the date they became the landlord and provide a narrative explanation of the circumstances that led to their landlord status, referencing the particular exemption category that applies.
It is important to emphasise that the exemption lasts for six months from the date the person becomes the landlord. After this period expires, the landlord must have either achieved an energy efficiency improvement that raises the property to at least EPC band E, or have registered another valid exemption if one is available and applicable, in order to continue letting the property. Educational and advisory services recommend that landlords plan in advance for compliance beyond the exemption period, to avoid potential penalties.
Regarding EPC requirements, current rules prohibit granting a tenancy to new or existing tenants in a property rated F or G unless the property is registered on the PRS Exemptions Register. Since 1 April 2023, it has further become an offence to continue letting or renting a property that does not meet at least an EPC rating of E, with penalties calculated on the rateable value of the property, typically ranging from £10,000 to £150,000 per breach. In addition, details of breaches can be made publicly available. There is an expectation that these standards will be tightened in the future, with discussions suggesting that commercial properties may be required to achieve an EPC rating of C or higher by 1 April 2027 and B or better by 2030.
To avoid inadvertent breaches, landlords are strongly advised to obtain independent legal advice if there is any doubt whether a particular temporary recent-landlord exemption applies. In addition, landlords should keep thorough records of all communications, dates, and documentation related to the exemption registration, property energy assessments, and any improvements undertaken or planned. Where possible, landlords should consult qualified energy assessors or building professionals to determine the most efficient and cost-effective upgrade options and to understand any enabling works or consent requirements from building owners, tenants, or local authorities.
If a landlord determines that an exemption is not applicable or no longer sufficient to cover ongoing letting, proactive steps should be taken to improve the property’s energy efficiency or to seek and register an alternative exemption as appropriate. It is essential for landlords to communicate transparently with tenants about any exemptions or planned improvements and to ensure that all actions remain compliant with current regulatory requirements.
Landlords should consider creating a compliance plan that outlines timelines for EPC improvements, budgets for energy efficiency measures, and milestones for securing any necessary permissions or funding. This plan can help ensure a smoother transition beyond the initial exemption period and reduce the risk of non-compliance or penalties.