The short answer
The minimum energy efficiency standards (MEES) make it unlawful in England and Wales to let most privately rented commercial property with an EPC rating below E unless a valid exemption is registered. The rule has covered new lettings since 1 April 2018 and all continuing lettings since 1 April 2023. [1, 2]
If you have a tenant trading beneath an old roof and a lease date coming up, the useful question is what to do next. Start with the EPC, its recommendations and the tenancy. Then decide which improvements belong in the programme and what evidence you need to retain. A proposed future standard belongs in that planning exercise; it does not replace today's rule.
This guide covers non-domestic privately rented property. For homes, use the government's domestic landlord guidance. Take independent advice on your lease and any exemption you intend to use. [1]
01What MEES requires
What MEES requires today
First, separate the certificate from the minimum standard. An EPC gives the building a rating. MEES controls whether a covered property can be let with that rating. An F or G certificate identifies a sub-standard building; obtaining the certificate does not, by itself, resolve the letting restriction. [1, 2]
For covered commercial lettings, the current minimum is E. Since 1 April 2018, that has applied when granting a new tenancy or renewing or extending an existing one. Since 1 April 2023, it has also applied when continuing to let, even if no new lease event occurs. A valid registered exemption is the alternative route where its conditions are met. [1, 2]
| Date | What it means for the commercial landlord |
|---|---|
| 1 April 2018 | The E minimum applies to covered new, renewed and extended lettings. |
| 1 April 2023 | The E minimum also applies to continuing covered lettings. |
| 18 June 2026 | Government publishes an interim response on strengthening non-domestic MEES. |
| 2031, proposed | EPC B for private rented buildings over 1,000 m², where cost-effective. This needs secondary legislation. |
Sources: regulations and government guidance, checked 14 October 2026. [1, 2, 4]
If a property is empty and you are not planning to let it, the government guidance says you do not need to improve its rating until you decide to let it again. That gives you a planning window, not a reason to leave the question until a prospective tenant wants the keys. [1]
02Which lettings are covered
Which commercial lettings are covered?
Before pricing improvements, establish whether this rule applies to the letting. The starting points are a non-domestic property, a legal requirement for an EPC and a relevant tenancy. The usual scope is a term certain of more than six months and less than 99 years. [1]
The short-lease exclusion has qualifications. A tenancy of six months or less can still be covered where it provides for renewal or extension beyond six months, or the tenant has already occupied continuously for more than 12 months when it is granted. Tenancies with a term certain of 99 years or more are excluded. Read the actual agreement rather than deciding from the label on the lease. [1]
| Check | What to establish |
|---|---|
| Building | It is non-domestic, rather than a dwelling. |
| EPC requirement | The property is legally required to have a certificate. |
| Tenancy | The term and any renewal provisions bring it within scope. |
| Current rating | E or above, or F/G needing action or a valid exemption. |
| Floor area | Relevant to planning around the June 2026 proposal, not a new exemption from today's E rule. |
An EPC exemption and a MEES exemption are different questions. A property outside the legal EPC requirement can fall outside MEES scope; a covered F/G property needs the appropriate registered MEES exemption if it is to be let without reaching E. Our EPC requirements for commercial property guide handles the certificate question in detail. [1]
03Exemptions and the Register
Exemptions and the PRS Exemptions Register
An exemption, from route to expiry
- 01Choose the routeOne of the six routes below, with the evidence it requires. A contractor's opinion that work is expensive is not enough.
- 02Register before you rely on itRegistration is self certification. The landlord remains responsible for meeting the exemption's conditions.
- 03Diary the expiryFive years for most routes; six months from becoming the landlord for the new-landlord route; a tenant-consent exemption can end earlier.
- 04At expiry, or a change of landlordReassess improvement to E or register another valid exemption. An exemption does not carry over to a new landlord.
