The Minimum Energy Efficiency Standard 2015 requires all commercial properties to have a minimum energy rating of an 'E'. Section 5 of the Energy Performance of Buildings (England and Wales) Regulations 2012 confirms that an EPC is not required for a listed building where compliance with the minimum energy performance requirements would "unacceptably alter the character or appearance of a building". However, the only way to properly assess whether there are any works that could be carried out to the property which could improve its energy rating is to commission an EPC which will confirm whether or not improvements can be made.

It is only once the EPC is commissioned that an assessment can be made as to whether any of the measures suggested in the Recommendation Report would unacceptably alter the character or appearance of the property. Evidence must be produced confirming that the minimum energy rating cannot be achieved. This includes obtaining evidence from the local planning authority confirming that the recommended works are not permitted under planning law.

An exemption would then need to be obtained before the new lease is granted by completing an online application at and uploading a copy of the EPC and Recommendation Report with the relevant planning/surveyor's evidence before a 5 year exemption certificate is issued.

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