EPCs - holiday lets?

It is “EPC day” on Wednesday, and many questions are arising. If you let out a holiday home, is an EPC required? Government Guidance states that an EPC is not required for holiday lets. In the DCLG Guidance paper “Energy performance certificates for dwellings in the social and private rented sectors: A guide for landlords” (see EPC Guide for Rentals ) there is a Q&A section at the back which reads: “Q. Will an EPC be needed for holiday accommodation? A. If the agreement between the parties expressly allows for a short period of holiday occupation only and no intention to create a tenancy can be inferred, then an EPC is not required.”

Whilst the academic lawyer would say that a two week letting for a holiday is nevertheless a tenancy, the landlord would prefer to ignore the academic lawyer, construe the arrangement as a licence, and go with Government Guidance.