Commercial MEES Update: What the New EPC B by 2031 Plans Mean for Landlords

Last year, we asked how realistic the proposed EPC B by 2030 target was for commercial properties.

We now have a much clearer answer.

In June 2026, the Government published an interim response to its consultations on strengthening Minimum Energy Efficiency Standards (MEES) for privately rented non-domestic buildings in England and Wales.

Previous Government proposals set out a future trajectory towards EPC B across the non-domestic private rented sector by 2030, with an interim EPC C milestone in 2027.

That approach has now changed.

Under the Government's latest plans, the EPC B requirement will focus on larger privately rented commercial buildings, while smaller properties will remain subject to the existing EPC E minimum.

What are the new commercial MEES proposals?

The Government has confirmed its intention to introduce a more targeted approach to non-domestic MEES.

From 2031, privately rented non-domestic buildings over 1,000 square metres would be required to achieve an EPC rating of B, where this is cost effective.

Properties below 1,000 square metres would continue to be subject to the existing minimum EPC E standard.

The previously proposed EPC C milestone for 2027 will also no longer be taken forward.

For landlords who had been planning around the earlier 2027 and 2030 dates, this represents a significant change.

It is important, however, to distinguish between the Government's stated intention and the law as it currently stands. The proposed EPC B requirement for larger properties will need secondary legislation to pass through Parliament before it comes into force.

What are the current EPC requirements for commercial landlords?

For now, the existing MEES requirements continue to apply.

Since 1 April 2023, privately rented non-domestic properties covered by the regulations generally need an EPC rating of E or above, unless a valid exemption applies.

This means commercial properties with an EPC rating of F or G generally cannot continue to be let unless the landlord has carried out the required improvements or registered a valid exemption.

The June announcement does not change that existing requirement.

What does the 1,000 square metre threshold mean?

This is one of the biggest changes from the previous proposals.

The Government's intention is now to concentrate the higher EPC B standard on privately rented buildings above 1,000 square metres.

That could include larger offices, warehouses, industrial units, retail premises and other substantial commercial buildings.

For landlords with properties below the threshold, there is currently no set deadline for moving beyond EPC E.

That does not necessarily mean energy efficiency improvements should be ignored. EPC ratings can still affect factors such as energy costs, the attractiveness of a property to prospective tenants and longer term asset planning.

However, it does remove the previous expectation that all qualifying commercial landlords needed to be working towards EPC B by 2030.

What happened to the EPC C target for 2027?

The proposed interim EPC C milestone has been dropped.

Under the previous plans, landlords would have been expected to achieve EPC C by 2027 before the eventual move towards EPC B.

The Government has said that removing this milestone will give landlords and tenants more time to improve their buildings in a way that works with individual properties, investment plans and lease arrangements.

For larger buildings that are likely to fall within the proposed 2031 rules, however, this should not necessarily be viewed as a reason to delay.

Moving a commercial building several EPC bands can require significantly more work than carrying out a small number of straightforward improvements.

Understanding where a property currently sits can therefore make future planning considerably easier.

Will every building over 1,000 square metres have to reach EPC B?

The Government's current proposal is EPC B where cost effective.

Existing flexibility within the MEES system is also expected to remain, including the seven year payback test and exemptions where appropriate.

This is important because not every commercial building can reasonably or practically achieve the same level of energy efficiency.

Factors such as the age and construction of the building, heating and cooling systems, insulation, lighting and the cost of potential improvements can all affect what is achievable.

Further detail on how the 1,000 square metre threshold and the new requirements will work is expected when the Government publishes its full response and brings forward the necessary legislation.

What should commercial landlords do now?

For landlords of larger commercial properties, 2031 may sound some way off, but there is value in understanding the current energy performance of a building well before any new deadline arrives.

An up to date Commercial EPC can establish the property's current rating and provide recommendations for potential improvements.

For landlords with portfolios, it can also help identify which buildings may require greater attention if the proposed EPC B standard becomes law.

If an EPC is approaching expiry, a property has undergone alterations, or major refurbishment work is being considered, it can be particularly useful to look at energy performance as part of that wider planning.

The direction has changed, but energy efficiency is still firmly on the agenda

The Government has stepped away from the previous approach of moving the wider non-domestic private rented sector towards EPC B by 2030.

Instead, the proposed higher standard will focus on buildings over 1,000 square metres, with a new target date of 2031.

For many smaller commercial landlords, that will reduce some of the immediate pressure created by the previous proposals.

For owners of larger properties, however, there is now a clearer indication of where regulation is heading.

Essential Green Skills provides Commercial Energy Performance Certificates for non-domestic properties. If you are unsure of your property's current EPC position or need a new Commercial EPC, our team can help.