1. What are the MEES regulations?
The Minimum Energy Efficiency Standards (MEES) set the minimum Energy Performance Certificate (EPC) rating required to let commercial property in England and Wales. If a property doesn't meet the minimum standard, you cannot legally:
- Grant a new lease
- Renew an existing lease
- Continue an existing lease (since April 2023)
This isn't guidance or best practice — it's law, with enforcement powers and significant penalties.
2. Where the standards stand now — and what changed in 2026
For years the expected path was "EPC E now, rising to C by 2027 and B by 2030, across all commercial stock." That trajectory has changed.
On 18 June 2026, the Department for Energy Security and Net Zero (DESNZ) published its interim response to the non-domestic MEES consultations. The position now is:
- EPC E — the minimum to let, now. In force since April 2023 for all lettings, including continuing leases. A property rated F or G is already in breach unless it has a registered exemption.
- EPC B by 2031 — but only for larger buildings. From 2031, privately rented commercial buildings over 1,000 m² must reach EPC B, where doing so is cost-effective.
- The EPC C by 2027 milestone has been dropped. The previously proposed interim step is no longer going ahead.
- Buildings of 1,000 m² or under stay on EPC E — with no announced deadline to go beyond it.
The existing flexibility mechanisms — the 7-year payback test and the established exemptions — remain in place.
Important: these changes are not yet law. They require secondary legislation to pass through Parliament, and a full government response is still expected. The direction of travel is clear, but the detail can still move.
3. The question that now comes first: how big is the building?
Under the old rules, every commercial property was heading the same way. Under the new position, building size decides the path:
- Over 1,000 m² — an EPC B target from 2031. That's a demanding standard, and a serious programme of work for most existing buildings.
- 1,000 m² or under — only the current EPC E minimum applies, with no further deadline announced.
For many landlords holding smaller units, this is a meaningful easing: the pressure to reach C by 2027 has gone. For owners of larger assets, 2031 may sound distant, but reaching a whole-building B is not a quick fix — it belongs in capital planning now.
4. Multi-let buildings: an added complication
For multi-let buildings, the 1,000 m² threshold is measured across the whole building, not floor by floor or unit by unit. Achieving a whole-building EPC B means coordinating improvements across both the common parts and individual tenant demises — areas you control and areas your tenants occupy.
That makes larger multi-let assets the most complex to plan: the works, the access, the timing around lease events and the cost recovery all have to line up. Starting early is the only realistic way to get there without disruption.
5. Why this matters to you
Legal compliance. You cannot legally let a non-compliant property. This applies now, to all tenancies — not just new leases. If your property is rated F or G today, you're already in breach unless you have a registered exemption.
Enforcement and penalties. Local authorities enforce MEES. For non-domestic property the penalties are set against the rateable value (Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, reg. 41):
- Letting in breach for less than 3 months — the greater of £5,000 or 10% of rateable value, up to a maximum of £50,000.
- Letting in breach for 3 months or more — the greater of £10,000 or 20% of rateable value, up to a maximum of £150,000.
- Registering false or misleading information — up to £5,000.
- Plus publication of the breach on a public register.
These are per-property penalties. A portfolio of non-compliant properties multiplies the exposure.
Lettability. Tenants increasingly weigh energy costs and sustainability when choosing premises. A poor EPC affects marketability, tenant quality and achievable rent.
Asset value. Poorly performing buildings are increasingly discounted in valuations — the so-called "brown discount." Investors and lenders scrutinise EPC ratings, so non-compliance affects capital value, not just income.
6. Understanding EPC ratings
EPC ratings run from A (most efficient) to G (least efficient), based on energy use per square metre. The rating considers:
- Fabric efficiency — insulation, glazing, airtightness
- Heating systems — efficiency, controls, distribution
- Lighting — efficiency and controls
- Renewables — solar panels, heat pumps
- Cooling — efficiency of air conditioning
Each building is assessed against a notional reference building. Ratings reflect the building's intrinsic characteristics, not how occupants use it.
7. Available exemptions
Several exemptions exist, each with specific requirements.
7-year payback exemption. If the improvements needed for compliance wouldn't pay back within 7 years through energy savings, you may register an exemption — but you must still carry out any improvements that do meet the 7-year test.
Consent exemptions. Where you can't obtain necessary consents — planning permission, listed building consent, tenant consent for disruptive works — an exemption may apply.
Devaluation exemption. If an independent surveyor determines that improvements would reduce market value by more than 5%, you may qualify.
New landlord exemption. If you've recently acquired a non-compliant property, a 6-month exemption period gives you time to improve it or register another exemption.
Points to remember about exemptions:
- They must be registered on the PRS Exemptions Register
- They last a maximum of 5 years, then must be renewed or replaced by compliance
- They're personal to the landlord — they don't transfer on sale
- They're not permanent solutions — you still need a long-term compliance strategy
8. What to do now
Map your portfolio by size and rating. The first cut is the 1,000 m² line:
- Buildings over 1,000 m² — these carry the 2031 EPC B target. Note their current ratings and the gap.
- Buildings 1,000 m² or under — confirm each clears the EPC E minimum. Anything at F or G is a breach today.
Assess improvement options. For anything needing work, professional energy assessment models the most cost-effective route to the required rating — insulation, heating upgrades or heat pumps, LED and controls, glazing, building management systems, renewables.
Plan and budget. Improvements take time and money. Align them with lease events, refurbishments and maintenance cycles; phase the spend; and for larger multi-let assets, start the coordination early.
Consider exemptions where compliance isn't cost-effective — but treat them as breathing space, not a solution.
Key Takeaways
- EPC E is the minimum now — F and G rated properties are already non-compliant.
- The proposed EPC C by 2027 deadline has been dropped.
- EPC B applies from 2031 — but only to buildings over 1,000 m², where cost-effective.
- Smaller buildings (1,000 m² or under) stay on E, with no further deadline announced.
- The changes are not yet law — secondary legislation is still to come.
- Multi-let assets are the most complex — a whole-building B means coordinating common parts and demises.
- Professional assessment is essential to know exactly what each property needs.
Need Help?
Working with our energy assessment partners Carbon Profile, we provide a complete MEES compliance service: assessment of what's needed, specification of improvement works, and managed delivery to achieve the rating you need — starting with a clear map of where your portfolio stands against the new rules.
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