Energy efficiency is one of the most prominent global challenges of our era. Heritage buildings usually have a poor energy performance, not necessarily because of their intrinsic constructive features but due to their mostly dilapidated condition owed to age and previous damage, exacerbated by other factors such as the limited maintenance allowed by the restrictive legal framework and/or residents not being able to afford retrofit. On both national and international levels, energy efficiency measures are considered the key to answering the global challenge of climate change. This article aims to provide a critical discussion of the policy framework for energy retrofitting targeting built heritage in the UK and in Turkey. To this end, the development of guidance and legislation on cultural heritage, energy efficiency and climate change in both countries were thoroughly reviewed, and the retrofit incentives and constraints were determined in order to identify existing policy gaps and potential problems with implementation in the realm of energy retrofitting and climate resiliency of heritage buildings. As a result of a critical comparative analysis, the paper is concluded with suggestions on policy frames for the retrofitting of heritage buildings for improved energy efficiency.