EPC Exemptions Landlords – How to Register on the PRS Exemptions Register

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Key Takeaways

  • Exemptions are temporary – They last 5 years, after which you must re‑assess the property and either improve it or re‑register.
  • Five main exemption types: 1) High cost (£3,500 cap), 2) All improvements made, 3) Consent refused, 4) Devaluation, 5) Wall‑type/7‑year payback.
  • Registration is mandatory – You must submit evidence to the [PRS Exemptions Register](https://prsregister.beis.gov.uk/) before letting a sub‑standard property. Failing to register can result in fines up to £5,000.
  • Evidence requirements are strict – For a devaluation exemption, you need a RICS surveyor’s report; for consent refused, written proof from tenant/freeholder.
  • Exemptions do not apply to the 2025 C deadline – The current exemptions are for reaching an E rating only. New exemptions for C will likely have a higher cost cap (£10,000).

Introduction – When You Can’t (or Shouldn’t) Upgrade

A landlord in Brighton spent £4,200 on loft insulation, cavity‑wall insulation, and a new boiler – but her Victorian flat still rated an F. The assessor explained that the solid walls and single‑glazed windows made a C impossible without spending over £15,000.

She thought she was stuck with a £4,000 fine. Instead, she registered a “high‑cost” exemption and continued letting the property legally.

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EPC exemptions exist for a reason: some properties cannot be improved to an E (or C) within a reasonable cost, or improvements would cause more harm than good.

This article walks you through the five exemption types, the evidence you need, and exactly how to register on the PRS Exemptions Register. I’ll also show you common pitfalls that lead to rejected applications.

1. Who Needs an Exemption?

You should consider an exemption if:

  • Your property has an EPC rating of F or G.
  • You have spent £3,500 or more on improvements but the property still isn’t an E.
  • Required improvements are technically impossible (e.g., solid walls where insulation isn’t suitable).
  • Improvements would reduce the property’s value by 5% or more.
  • A tenant, freeholder, or planning authority refuses consent for the works.

Important: Exemptions are not a way to avoid upgrading indefinitely. They last 5 years, after which you must try again (or re‑register if circumstances haven’t changed).

2. The Five Exemption Types – Detailed Breakdown

2.1 High‑Cost Exemption

When it applies: The cost of buying and installing the cheapest improvement that would raise the property to an E exceeds £3,500 (including VAT).

Evidence required:

  • A copy of the current EPC.
  • At least three quotes for the recommended improvement(s) from qualified installers, showing the total cost exceeds £3,500.
  • A declaration that you have not deliberately obtained inflated quotes.

Example: Your EPC recommends external wall insulation costing £4,200. You obtain three quotes: £4,100, £4,300, £4,500. All exceed £3,500 → you qualify.

2.2 All Improvements Made Exemption

When it applies: You have installed all “relevant improvements” that can be made within the £3,500 cap, but the property remains below an E.

Evidence required:

  • A copy of the current EPC.
  • Receipts/invoices for all improvements carried out, totalling at least £3,500.
  • A new EPC showing the rating after improvements (still below E).

Example: You spent £3,400 on loft insulation, cavity‑wall insulation, and a new boiler. The new EPC shows an F rating. You’ve done all you can within the cap → exemption granted.

2.3 Consent Refused Exemption

When it applies: A tenant, freeholder, or planning authority refuses consent for the required improvements.

Evidence required:

  • Written proof of refusal (e.g., email, letter, signed form).
  • For tenant refusal: a copy of the tenancy agreement showing the tenant’s right to occupy.
  • For planning refusal: a copy of the rejection notice from the local planning authority.

Important: You must show you have made “reasonable efforts” to obtain consent. A single unanswered email may not be enough.

2.4 Devaluation Exemption

When it applies: Improvements would reduce the market value of the property by 5% or more.

Evidence required:

  • A report from a RICS‑qualified surveyor stating that the improvement would devalue the property by at least 5%.
  • The report must be specific to the property and the proposed works.
  • The surveyor must be independent (not your relative or business partner).

Example: Installing external wall insulation on a listed building would alter its character, reducing its value by 8%. A RICS surveyor confirms this → exemption granted.

2.5 Wall‑Type / 7‑Year Payback Exemption

When it applies:

  • The property has solid walls and internal or external insulation is not suitable (e.g., would cause damp).
  • The improvement would not pay for itself through energy savings within 7 years.

