MEES - EPC B by 2031 for commercial buildings over 1,000 m²

On 18 June 2026, the government published an interim response to the 2019 and 2021 consultations on increasing the future trajectory for minimum energy efficiency standards (MEES) for commercial property in England and Wales.

The headline announcement is that a standard of EPC B will be required by 2031 for commercial buildings over 1,000 square metres, where it is cost effective.

A quick recap…

In short, MEES makes it unlawful for landlords of certain commercial properties which have an Energy Performance Certificate (EPC) rating of F or G to let or continue to let a property, unless all the relevant energy efficiency improvements for the property have been made (and the property remains sub-standard) or one of the specified exemptions applies, and a landlord has successfully registered this on the PRS Exemptions Register.

A 2020 energy white paper published by the Conservative government set out that the future trajectory for MEES in relation to commercial property would be EPC band B by 2030. A 2021 consultation on implementing this policy then followed. However, since then, despite repeated industry calls for clarity, there has been no further official government guidance on MEES in relation to commercial property - until now.

What does the government’s interim response say?

The government has published an interim response confirming:

• From 2031, 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.
• Buildings below 1,000 square metres will continue to be subject to the current minimum standard of EPC E. In relation to buildings below 1,000 square metres the government states ‘we are giving additional flexibility to SMEs and high street landlords of smaller properties to upgrade their buildings over time, with no set deadline for going beyond this level’.
• The previously proposed interim EPC C milestone for 2027 will not be taken forward (this is unsurprising given we are part way through the compliance window which was proposed by the government in relation to this measure).
• The 7-year payback test and existing exemptions will remain in place.

Secondary legislation will be required to implement the increase to EPC B for larger buildings.

In its interim response, the government states that ‘[t]his targeted approach focuses action where it delivers the greatest benefits’ and it will help tenants in the largest rented buildings save energy and reduce their bills. It also states that the measures are expected to reduce energy demand which will strengthen energy security and cut carbon emissions.

What next?

In the interim response the government notes that ‘[f]urther detail on these proposals and implementation of the threshold will be set out in the forthcoming government response to the public consultations. The government aims to introduce legislation and updated guidance at the earliest opportunity, working with stakeholders to get the detail right’.

What else is happening?

The government ran a separate consultation on ‘Reforms to the Energy Performance of Buildings regime’ in December 2024 in which it considered the design of commercial EPCs. The government published a partial response to this consultation in March 2026 and concluded that it would maintain the single carbon-based Environmental Impact Rating (EIR) as the headline metric for commercial EPCs. In its partial response to this consultation, the government also concluded that it plans to maintain the 10 year validity period for EPCs. Of practical relevance, regulations will be updated so that an EPC is required at the point of marketing a property, rather than the point of sale or rent and all heritage buildings will be required to have an EPC.

Comment

Given we are part way through the first compliance window which was proposed in the 2021 consultation, it is not surprising that timeframes and targets have moved from the original proposals and some certainty in this area is likely to be welcomed by the property industry. However, there may be some frustration that, given the delays, a full response to the consultation and a time frame for legislation and updated guidance is still awaited.

It is also worth noting that at the same time the Conservative government published its 2021 consultation on increasing the trajectory for commercial EPCs, it also published a consultation on a new policy framework for measuring and assessing the energy performance of commercial and industrial buildings larger than 1,000m² in England and Wales. This was focussed on introducing a performance based ratings system that could measure and assess building performance and was intended to complement the original MEES target of EPC B by 2030, with the government noting in this consultation that ‘[i]n large and complex buildings in particular, there is almost no correlation between a building's EPC score and its actual energy and carbon performance in practice’. It will be interesting to see if the government’s interim response in relation to EPCs for commercial buildings is a first step in producing a detailed set of policies in this area in relation to commercial buildings.