Separately, qualifying privately rented non-domestic premises generally need at least EPC E unless a valid exemption applies. The proposed higher standard for larger buildings is not yet the current rental rule. [1][2][3]
When is a commercial EPC needed?
GOV.UK identifies selling, renting and completing construction as circumstances requiring an EPC, subject to the relevant exceptions. Certain changes creating separately usable accommodation and involving fixed heating, air conditioning or mechanical ventilation can also trigger the requirement. Check the proposed works and occupation arrangement rather than assuming that every existing certificate covers the altered property. [1]
An EPC rates the building from A to G and is normally valid for ten years. It must be produced by an appropriately accredited assessor for the type of property. The certificate and recommendation report are useful inputs to an upgrade brief, but do not themselves grant building regulations or planning approval. [1][4]
The current minimum rental standard
The minimum energy efficiency standards, or MEES, apply to qualifying non-domestic private rented property that is required to have an EPC. From 1 April 2018, the rules restricted granting, renewing or extending relevant tenancies of substandard property. From 1 April 2023, they also apply to continuing to let qualifying property. [2]
The current minimum is EPC E. A landlord with an F- or G-rated property must address the applicable improvement requirements or establish and register an available exemption before relying on it. A tenant agreeing to accept the building does not itself create an exemption. [2]
An owner-occupied commercial building is not automatically subject to the private-rental restriction. It may nevertheless need an EPC on sale or in other circumstances covered by the certificate rules. Keep the two questions separate. [1][2]
Improvements and exemptions
The non-domestic rules include a seven-year payback test and defined exemptions, supported by evidence and registration requirements. Do not import a domestic-landlord cost cap into a commercial assessment: follow the non-domestic guidance for the property and proposed measures. [2]
Protected or listed status is not a blanket exemption from EPC requirements. The relevant exception concerns cases where compliance with particular minimum energy performance requirements would unacceptably alter the building's character or appearance. A heritage label alone does not settle the question. [1][2]
Before committing to works, coordinate the assessor's proposals with the building's fabric, services and any permissions needed for alterations. Retain the evidence supporting the chosen compliance or exemption route. [2][4]
What changed in the government's June 2026 proposals?
The interim response published on 18 June 2026 proposes EPC B from 2031 for privately rented non-domestic buildings over 1,000 m² where cost-effective. It proposes retaining EPC E below that threshold and says the previously proposed EPC C milestone for 2027 will not proceed. [3]
These higher requirements depend on secondary legislation. The precise operation of the size threshold and further implementation detail remain to be published. Until the legislation and final details are published, 2031 is a proposed timetable rather than an enacted deadline. The treatment of a building exactly at the size threshold also needs confirmation. [3]