Whether an Airbnb or holiday let needs an Energy Performance Certificate (EPC) is a genuine grey area, and it is one where a lot of hosts either pay for a certificate they do not need or skip one they do. The rule turns on how the property is let, not just what you call it. Here is the accurate position, with the exemptions and the traps that catch people out.

When an EPC is generally required

An EPC is normally required whenever a building is built, sold or let. For most rented homes that means you must have a valid EPC to market and let the property, and in England and Wales the Minimum Energy Efficiency Standard (MEES) requires a domestic property let on a qualifying tenancy to reach at least band E. So the starting assumption for a let property is that an EPC is needed.

The holiday-let exemption

Short-term and holiday lets are the exception, and this is where the confusion lives. Government EPC guidance treats a building as not needing an EPC where it is holiday accommodation rented out for less than four months a year, or where it is let under a licence to occupy rather than a tenancy. A genuine short-stay Airbnb, where guests stay under a licence to occupy for short periods and the property is not let as a home for four months or more in the year, can therefore fall outside the EPC requirement altogether.

When you do still need one

The exemption is narrower than it sounds, and an EPC is required if any of the following apply:

The property is let for four months or more in a 12-month period.
It is let on a tenancy rather than a short-stay licence to occupy — for example a longer winter let between seasons.
You sell or remortgage the property — sale always triggers an EPC, and most mortgage lenders require a valid one, so many holiday-let owners need an EPC for finance reasons even when letting alone would not demand it.

Because of the finance point in particular, a large share of holiday lets end up needing an EPC anyway, which is why “you never need one for an Airbnb” is as wrong as “every Airbnb needs one”.

Does the band E minimum apply?

MEES — the band E minimum — bites on domestic properties let on qualifying tenancies. A pure short-stay let occupied under a licence to occupy generally sits outside MEES, so the band E floor does not apply in the same way it would to an assured shorthold tenancy. But if your letting arrangement is actually a tenancy, or the property is also let residentially, MEES can apply — so the occupation basis matters, not the label on the listing.

Scotland, Wales and Northern Ireland

In Scotland and Northern Ireland, an EPC is required when a property is sold or let, but there is no MEES-style minimum rating for holiday accommodation in the way England applies it. In Wales, the position broadly follows England. And note that Scotland’s short-term let licence can require you to hold an EPC as part of the application, so a Scottish short-term let may need one via licensing even where the letting pattern alone would not demand it.

Don’t confuse EPC rules with the tax regime

The old “furnished holiday let” (FHL) tax status — with its 105-day and 210-day letting tests — was a tax concept, and the FHL tax regime was abolished from April 2025. It is easy to muddle the FHL letting tests with the EPC four-month rule, but they are different things: the EPC question is about your letting pattern and occupation basis, not your tax status. Judge the EPC position on its own terms.

Listed buildings

Listed buildings can be exempt from the EPC requirement where the energy-efficiency measures an EPC implies would unacceptably alter the building’s character. This is not automatic — take advice from your local conservation officer rather than assuming the exemption applies.

The bottom line

If your property is a genuine short-stay let, rented under a licence to occupy for less than four months of the year, you may not legally need an EPC — but you will need one if you let for longer, let on a tenancy, sell or remortgage, or (in Scotland) as a licence condition. Given an EPC is inexpensive and lenders and some platforms like to see one, many hosts get one regardless. Work out your letting pattern and occupation basis first, and get one if there is any doubt.

How Complys helps

Complys stores your EPC (where you hold one) with your other property documents and tracks its ten-year expiry alongside your fire, gas and electrical records. See Airbnb & short-term let compliance software, and check the wider picture in our Airbnb fire safety and EICR guides, and the full Airbnb compliance checklist, or check where you stand with the free Airbnb compliance checker.

Official guidance and sources

GOV.UK — when a building needs an EPC and the exemptions.
gov.scot — short-term let licence conditions in Scotland.

Do you need an EPC for an Airbnb or holiday let?