Evidence required:

  • A report from a qualified installer or surveyor confirming the wall type and unsuitability of insulation.
  • For 7‑year payback: a calculation showing the improvement cost versus expected annual savings.

3. Step‑by‑Step Registration Guide

Registering an exemption takes about 20 minutes if you have your evidence ready.

Step 1: Gather Evidence

Collect the documents listed above for your chosen exemption type. Ensure they are clear, legible, and in PDF or JPEG format.

Step 2: Create an Account on the PRS Exemptions Register

Go to [https://prsregister.beis.gov.uk/](https://prsregister.beis.gov.uk/) and click “Register as a landlord”. You’ll need:

  • Your name and contact details.
  • The property address(es).
  • Your landlord registration number (if you have one).

Step 3: Add a Property

Enter the property’s address and its EPC reference number (found on the EPC certificate). The system will pull in the EPC details automatically.

Step 4: Select Exemption Type

Choose the appropriate exemption from the dropdown menu. You’ll be prompted to upload your evidence.

Step 5: Upload Evidence

Attach your documents. Make sure they meet the file‑size and format requirements.

Step 6: Submit and Pay

There is no fee for registering an exemption. Review your application and submit.

Step 7: Confirmation

You’ll receive an email with a unique exemption reference number. Keep this safe – you may need to provide it to tenants, agents, or local authorities.

4. Common Mistakes That Get Applications Rejected

  • Insufficient evidence – Quotes that are not from qualified installers, missing receipts, or incomplete surveyor reports.
  • Wrong exemption type – Applying for “high cost” when you haven’t spent £3,500, or “consent refused” without written proof.
  • Out‑of‑date EPC – The EPC must be less than 10 years old. If it’s expired, you need a new assessment.
  • Not registering before letting – You must register the exemption before you let a sub‑standard property. Letting first and registering later is illegal.
  • Assuming exemption is permanent – Exemptions expire after 5 years. You must renew if the situation hasn’t changed.

Real‑world example: A landlord in Liverpool applied for a devaluation exemption but submitted a report from a local estate agent instead of a RICS surveyor. The application was rejected, and he was fined £2,000 for letting an F‑rated property without a valid exemption.

5. What Happens After Registration?

Once registered, you can legally let the property even though it’s below an E. However:

  • You must provide the exemption reference number to any prospective tenant (usually via the letting agent).
  • The exemption will appear on the public part of the PRS register (your name and the property address are visible).
  • You cannot make any false statements – doing so can lead to a £1,000 fine.

Renewing an Exemption

Five years after registration, you will receive a reminder email. You must:

1. Re‑assess the property – Get a new EPC to see if the rating has changed.

2. Check if new improvements have become cost‑effective – Technology and prices change; what was impossible 5 years ago may now be feasible.

3. Either upgrade the property to an E, or re‑register the exemption (with updated evidence).

6. Exemptions and the 2025 C Deadline

Important: The current exemptions are for reaching an E rating only. They do not automatically apply to the 2025 C requirement.

When the C deadline comes into force, new exemptions will likely be introduced with a higher cost cap (£10,000). If you currently have an exemption for reaching E, you will need to reassess for C.

Action point: If your property is exempt from reaching E, start planning now for how you’ll tackle the C deadline. Grants, new technologies, or changes in tenant consent may make upgrades possible by 2025.

7. Free Exemption Checklist

To ensure you don’t miss any steps, download our Property Compliance Checklist – it includes an exemption eligibility quiz, evidence checklist, and registration walk‑through.

[Download the Property Compliance Checklist](#) – Free for propertycomplianceuk.co.uk/ readers

Conclusion – Don’t Guess, Register

EPC exemptions are a legitimate way to comply when upgrading is impossible or unreasonable. But they require careful documentation and timely registration.

If your property is below an E:

1. Determine which exemption applies – review the five types.

2. Gather robust evidence – quotes, reports, written refusals.

3. Register before letting – use the PRS Exemptions Register.

4. Diarise the 5‑year renewal – set a reminder to re‑assess.

Ignoring the requirement or hoping you won’t get caught is a gamble that can cost you thousands in fines. Register correctly and let with confidence.

Unsure which exemption applies to your property?
Book a free 15‑minute compliance review with our team. We’ll analyse your EPC, recommend the appropriate exemption, and help you prepare the evidence. [Schedule your call here](#).

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