
After years of regulatory limbo, the government has finally said what it intends to do with the minimum energy standard for commercial buildings, and the answer is narrower and later than the industry had been planning around. On 18 June 2026 the Department for Energy Security and Net Zero published its interim response to the long-running 2019 and 2021 consultations on non-domestic Minimum Energy Efficiency Standards. For landlords who had spent years bracing for one version of this, the confirmed version changes the maths — and the timing — of a lot of plant and fabric decisions.
The headline is straightforward. From 2031, privately rented non-domestic buildings over 1,000 square metres in England and Wales will be required to reach an EPC rating of B, where cost-effective. Buildings of 1,000 square metres or less stay at the current EPC E minimum, with no commitment to raise it. And the interim EPC C milestone that had been pencilled in for 2027, the one many landlords had been sequencing works around, has been dropped altogether.
Three things about that are worth drawing out, because the detail is where the planning decisions actually sit.
The first is the size threshold, which is a genuinely new dividing line. Non-domestic MEES has until now applied a single minimum standard across the whole let stock — most recently EPC E — and the new approach differentiates it by size. A landlord with a portfolio of larger buildings is now on a defined path to EPC B by 2031, while a landlord whose stock is mostly smaller units, high-street premises and SME space sits at EPC E with no announced escalation. That distinction matters for portfolio strategy, for how buildings are valued, and for where capital gets directed first. It also raises an obvious question at the margin, around what happens with a building close to the 1,000 square metre line, that the government has said will be clarified in the fuller response still to come.
The second is that the dropped 2027 milestone is a reprieve on timing, not on ambition. Removing the interim EPC C step gives landlords more runway, but the destination for larger buildings is still EPC B, and B is a demanding standard for existing commercial stock. A building sitting at D or E today does not get there on lighting and controls alone; for most, reaching B means engaging with the heating system, because how a building is heated is one of the largest single inputs into its EPC. The extra time is real, but it is time to plan a substantial upgrade, not time to ignore one.
The third is the part that does not change, and it is the part that protects landlords: the exemptions carry over. The seven-year payback test remains — if the energy efficiency improvements would not pay for themselves through energy savings within seven years, the building is not required to make them. So does the devaluation exemption, where improvements that would reduce a property's value by more than five per cent need not be carried out. The whole obligation is framed as EPC B "where cost-effective," and that phrase is doing real work: this is not a blanket demand that every large building hit B regardless of expense, but a requirement to make the improvements that genuinely stack up, and to register an exemption, properly evidenced, where they do not.
There is one important caveat over all of it. This is an interim response, not the final regime. The change takes effect only after secondary legislation passes through Parliament, and a fuller government response with the implementation detail — including exactly how the size threshold works — is still to come. The direction and the headline numbers are now confirmed and can be planned around, but the fine print is not yet law, and landlords should watch for the full response before treating every detail as fixed.
For a landlord or asset manager, the practical takeaways are about timing rather than panic. A larger building heading for a lease event, a refurbishment, or the end of its heating plant's life before 2031 should factor the EPC B target into that work now, because the cheapest time to improve a building's rating is when it is being worked on anyway, not as a standalone compliance scramble in 2030. The end of a boiler's life, in particular, is the natural moment to ask what the building's rating will need to be and whether the replacement plant moves it in the right direction, since heating is such a large component of the score. The government's own modelling puts the prize for tenants at around £360 million a year in energy savings across the largest rented buildings by 2031, which is a reminder that for a well-chosen upgrade the efficiency gain is not only a compliance cost but a running-cost saving that a tenant, or an owner-occupier, actually banks.
The buildings that meet 2031 comfortably will be the ones whose owners treated the June announcement as the moment to start sequencing the work into projects that were coming anyway. The ones that meet it expensively will be those that wait, and find themselves upgrading plant and fabric against a deadline instead of alongside a refurbishment.
Pleasant Plumbers' commercial team advises on the heating and hot water side of EPC and MEES improvement across London — assessing how a building's plant affects its rating and sequencing upgrades to meet the 2031 standard alongside work that was already due. To review where your buildings stand against the EPC B target, call or WhatsApp 0800 046 1000, or email [email protected].
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