Holiday Lets and EPC's

Why It’s Often Simpler to Just Get One

We’re often asked whether holiday lets need an Energy Performance Certificate (EPC). If you’ve looked online, you’ve probably seen conflicting advice - and the truth is that some situations can be open to interpretation.

Rather than focusing on technical arguments, this post explains the general principles and why, in many cases, getting an EPC is simply the easiest and lowest-risk option.

How EPC Requirements Are Usually Considered

EPC requirements are generally linked to:

• How a property is used
• How long it is available for occupation
• Whether it operates like a normal dwelling (heated, furnished, occupied)

For some holiday accommodation — particularly seasonal or limited-use properties — there may be a reasonable argument that an EPC isn’t required.

For others — especially those operating as modern, year-round holiday lets or short-term rentals - the position is often much less clear-cut.

Availability vs Actual Occupancy

One area that often causes confusion is the difference between:

• How long guests actually stay, and
• How long the property is available or marketed for letting

In practice, availability is often considered more relevant than actual bookings. A property that is listed and ready to let for much of the year may be treated differently from one that is only opened for a short, defined season - even if both have similar occupancy levels.

This is where borderline cases can arise, and where different advice can sometimes be found online.

A Quick Myth-Busting Section

“Holiday lets never need EPCs”

Some may not — but many do. There isn’t a single rule that applies to every holiday let.

“If it qualifies as a Furnished Holiday Let for tax, it doesn’t need an EPC”

Furnished Holiday Let (FHL) status is a tax concept, not an energy or building-use one. While it’s relevant for HMRC, it doesn’t automatically answer EPC questions.

“There’s no EPC if the owner pays the energy bills”

Who pays the energy bills doesn’t usually change how EPC requirements are considered. EPCs are about the building’s energy performance, not billing arrangements.

Why Many Holiday-Let Owners Choose to Get an EPC Anyway

Given the grey areas, many owners decide that obtaining an EPC is simply the most practical solution:

• Valid for 10 years
• Relatively low cost
• Provides peace of mind
• Removes uncertainty if rules are interpreted differently in future
• Helpful when selling, refinancing, or changing how the property is let

It can also highlight simple improvements that reduce running costs — something guests increasingly value.

A Practical Rule of Thumb

• Short-season, limited-use holiday properties → EPC position may be arguable
• Long-season or year-round holiday lets → An EPC is often the sensible choice