Update (13 March 2026): The government has since delayed reformed HEM-based EPCs to the second half of 2027. Read more →
Two of the most significant changes buried in the government's January 2026 EPC reforms affect property types that have never needed energy certificates before. Listed buildings and conservation area properties are losing their automatic EPC exemption, and short-term rental properties — including Airbnb-style holiday lets — must now have a valid EPC in place when let. Published alongside the Warm Homes Plan and MEES reforms, these changes bring hundreds of thousands of additional properties into the EPC regime and raise urgent questions about how the Home Energy Model will handle buildings it was never designed for.
Listed Buildings Lose Automatic EPC Exemption for the First Time
· Source: GOV.UK
Since 2012, buildings “officially protected as part of a designated environment or because of their special architectural or historical merit” have been exempt from EPC requirements under Regulation 5(1)(a) of the Energy Performance of Buildings Regulations. In practice, this covered all listed buildings (Grade I, II*, and II) and many properties in conservation areas — roughly 410,000 listed buildings across England and Wales alone.
The government's partial response to the Reforms to the Energy Performance of Buildings consultation, published on 21 January 2026, confirmed this exemption will be removed entirely. Heritage properties will need a valid EPC when sold, let, or marketed, just like any other dwelling. The government acknowledged that a majority of consultation respondents opposed the change, but concluded that removing the exemption would “provide greater clarity and provide landlords and consumers with better information on energy performance.”
To address concerns about inappropriate retrofit recommendations, the government committed to tailoring EPC recommendations for heritage properties and retaining existing MEES exemptions where listed building consent is refused. A new “negative impacts” exemption under MEES will allow landlords to provide evidence that a specific measure would damage their property. The government's impact assessment estimated the change would generate approximately 35,000 additional EPCs across the heritage building stock.
What this means: Property owners and agents who have relied on the heritage exemption for over a decade will need EPCs for the first time. The real challenge is not the certificate itself but what it recommends — standard measures like external wall insulation and replacement double glazing can damage historic fabric. Whether HEM's new modular assessment approach can produce sensible recommendations for traditional buildings is the critical question.
Short-Term Lets Must Now Have EPCs — Regardless of Who Pays the Bills
· Source: GOV.UK
The government has closed a long-standing regulatory gap by requiring all short-term rental properties to have a valid EPC in place when let, regardless of whether the landlord or guest pays energy costs. Previously, many Airbnb hosts and holiday let operators avoided EPCs because their lets were shorter than four months per year or because all-inclusive pricing meant the landlord covered energy bills.
The definition of “short-term let” aligns with the Levelling Up and Regeneration Act 2023: any dwelling provided for guest accommodation in return for payment as part of a trade or business. Industry data suggests around 257,000 short-term let listings in England alone, concentrated in the South West, London, and the South East. The government also proposed extending MEES to short-term lets to prevent landlords switching tenure to avoid energy efficiency requirements.
What this means: Holiday let owners who have never commissioned an EPC will need one. Many short-term lets are also in heritage buildings — particularly in rural and coastal areas — so these two changes compound for a significant number of property owners.
The U-Value Problem: Why EPCs Consistently Underrate Old Buildings
· Analysis: HEM Guide
A core concern behind the heritage sector's opposition to the exemption removal is that current EPC methodology systematically underestimates the thermal performance of traditional construction. RdSAP assigns a default U-value of 2.1 W/m²K to pre-1919 solid walls, but peer-reviewed research consistently shows in-situ measured values averaging closer to 1.3 ± 0.4 W/m²K — roughly a third lower.
Stone walls compound the problem further. They are rarely truly solid — most contain voids filled with rubble and mortar — and their thermal performance varies dramatically with thickness, stone type, and exposure. Earth walls, cob, and wattle-and-daub present similar challenges. RICS has documented that “models underestimate historic building performance,” and SPAB has argued that current policy is “flawed in its application to traditional buildings, causing damage and creating risks.”
What this means: If HEM inherits the same default U-values, heritage buildings will continue to receive worse ratings than their actual performance warrants. The HEM EPC consultation proposes a modular approach that could address this — but only if assessors can input measured values rather than relying on defaults.
HEM's Modular Approach: A Better Deal for Heritage Properties?
The HEM EPC consultation explicitly acknowledges heritage properties, noting the modular approach may be “particularly important for dwellings not well represented by RdSAP default assumptions.” Unlike RdSAP's fixed data requirements, HEM allows assessors to input dwelling-specific measurements where available and fall back to defaults only where data is unobtainable.
Key improvements for heritage buildings include wall thickness as a calculation input (benefiting properties with thick masonry walls), more granular construction-type categories, and the separation of Fabric Performance as a standalone metric. The government has also proposed optional additional training for assessors on heritage building assessment — though heritage bodies have called for this to be mandatory.
What this means: HEM offers a structural improvement over RdSAP for heritage buildings, but “optional” training risks leaving the quality gap in place. A listed Georgian townhouse assessed by a specialist could get a very different rating to one assessed with default assumptions — and property owners cannot currently choose their assessor's specialism.
Heritage Bodies Sound Alarm Over “Flawed” Assessment of Traditional Buildings
· Sources: SPAB / CLA / Propertymark
The Society for the Protection of Ancient Buildings (SPAB) described current energy policy as “flawed in its application to traditional buildings, causing damage and creating risks.” The CLA called EPC recommendations for heritage properties “misleading at best or physically-damaging at worst” and opposed extending MEES to short-term lets. Propertymark warned that heritage buildings face “unique constraints around structural restrictions, cost, and expertise” and lack of grants makes retrofitting “financially unviable for many owners.”
