This guide records the position reviewed on 25 July 2026. It is a practical scoping note, not legal advice, and should be rechecked as the government publishes its full response and legislation.
Minimum Energy Efficiency Standards affect certain privately rented non-domestic properties in England and Wales. Use the current minimum to check the present position and keep proposed changes separate in any longer-term plan.
The current minimum remains EPC E
Current government landlord guidance states that relevant privately rented non-domestic properties must generally have at least an EPC E unless a valid exemption applies. The requirement has applied to all relevant continuing lettings since 1 April 2023, not only a new or renewed tenancy.
Whether a property is within scope, legally required to have an EPC or covered by an exemption is a property-specific legal question. An EPC assessment can provide a rating and recommendations; it does not by itself determine every aspect of MEES liability.
The June 2026 proposal is targeted
The government's interim response proposes that, from 2031, private rented non-domestic buildings over 1,000 m² in England and Wales should reach EPC B where cost-effective. It says buildings below 1,000 m² would continue to be subject to the current EPC E minimum.
This is not a blanket statement that every commercial building must be EPC B in 2031. Building size, private-rented status, EPC requirements, cost effectiveness and any applicable flexibility or exemption all matter.
The 2027 EPC C milestone was dropped
The interim response says the previously proposed EPC C milestone for 2027 will not be taken forward. Project briefs, asset plans and online guidance that still treat EPC C in 2027 as settled policy should be updated.
A landlord can still choose to improve a building earlier, and a lender, investor, occupier or corporate standard may set a stronger target. Those commercial requirements should be distinguished from the statutory minimum.
Secondary legislation is still required
Government states that the proposed EPC B change for larger buildings will take effect only after secondary legislation has passed through Parliament. Further detail on implementation and the 1,000 m² threshold is expected in a later response and updated guidance.
Treat the 2031 proposal as a planning assumption to watch, not as enacted law. Record the source date in any option appraisal so it can be revisited.
Use the EPC as a starting evidence set
For an existing building, start with the current EPC, recommendation report, floor area, tenancy position and evidence about fabric and fixed services. Check whether the certificate still represents the building and whether better evidence could replace defaults in a new assessment.
A rating exercise and an improvement plan are different commissions. Before promising a target, identify the measures that are technically feasible, how the EPC methodology represents them, their cost and disruption, and who is responsible under the lease.
Confirm the property position
Record the building area, use, tenancy, current EPC and known exemption position with the appropriate legal or property adviser.
Check the evidence
Review drawings, inspection records and fixed-services information before relying on an old rating or recommendation.
Model realistic options
Test feasible fabric, services, controls and renewable measures without assuming that every physical improvement changes the EPC in the same way.
Keep policy under review
Recheck the full government response, secondary legislation and updated landlord guidance before an investment or compliance deadline.
Frequently asked questions
Must every commercial building reach EPC B by 2031?
No. The June 2026 interim response proposes a targeted change for private rented non-domestic buildings over 1,000 m² in England and Wales, where cost-effective. It is not yet in force and does not describe every commercial building.
Is EPC C still required in 2027?
The government says the previously proposed 2027 EPC C milestone for non-domestic private rented property will not be taken forward.
Is the 2031 EPC B proposal already law?
No. The interim response states that the change would take effect only after secondary legislation has passed through Parliament.
Does an EPC prove that a landlord complies with MEES?
An EPC supplies important rating evidence, but scope, tenancy, exemptions and legal responsibility may also need review. Obtain property-specific legal advice where necessary.