MEES for Commercial Landlords: EPC E Today, EPC B Proposed for 2031
Today, under the Minimum Energy Efficiency Standards (MEES), you can't let or continue to let a commercial building in England and Wales with an EPC rating below E, unless a valid exemption is registered. That has applied to existing leases since 1 April 2023. On 18 June 2026 the government said, in an interim response to its consultation, that it intends to raise the minimum to EPC B from 2031 for privately rented commercial buildings over 1,000 m², where the works are cost-effective, while buildings under 1,000 m² stay at E. A full response and secondary legislation are still to come, so it isn't law yet, and details such as penalties under the new regime aren't confirmed. But a 2031 deadline is closer than it sounds once you count lease events and the time works take.
If you've read that the next step is EPC C in 2027 and B in 2030, that was the earlier proposal. The 2027 step has been dropped.
Where the rules stand in October 2026
| Status | What it means | |
|---|---|---|
| EPC E minimum for new lettings and renewals | In force since 1 April 2018 | No new lease or renewal on an F or G building without an exemption |
| EPC E minimum for all existing lettings | In force since 1 April 2023 | Continuing to let an F or G building is a breach, even mid-lease |
| EPC C by 2027 | Dropped | No longer part of the government's plans |
| EPC B from 2031, buildings over 1,000 m² | Proposed (interim response, 18 June 2026) | Where cost-effective; needs secondary legislation before it applies |
| Buildings under 1,000 m² | Proposed to stay at E | No higher minimum planned for now |
| Seven-year payback test and exemptions | Proposed to stay | You won't have to spend more than the works save over seven years |
The rules come from the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015. They apply to buildings that need an EPC and are let on leases of between six months and 99 years.
Who does MEES apply to?
If you're the landlord of a commercial building in England or Wales, let (or about to be let) on an ordinary commercial lease, assume it applies to you.
It catches more than offices: shops, warehouses, industrial units, restaurants, clinics, anything with an EPC. And it bites on existing leases too, not just new ones. A building that was fine when the tenant moved in can fall into breach because the law moved.
The exemptions
You don't have to do the impossible. You can register an exemption, valid for five years, on the government's PRS Exemptions Register. The main ones:
- All relevant improvements made. You've carried out every improvement that pays back within seven years (or there are none), and the building is still below the minimum.
- Consent. A tenant, superior landlord, lender or planning authority has refused consent for the works.
- Devaluation. An independent valuer confirms the works would reduce the building's market value by more than 5%.
- New landlord. A short temporary exemption when you've just become the landlord.
Exemptions are personal to the landlord who registers them. If you sell, the buyer has to deal with the building afresh. And the government's proposals keep the payback test and the exemptions, so they're not going away.
What happens if you don't comply?
Local authorities (trading standards) enforce MEES. Under the current regulations, the fine for letting in breach is linked to the building's rateable value and can reach £150,000 per breach, and the breach can be published. The bigger costs are usually indirect: a building you can't relet, a lender that won't refinance it, and a buyer who prices in the upgrade.
Why "B by 2031" is closer than it looks
Work backwards from 2031.
Most commercial leases give the landlord limited rights to carry out works while the tenant is in occupation. The natural windows for major upgrades are lease ends, breaks and voids. If your next lease event is 2028, that may be your only realistic chance before the deadline. Then add design, tendering and, for an occupied building, phased working.
There's a second trap. EPCs are valid for ten years, and the method behind them has changed since many current certificates were issued. A new EPC on an older building, especially one heated by gas, can come out lower than its old certificate without anything physical changing. Know your real rating before you plan around an old one.
What to do now
- Get a current picture. List every let building, its EPC rating, expiry date, floor area (is it over 1,000 m²?) and next lease event.
- Model the upgrade. Ask an energy assessor what it would take to reach C and B, and the cost of each step, from the recommendations report and a site visit.
- Line works up with lease events. Plan the biggest works for voids and lease ends. Use dilapidations settlements and refurbishments you were going to do anyway.
- Talk to tenants. Some works need their consent or access. Green lease clauses can make future upgrades easier.
- Price it with a builder. Assessors model; contractors price. The two together tell you what the upgrade really costs and how long it takes on site.
What usually moves a commercial EPC
Every building is different, so take this as a checklist to discuss with your assessor, not a promise:
- Lighting. LED fittings with presence and daylight controls. Often the cheapest step.
- Heating and cooling. Replacing old gas boilers or end-of-life air conditioning, often with heat pumps.
- Controls. Time, zone and temperature controls, or a building management system.
- Fabric. Roof and wall insulation, glazing, and sealing obvious air leaks.
- On-site generation. Solar panels on a suitable roof. See commercial solar installation.
How Craftex helps landlords
We carry out the works that change an EPC: lighting, heating and cooling, and fabric, in occupied buildings as well as empty ones, with noisy work at night or weekends where needed. Our landlord compliance service starts with a site audit of the building, and our sustainable and low-carbon fit-outs keep what works and replace only what doesn't.
If an upgrade looks uneconomic, the building may have a better future as something else. Our guide to what to do with an empty office building compares the options. Design ideas for greener workplaces are in sustainable office design tips.
We take construction projects from £100,000 to £10M+.
