The general consensus in the industry appears to be that listed buildings are exempt from the requirement to provide Energy Performance Certificates, if the property is being sold or rented, this has widely been the view since the recast of Energy Performance of Buildings Directive that came into force on 9th January 2013. 
However, there is no express exemption for listed buildings and only states that a listed building is exempt from a EPC in so far as compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance. 

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A quote from: The Energy Performance of Buildings England and Wales) Regulations 2012 states:  

“Duties relating to Energy Performance Certificates 
Application of Part 2 
5.—(1) This Part does not apply to— 
(a) buildings officially protected as part of a designated environment or because of their special architectural or historical merit, in so far as compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance;” 
The main issue here is that the test for certain Minimum energy performance requirements is not defined and therefore can’t be effectively complied with. The other side of the argument where most people get the understanding that EPC’s are not required is from historic England website on EPC requirement, this indicates that listed buildings are exempt from the EPC requirements, although government websites seem to back up the Energy Performance of Buildings regs that states “advice should be sought from the relevant local authority conservation officer if the work would alter the buildings character”. 
This appears to be a classic catch 22 situation in that to adhere to the regulations one would have to undertake an energy assessment and produce the EPC in order to then substantiate to an appropriate authority that the energy efficiency measures would unacceptably alter the building character, to then prove that the building was exempt from the EPC in the first place. 
BEST Compliance have been advised by Elmhurst that it would be easier to have EPC’s undertaken on ALL listed buildings although our personal opinion is that Grade 1 buildings should be exempt as there is very little you can do however Grade 2 buildings there is much more scope for improvements for instance the changing of light fittings/ bulbs and replacement of boilers are feasible in circumstances as these would not alter the appearance or character. 
However we can say once this is cleared up and if noted that you do not need EPC’s on listed buildings than the EPC placed on the listed building will be classed as a voluntary EPC and the landlord will not be required to meet the minimum standard in 2018. 
As I’m sure this is not an easy or logical situation, and should you require further information please do not hesitate to contact us and we can further clarify any new progress on this matter. 


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