The concern is not hypothetical. Standard EPC recommendations — external wall insulation, replacement double glazing, cavity fill — can trap moisture in traditional “breathable” construction, leading to damp, timber rot, and structural damage. SPAB has called for a review of the EPC Register to ensure recommendations for traditional properties “do not damage fabric” and recommended a dedicated task group on assessor qualifications for older buildings.
What this means: The heritage sector accepts the need for better energy data but argues the tools are not yet fit for purpose. The government has offered safeguards — tailored recommendations, a negative impacts exemption, optional training — but whether these are sufficient will depend on implementation detail that has not yet been published.
What's Still Outstanding: DECs, Data Quality, and the Full Response
· Source: GOV.UK
The January 2026 publication was a partial government response, covering questions 1–21 of the original consultation. Several important areas remain unresolved and will be addressed in a full response later in 2026. These include: Display Energy Certificate (DEC) validity periods, EPC data quality measures and accreditation standards, and air conditioning inspection reports (ACIRs).
The data quality question is particularly relevant to the heritage changes. If assessors are to produce meaningful EPCs for traditional buildings, training standards and quality assurance mechanisms need to be in place before the October 2026 target date. The government committed to “engaging with the sector on training and accreditation” but details remain sparse.
What this means: The full picture of EPC reform is not yet complete. Heritage property owners, holiday let operators, and energy assessors should watch for the full government response, expected later in 2026, which will address assessor training and quality standards — both critical for getting heritage assessment right.
What's Changing at a Glance
| Area | Before (Current Rules) | After (2026 Reforms) |
|---|---|---|
| Listed buildings | Automatic EPC exemption under Regulation 5(1)(a) | Exemption removed — EPC required when sold, let, or marketed |
| Conservation area properties | Potentially exempt if compliance would alter character | Exemption removed — same requirements as all dwellings |
| Short-term lets | EPC only if let 4+ months/year and guest pays energy | EPC required for all short-term lets regardless of billing |
| HMOs | EPC for individual units only | Whole-building EPC required (24-month transition) |
| Marketing timing | 28-day grace period after marketing begins | Valid EPC required at point of marketing |
| EPC validity | 10 years | 10 years (retained) |
Background & Context
These changes were published as part of the government's partial response to the Reforms to the Energy Performance of Buildings consultation, which ran from December 2024 to February 2025 and received over 1,600 responses. The partial response, covering questions 1–21, was published on 21 January 2026 alongside the Warm Homes Plan and the HEM EPC consultation.
The heritage exemption has been contentious since its introduction. While intended to protect buildings where energy improvements would “unacceptably alter their character,” it was not technically blanket — yet in practice it was widely treated as one. Removing it brings consistency to the market and provides data on a large segment of the housing stock that has been invisible to energy performance analysis. England's approximately 379,000 listed buildings include many of the country's least energy-efficient homes, and the absence of EPC data has made it impossible to quantify the scale of the challenge.
The short-term let change sits alongside the government's broader registration scheme for short-term lets (also from the Levelling Up and Regeneration Act). Together, these measures bring a large, previously unregulated segment of the rental market into the same energy performance framework as conventional tenancies. For a full overview of how EPCs are changing, see our How EPCs Change Under HEM guide.
What to Watch Next
Several developments will determine how these changes play out in practice:
- Full government response — expected later in 2026, covering DEC validity, EPC data quality, assessor training, and air conditioning inspections
- HEM EPC consultation response — the consultation closed 18 March 2026; the response will confirm band boundaries, default values for heritage construction types, and the modular assessment framework
- Heritage assessor training — whether the proposed “optional additional training” is adequate or whether mandatory specialist qualifications are needed
- Statutory instrument — the legal instrument removing the heritage exemption and bringing short-term lets in scope must be laid before Parliament
- MEES application to short-term lets — the government proposed this to prevent tenure switching, but confirmation is still awaited
For the full regulatory timeline including the Future Homes Standard, RdSAP to HEM transition, and MEES EPC C deadline, see our Timeline & Status page.
Frequently Asked Questions
Do listed buildings now need an EPC?
Yes. The automatic exemption is being removed. Once the new regulations come into force (originally targeted for October 2026, since delayed to H2 2027), heritage properties will need a valid EPC when sold, let, or marketed. However, existing MEES exemptions still apply where listed building consent for specific improvement measures is refused.
Do Airbnb and holiday let properties need EPCs?
Yes. Short-term lets will need a valid EPC when let, regardless of who pays the energy bills. This closes a gap where many holiday lets avoided EPC requirements because the landlord covered energy costs or the let was shorter than four months per year. The definition aligns with the Levelling Up and Regeneration Act 2023.
Will HEM rate heritage buildings more fairly than RdSAP?
Potentially. HEM's modular assessment approach lets assessors input dwelling-specific measurements rather than relying on defaults that underestimate traditional construction. Research shows RdSAP's default U-value for pre-1919 solid walls is roughly a third higher than measured values. HEM's ability to account for wall thickness should help — but the extent depends on the final methodology and whether assessors have adequate training for heritage properties.
When do these EPC changes take effect?
The government originally targeted October 2026 for new-style HEM-based EPCs but has since delayed the launch to H2 2027. The heritage exemption removal and short-term let requirements take effect when the regulations are laid. The current EPC system continues alongside the new one until October 2029.
Related Pages
How EPCs Change Under HEM
The four new metrics, what they measure, and how the new EPC design affects homeowners and landlords.
New EPC Metrics Explained
Fabric Performance, Heating System, Smart Readiness, and Energy Cost — what each metric measures and how banding works.
RdSAP to HEM Transition
How the switch from RdSAP to HEM works, what changes for assessors, and the dual-running timeline.
Timeline & Status
Live tracker of HEM, FHS, EPC reform, and MEES milestones.