By the Unity Stays directors, Marcus Chong & Gadir Al-Khatib · Last updated 12 August 2026
In short: Sometimes: an EPC is generally required when a property is constructed, sold or let, but for short-term holiday letting the requirement is narrower, turning on how long the property is let each year and who is responsible for the energy — so confirm rather than assume. Improving efficiency pays regardless, because in a short let the owner pays every bill.
When an EPC is required
An Energy Performance Certificate is generally required when a property is constructed, sold or let, and it must be made available to prospective buyers and tenants.
For short-term holiday letting the position is narrower than for tenancies, and turns on factors including how long the property is let for in a year and whether the occupier is responsible for the energy. Some genuinely short-let holiday accommodation falls outside the requirement.
Because the boundary depends on how a specific property is used, it is worth confirming rather than assuming either way — and where a property mixes short lets with longer stays, the longer stays can bring it into scope.
Minimum energy efficiency standards
Separately from the certificate itself, minimum energy efficiency standards restrict letting properties below a specified rating in the domestic private rented sector.
These are framed around tenancies, so the application to short-term holiday letting is not the same. Where a property is let on tenancies at any point, or on longer arrangements, the position changes.
The direction of travel across the sector has been towards higher minimum standards, and a property near the threshold today is worth improving on that basis alone rather than waiting to be forced.
Why efficiency matters here regardless of the rules
In a tenancy the tenant usually pays the energy bill. In a short let you do, all year, including the months nobody stays.
That inverts the usual landlord calculation. Insulation, draught-proofing and heating controls pay back directly to you rather than to an occupier, and they pay back faster than in any tenanted property because guests have no incentive to be careful.
A poorly insulated property with electric heating, let through a British winter to guests on an inclusive rate, is where an otherwise good short-let model quietly loses its margin. Our bills guide covers the controls that work.
What is worth doing first
In rough order of return for a typical property, and none of it requires waiting for a regulation.
Draught-proofing and loft insulation, which are cheap and immediate. Heating controls that limit temperature and switch off between stays. LED lighting throughout. Then the larger items — cavity wall insulation, glazing, heating system — which are worth assessing properly rather than piecemeal.
An EPC assessment is also a reasonable diagnostic even where one is not strictly required, because the recommendations report tells you where the losses are.
A plain summary of a changing area, not legal advice. EPC and minimum standard requirements depend on the property and how it is let. Confirm your position before letting.