What every landlord should know
- Since April 2023, most commercial property must be EPC E or better to continue being let.
- Government proposals point to EPC C by 2027 and EPC B by 2030 for commercial stock (timelines can change).
- A large share of stock sits below C today — the upgrade cliff is real, and worst for older buildings.
- Plan works now — EPCs age, and a poor rating hits value, lettability and rent long before any deadline.
What MEES actually requires today
Minimum Energy Efficiency Standards (MEES) already bite. Since April 2023 it has been unlawful to continue letting most commercial property with an EPC below E, extending an earlier rule that applied to new lettings. In practice that means an F or G-rated building can't be let without a valid, registered exemption.
The exemptions register matters: certain works that aren't cost-effective, or that would devalue the property, can be registered — but exemptions are time-limited and evidence-based, not a way to opt out indefinitely.
What's coming: EPC C by 2027, B by 2030
The direction of travel is clear even where the detail isn't. Government proposals have set out a path toward requiring EPC C by 2027 and EPC B by 2030 for commercial (non-domestic) property. Exact dates and thresholds have moved during consultation, so treat the years as planning signals rather than fixed law.
My advice to landlords is not to wait for certainty. Even on a cautious reading, the standard is heading up, and the cost of upgrading is lowest when it's folded into a refurbishment or a lease event you're doing anyway.
The scale of the challenge
A significant proportion of UK commercial buildings currently sit below EPC C — the older, secondary stock most exposed. For those owners, the gap to a future C or B standard can be substantial, and leaving it to the last minute risks void periods, rushed works and weaker negotiating positions.
It also increasingly shows up in value. Buyers and occupiers now price EPC risk directly, so a poor rating discounts the asset well before any legal deadline forces the issue.
What upgrades actually move the rating
The biggest, most reliable gains usually come from LED lighting with good controls, improved insulation, upgrading heating (heat pumps where feasible), a building management system, and better glazing — often topped up with on-site renewables such as rooftop solar. The right mix depends on the building, so a proper assessment beats guesswork.
The smart approach is to time works to lease events and planned refurbishments, model the rating uplift before you spend, and prioritise the measures with the best return per EPC point.
A landlord's action plan
I give owners a simple five-step plan: audit your current EPCs and their expiry dates; model the gap to a C and a B; phase works to lease events and refurbishments; register valid exemptions where they genuinely apply; and factor EPC risk into every acquisition and disposal from now on.
Here's a quick way to read where each building sits today and under the proposed changes.
| EPC band | Can you let it today? | Under proposed 2027–2030 changes |
|---|---|---|
| A–B | Yes | Future-proof |
| C–D | Yes | At risk from 2027–2030 |
| E | Yes (minimum) | Likely non-compliant |
| F–G | No (unless exempt) | No |
This article is general information, not legal, compliance or financial advice. MEES rules and timelines change — always check the current regulations and take professional advice before acting.
JHJordan advises commercial landlords across Greater Manchester and the North West on lettability, repositioning and energy-standard risk. Want a view on your portfolio's EPC exposure? He's happy to talk it through — no obligation.
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