EPC and MEES for commercial property: what is required now, and what is proposed

In England and Wales, commercial EPC duties sit under MEES as well as the ordinary duty to have an EPC when a building is sold or let. Scotland and Northern Ireland use different rules, so the legal minimum-rating answer is not UK-wide.

What is the minimum EPC rating for a commercial property?

In England and Wales, the minimum EPC rating for a privately rented commercial property is band E, and since 1 April 2023 that E floor has applied to sitting tenancies as well as new lettings unless a valid exemption applies. The MEES regulations define the “minimum level of energy efficiency” for a non-domestic private rented property as “an energy performance indicator of band E,” and regulation 27 says: “A landlord of a sub-standard non-domestic PR property must not let the property unless regulation 29, or one or more of the exemptions in Chapter 4, applies.” Government landlord guidance makes the sitting-tenancy point explicit: “From 1 April 2023” the EPC E requirement applies to “all privately rented non-domestic properties (even where there has been no change in tenancy).” Scotland does not set a minimum commercial EPC band to let; it uses an action-plan disclosure regime instead. Northern Ireland also has no minimum band for commercial letting, but a valid EPC must be issued. Lenders often apply a tighter EPC bar than the legal E floor. Abodient can hold the EPC certificate against each commercial property and flag its expiry, so a landlord with a mixed portfolio can see which buildings are approaching a band that would block a new letting.

What new EPC rules are coming for commercial property?

The current England and Wales proposal is EPC B by 2031 for private rented non-domestic buildings over 1,000 square metres, not the older “C by 2028, B by 2030” timeline still repeated on some landlord-facing pages. The government’s 18 June 2026 interim response says that “from 2031” buildings over 1,000 square metres in England and Wales will need “EPC B, where cost effective,” and it also says “the previously proposed interim EPC C milestone for 2027 will not be taken forward.” The B rule is not law yet: the same response says the change “will only take effect following the successful passage of secondary legislation through Parliament.” Buildings below 1,000 square metres are intended to remain on the current EPC E minimum, with no further deadline set in that response. Scotland’s 31 October 2026 EPC change is a separate EPC format and methodology reform, not an EPC B minimum-rating rule for commercial landlords.

Last reviewed August 2026.

Sources

• MEES Regulations 2015, regulation 22 — “(b)"minimum level of energy efficiency", in relation to a domestic PR property and a non-domestic PR property, means an energy performance indicator of band E,” Source
• MEES Regulations 2015, regulation 27 — “A landlord of a sub-standard non-domestic PR property must not let the property unless regulation 29, or one or more of the exemptions in Chapter 4, applies.” Source
• GOV.UK non-domestic private rented property MEES landlord guidance — “From 1 April 2023, the requirement for non-domestic landlords to obtain at least an EPC E rating, unless they have registered a valid exemption, applies to all privately rented non-domestic properties (even where there has been no change in tenancy).” Source
• Scotland Assessment of Energy Performance of Non-domestic Buildings Regulations 2016, regulation 5 — “Where a building or building unit to which these Regulations apply is to be sold or is to be let by the owner of the building or building unit, the owner must—” Source
• Northern Ireland Energy Performance of Buildings Regulations 2013, regulation 5 — “Before a building is made available for sale or rent, the relevant person shall ensure that an energy performance certificate is issued for the building.” Source
• Kingston Surveyors — “Most major UK lenders now apply informal or formal minimum EPC thresholds as part of their lending criteria.” Source
• DESNZ interim response on non-domestic private rented sector MEES — “from 2031, it is proposed that all private rented buildings over 1,000 square metres in England and Wales will need to reach a higher standard of energy efficiency of EPC B, where cost effective” Source
• DESNZ interim response on non-domestic private rented sector MEES — “the intention is for buildings below 1,000 square metres to continue to be subject to the current minimum standard of EPC E” Source
• DESNZ interim response on non-domestic private rented sector MEES — “the previously proposed interim EPC C milestone for 2027 will not be taken forward, giving landlords and tenants more time to improve the efficiency of their buildings in a way that suits their buildings and lease agreements” Source
• DESNZ interim response on non-domestic private rented sector MEES — “The changes to raise MEES to EPC B for larger buildings will only take effect following the successful passage of secondary legislation through Parliament.” Source
• Scotland Energy Performance of Buildings Amendment Regulations 2025 — “Other than those regulations specified in paragraph (3) these Regulations come into force on 31 October 2026.” Source