Updated: 27 September 2026. Commercial landlords are seeing a major change in the direction of Minimum Energy Efficiency Standards (MEES). The most important point is that the previously proposed EPC C milestone for 2027 is no longer being taken forward. Instead, the government has set out an intention to move larger privately rented non-domestic buildings towards EPC B from 2031, subject to legislation and where improvements are cost-effective.
For London landlords, investors, asset managers and property managers, this creates a useful planning window—but it does not remove today’s obligations. The current minimum standard for relevant privately rented non-domestic property remains EPC E, unless a valid exemption applies.
MEES changes 2026: the position at a glance
| Issue | Position in September 2026 |
|---|---|
| Current minimum for relevant non-domestic rented property | EPC E, unless a valid exemption applies |
| Previously proposed 2027 milestone | EPC C milestone will not be taken forward |
| Government’s proposed future standard | EPC B from 2031 for privately rented non-domestic buildings over 1,000 m², where cost-effective |
| Buildings below 1,000 m² | Government intends these to remain subject to the current EPC E minimum |
| Legal status of the 2031 change | Not yet in force; secondary legislation is required |
| Existing flexibility | Government intends to retain mechanisms including the seven-year payback test and exemptions |
What changed in June 2026?
On 18 June 2026, the Department for Energy Security and Net Zero published an interim response on strengthening non-domestic MEES in England and Wales. The response changed the direction previously discussed in earlier consultations.
The government said it intends to require privately rented non-domestic buildings larger than 1,000 square metres to achieve EPC B from 2031, where this is cost-effective. It also said that buildings below 1,000 square metres are intended to continue under the current minimum EPC E standard.
Crucially, the previously proposed EPC C milestone for 2027 will not proceed. This gives landlords and tenants more time to plan improvements around leases, refurbishments and investment cycles instead of treating 2027 as a universal compliance deadline.
The government’s full interim response is available on GOV.UK.
What are the current MEES rules for commercial property?
For relevant privately rented non-domestic property in England and Wales, the current minimum level remains EPC E. Since 1 April 2023, the requirement has applied to continuing to let relevant non-domestic properties as well as granting, renewing or extending tenancies, unless the property is outside the scope of the regulations or a valid exemption applies.
Government guidance states that a privately rented non-domestic property that requires an EPC must generally have an EPC rating of E or above or a valid registered exemption. Landlords should not treat the proposed 2031 policy as a reason to ignore the existing rules.
You can review the current government landlord guidance on non-domestic private rented property MEES.
Does every commercial building need to reach EPC B by 2031?
No. That would overstate the government’s current position.
The June 2026 response sets out an intention for privately rented non-domestic buildings over 1,000 m² to reach EPC B from 2031 where cost-effective. The change has not yet taken legal effect and will require secondary legislation.
The same response states that buildings below 1,000 m² are intended to remain at the current EPC E minimum. Existing flexibility mechanisms, including the seven-year payback test and exemptions, are also intended to remain.
What does this mean for London commercial landlords?
For landlords with London offices, retail units, mixed commercial portfolios, industrial premises or other rented non-domestic assets, the practical message is to separate current compliance from future asset planning.
- Check current compliance first. Confirm whether each relevant property has a valid EPC and whether it meets the current EPC E minimum or has a valid exemption.
- Identify buildings over 1,000 m². These are the assets most directly affected by the government’s proposed 2031 direction.
- Do not plan around the old 2027 EPC C milestone. That milestone has been dropped.
- Use refurbishment cycles intelligently. If planned works could improve energy performance, assessing EPC implications early may reduce duplicated disruption and cost.
- Keep evidence. EPCs, recommendation reports, improvement records and exemption evidence can become important when demonstrating compliance.
- Monitor legislation. The 2031 EPC B proposal is a policy intention until the required secondary legislation is passed.
Why landlords should not wait until 2030
Even though the proposed EPC B requirement is not yet law, larger commercial assets often need long lead times for surveys, budgets, landlord-and-tenant coordination, mechanical or electrical upgrades and refurbishment planning.
A sensible approach is to use current EPC information as an asset-planning tool rather than treating the certificate as a last-minute administrative requirement. Where an EPC is approaching expiry, a building is being refurbished, or a lease event is approaching, it may be useful to review likely future energy-performance implications at the same time.
What about MEES exemptions?
MEES includes exemptions in specified circumstances. Government guidance also provides a register for private rented sector energy-standard exemptions. The June 2026 interim response says the government intends to retain existing flexibility mechanisms, including the seven-year payback test and exemptions.
An exemption should not be assumed simply because improvement work appears difficult or expensive. The exemption must fit the applicable criteria and, where required, be properly registered with supporting evidence. The government provides a PRS exemptions service and a searchable exemptions and penalties register.
How Primelinks Solutions can support EPC and MEES planning
Primelinks Solutions helps landlords, property managers and commercial property stakeholders coordinate property-compliance requirements across London. If you need to review the EPC position of a property or understand which energy-performance service is appropriate, start with our EPC service.
- For MEES-specific support, see our EPC service.
- For a commercial certificate requirement, see EPC service.
- For a broader explanation, read our EPC & MEES Guide.
- For London coverage, see our London coverage page.
Frequently asked questions
Is EPC C still required for commercial property in 2027?
No. The government confirmed in June 2026 that the previously proposed interim EPC C milestone for 2027 will not be taken forward for the non-domestic private rented sector.
What is the current minimum EPC rating for rented commercial property?
For relevant privately rented non-domestic property in England and Wales, the current minimum is generally EPC E unless a valid exemption applies.
When is EPC B proposed to apply?
The government intends to introduce EPC B from 2031 for privately rented non-domestic buildings over 1,000 m² where cost-effective. This remains subject to secondary legislation.
Will smaller commercial properties also need EPC B?
The June 2026 interim response says buildings below 1,000 m² are intended to remain subject to the current EPC E minimum.
Next step
If you manage a commercial property or portfolio in London and want to review its EPC or MEES position, use our Get a Quote route and provide the property address, approximate floor area, current EPC details if available and any upcoming lease or refurbishment dates.
This article provides general information and should not be treated as legal advice. Regulatory requirements can depend on the property, tenancy and circumstances.