Commercial EPC and MEES: The Minimum E Rating Rule for Letting (2026)

If you let commercial property in England or Wales, MEES is the rule that decides whether you can put a tenant in at all. It's easy to treat the EPC as a box-ticking formality for the marketing particulars. It isn't. Since April 2023 the certificate has had teeth, because letting a sub-standard building is now unlawful and the penalties are serious. Here's exactly what MEES requires, the dates that matter, and where the minimum is heading next.

What MEES actually is

MEES stands for Minimum Energy Efficiency Standards. It comes from the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, and it sets a floor: the lowest EPC rating a privately rented property is allowed to have and still be let.

For commercial (non-domestic) property, that floor is currently an EPC E. If your building is rated F or G, it is "sub-standard" for MEES purposes, and letting it is restricted unless you either improve it or register a valid exemption. The EPC is no longer just a document you hand over. It's the thing that decides whether you have a lettable asset.

This is general information, not legal advice. MEES has specific exceptions and the detail depends on your property and lease.

The two dates that changed everything

There are two milestones every commercial landlord should know, because they widened MEES from a problem at letting to a problem all the time:

• 1 April 2018. From this date you could not grant a new lease (or renew one) on a commercial property rated F or G. If you weren't re-letting, an old sub-standard building could keep running.
• 1 April 2023. This is the big one. From this date it became unlawful to continue to let a sub-standard commercial property, even on an existing lease signed years earlier. There is no longer a "we'll deal with it at renewal" option.

In other words, since April 2023 the obligation bites on your whole let portfolio, not just the units you happen to be re-marketing. The GOV.UK landlord guidance sets out the position in full.

The current minimum, in plain terms

Right now, to let a commercial property lawfully you need a valid EPC of E or better, unless a registered exemption applies. F and G are out. That's the whole rule in a sentence, but two things trip people up.

First, "valid EPC" means a current one. An EPC lasts ten years, so a rating from 2014 may already have lapsed. Second, the rating on an old certificate may not reflect the building today: methodology and benchmarks change, and a property that scraped an E years ago can slip. If you're relying on an old E, it's worth checking.

What's changing: EPC B by 2031

The E minimum is not the end of the story. After several years of consultation, in June 2026 the government published its interim response confirming the direction for non-domestic MEES:

• From 2031, privately rented commercial buildings over 1,000 square metres will need to reach EPC B, where that is cost-effective.
• Buildings under 1,000 square metres stay on the current EPC E minimum for now.
• The previously floated interim EPC C milestone for 2027 will not be taken forward.

This still needs to pass into legislation, and a cost-effectiveness test and exemptions will apply. But the direction is clear and it's the one landlords should plan around: the bar rises, and it rises furthest for larger premises. Reaching a B from a low E is a serious programme of work, not a weekend job, which is exactly why knowing your number early matters.

The penalties for getting it wrong

MEES is enforced by local authorities, and the penalties are calculated on the property's rateable value. For a commercial property let in breach for three months or more, the financial penalty can reach £150,000 per property. There is also a publication penalty: the breach can be published on a public register, which is its own reputational cost.

Set against a penalty on that scale, and the risk of a building you simply cannot let, the cost of an assessment and a sensible improvement plan is small. That's the calculation MEES forces, and it's why it can't sit at the bottom of the to-do list.

Does MEES apply to your property?

MEES applies to most privately rented non-domestic property in England and Wales, but not everything. Some lettings fall outside it, for example very short lettings and very long ones, and some buildings don't require an EPC at all (certain places of worship, some temporary or stand-alone buildings, and specific industrial or agricultural cases). Listed and heritage buildings are a special case: they may be exempt where the improvements needed would unacceptably alter their character, but this is not automatic and needs checking.

The safe assumption for a standard office, shop, warehouse or mixed-use unit is that MEES does apply. If you think you're an exception, confirm it rather than assume it, because getting that wrong is expensive.

What to do now

1. Find your current rating. Look the property up on Find an energy certificate, or commission a fresh EPC if there's no valid one.
2. If you're an E, don't relax. Check when it expires and whether the rating still holds. A marginal E is worth improving before the B trajectory arrives.
3. If you're an F or G, act. Get an assessor to identify the most cost-effective route to an E now, and towards a B if you hold larger premises. If genuine barriers exist, look at whether an exemption applies and register it.
4. Plan across the portfolio. Sequence works so several buildings don't all hit a wall in the same year.

Getting the right assessor

Confirming a rating and planning improvements is a job for an accredited non-domestic energy assessor, many of whom are also chartered surveyors. ComSurv matches you with accredited assessors who cover your area and building type, and you can look up a firm's regulation via RICS Find a Surveyor. Compare no-obligation quotes before you commit.

Sources & further reading

• Non-domestic private rented property: minimum energy efficiency standard (GOV.UK landlord guidance) — the official landlord guidance on non-domestic MEES
• The Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 — the MEES regulations in full
• Non-domestic MEES: interim response (GOV.UK, June 2026) — the confirmed direction of travel: EPC B by 2031 for larger buildings
• Find an energy certificate (GOV.UK) — look up an existing EPC
• RICS Find a Surveyor — find RICS-regulated professionals

External links open in a new tab. ComSurv is a matching service, not a firm of surveyors, and is not affiliated with these organisations. This article is general information, not legal, surveying or valuation advice; take advice on your specific situation.