Very few unheated buildings are exempt from needing an EPC although some are classed as low energy buildings and where this is the case, no EPC is required when selling, leasing or renting the building.
If a building is unheated, The Department of Communities and Local Government (DCLG) EPC conventions are applied to consider whether the building is classed as of low energy use.
If an unheated building includes any form of personnel accommodation such as a toilets, tea making facility, office or workstation then an EPC will be required (although again, there are curtain situations where the conventions may change this situation).
In our experience, buildings that are exempt tend to have an agricultural use such as hay or grain stores or unheated storage buildings. In these cases, the building is not used as a workplace by personnel and is not conditioned.