# Listed building EPC upgrades and the exemption route > What you can and cannot change in a listed commercial building, and when a registered exemption is the honest end point. Source: https://commercialepcupgrades.co.uk/buildings/listed-building --- # Listed building EPC upgrades and the exemption route Every other building type on this site is a question of what is worth spending. A listed building is a question of what you are allowed to do. Consent constraints can put the obvious measures out of reach entirely, and the honest end point is sometimes a properly evidenced exemption rather than a better certificate. The owner, the local conservation officer, and in some cases a national heritage body. General guidance, not legal advice Energy performance rules for commercial property in England and Wales have changed repeatedly, and proposals have moved during consultation. This page describes the position as we understand it and is written to be useful rather than definitive. Check the current position and your own obligations with a solicitor or a qualified assessor before committing to capital spend. ## Consent comes before specification Changes affecting the character of a listed building generally need consent, and the elements that matter most for energy are frequently the ones that define that character: windows, roofs, facades and visible services. A specification produced without that conversation is a specification that gets refused. In practice the useful sequence is reversed from a normal project. Establish what is likely to be permitted, then design within it, then price it. Doing it the other way round wastes the fee. ## What usually can be done - Lighting, in most cases, because fittings are reversible and frequently not original. Surface-mounted and pendant solutions avoid cutting into historic fabric. - Heating controls, zoning and scheduling, which change behaviour rather than fabric. - Insulation at loft and floor level where it is concealed and reversible. - Draught-proofing and secondary glazing, which is often acceptable where replacement windows are not. - Plant replacement where the plant is modern and the plant room is not of historic interest. Reversibility is the recurring theme. A measure that can be removed without trace is a far easier consent conversation than one that cannot. ## When the exemption register is the right answer Where the required work cannot lawfully be done, or would unacceptably alter the building, there is provision to register an exemption rather than carry out the work. That is a legitimate, evidenced route and not a loophole: it needs the right grounds, the right evidence and registration, and an unregistered exemption is not an exemption at all. This is firmly a question for a solicitor and a qualified assessor rather than a contractor. Get the advice before you conclude the building cannot be improved, because the assumption is wrong more often than people expect. ## The thing people get wrong Assuming listed means nothing can be done. Lighting in particular is usually available, it is reversible, and in a building with poor fabric it may be a larger share of the controllable load than it would be in a modern one. The opposite error is assuming consent is a formality. It is not, and a refused application after a full specification is an expensive way to find out. ## Questions we get asked ### Can a listed commercial building be exempt from the minimum standard? ### Can we change the lighting in a listed building? ### Do we need consent for everything? Sources - A landlord who cannot meet the minimum may register an exemption on the PRS Exemptions Register. Registration is self-certified and must be supported by evidence. [Guidance on PRS exemptions and Exemptions Register evidence requirements, DESNZ, 2017](https://www.gov.uk/government/publications/private-rented-sector-minimum-energy-efficiency-standard-exemptions/guidance-on-prs-exemptions-and-exemptions-register-evidence-requirements) - A non-domestic EPC is an asset rating: it is based on the fabric of the building and its services rather than on metered consumption. [A guide to energy performance certificates for the construction, sale and let of non-dwellings, DCLG, 2014](https://www.gov.uk/government/publications/energy-performance-certificates-for-the-construction-sale-and-let-of-non-dwellings) Last updated 8 October 2026 . - [MEES and the minimum The obligation an exemption sits against](https://commercialepcupgrades.co.uk/mees) - [Lighting Usually the most available measure here](https://commercialepcupgrades.co.uk/measures/lighting) Next step ## Get a quote for your listed and historic building One commercial contractor, quoting off a survey of the actual building rather than a rate per square foot over the phone. Or call [07367 293494](tel:+447367293494). Monday to Friday, 9am to 5.30pm.