Once you know the property is covered, an exemption needs a reason and a file to support it. A contractor's opinion that work is expensive is not enough. The government sets out specific routes, evidence requirements and expiry periods. Register the exemption before relying on it. [1]
| Route | Evidence to retain and upload | Duration |
|---|---|---|
| Seven-year payback | Three quotations for the recommended improvement and the calculation showing it fails the seven-year test. | Five years. |
| All relevant improvements made | Evidence of the measures installed, or a report showing no relevant improvements can be made, while the property remains below E. | Five years. |
| Wall insulation | Written expert advice that the recommended wall insulation would harm the fabric or structure, where wall insulation is the only relevant improvement left. | Five years. |
| Third-party consent | Correspondence showing consent was sought but refused, or offered on unreasonable conditions. | Five years; a tenant-consent exemption ends earlier if that tenancy ends or is assigned. |
| Property devaluation | An independent RICS registered valuer's report showing relevant measures would reduce market value by more than 5%. | Five years. |
| Recently becoming a landlord | Evidence of the date and qualifying circumstances set out in the guidance. | Six months from becoming the landlord. |
Source: government non-domestic landlord guidance, checked 14 October 2026. [1]
The seven-year test compares the cost of buying and installing the recommended measure or package with the expected energy-bill savings over seven years. It is the MEES cost-effectiveness test. Do not substitute a general return-on-investment estimate, or a Part L calculation, for the evidence that this route requires. [1]
A low installation price does not prove that a measure passes the test, either. The relevant energy savings and package of improvements still need assessing. When we supply a roof price and U-value calculation, those are inputs your advisers can use. They do not decide the exemption for you.
Use the PRS Exemptions Register and keep copies of the material submitted. Registration is self certification, so the landlord remains responsible for meeting the exemption's conditions. An entry is not a government approval of your reasoning. [1, 5]
Also put its expiry date in the property file. Once the exemption expires, you need to reassess improvement to E or register another valid exemption. If the property changes owner or landlord, the existing exemption does not carry over. The new landlord must improve the property or register an applicable exemption in their own right. [1]
04Enforcement and penalties
Enforcement and penalties
The next reason to keep an orderly file is enforcement. Local weights and measures authorities enforce non-domestic MEES. They can request the EPC, tenancy agreement, improvement information and other relevant records through a compliance notice, including up to 12 months after a suspected breach. [1]
The penalties below are the commercial figures from regulation 41. They are maxima, not automatic fixed fines. Domestic MEES has a different penalty provision and those figures do not belong in a commercial budget. [3]
| Non-domestic breach | Maximum financial penalty | Publication |
|---|---|---|
| Letting in breach for less than three months | The greater of £5,000 or 10% of rateable value, capped at £50,000. | The authority may also impose a publication penalty. |
| Letting in breach for three months or more | The greater of £10,000 or 20% of rateable value, capped at £150,000. | The authority may also impose a publication penalty. |
| False or misleading Exemptions Register information, or failure to comply with a compliance notice | Up to £5,000. | The authority may also impose a publication penalty. |
Source: SI 2015/962, regulation 41, current revised text, checked 14 October 2026. [3]
If a notice arrives, work from the documents and the stated response requirements. Bring in your adviser, locate the EPC that applied when the property was let, and gather the tenancy and improvement records. A new contractor quotation will not explain what happened during an earlier letting period.
05The June 2026 proposal
The June 2026 interim response: proposed EPC B from 2031
With today's position clear, you can look ahead without treating a proposal as an enacted duty. The government's interim response of 18 June 2026 proposes EPC B from 2031 for private rented buildings over 1,000 m² where cost effective, subject to secondary legislation, and a full government response is still awaited. [4]
The intention is for buildings below 1,000 m² to remain subject to the current E minimum. The previously proposed interim C milestone for 2027 is not being taken forward. Existing flexibility mechanisms, including the seven-year payback test and exemptions, are intended to remain. The changes take effect only after secondary legislation passes. [4]
Key dates for the commercial landlord
Checked 14 October 2026For a larger building, that is a reason to plan improvements together. If a roof project, lighting replacement and heating work are all in the asset plan, ask the assessor to consider the combined sequence before you commission them separately. You want each expenditure to contribute to the intended building outcome.
The response says further detail on implementing the threshold will follow. Keep a dated record of the official position and review it as legislation and guidance develop. A headline about 2031 does not settle every question about a multi-let building, its assessment boundaries or your particular lease. [4]
06EPC B by 2030?
Is EPC B required by 2030?
No current commercial MEES duty requires every covered building to reach B by 2030. As checked on 14 October 2026, the current minimum remains E, subject to a valid exemption. The government's interim response of 18 June 2026 proposes EPC B from 2031 for private rented buildings over 1,000 m² where cost effective, subject to secondary legislation, and a full government response is still awaited. [1, 4]
Use that distinction when talking to tenants and approving budgets. “We are planning for the proposed higher standard” accurately describes future work. It does not turn a proposed date into a current legal deadline.
It does not turn a proposed date into a current legal deadline.
07Where the roof comes in
Where the building fabric and roof come in
Once the assessor has identified the improvements worth making, the roof becomes a practical construction question. What is there now? Is it sound? How much insulation can the build-up accommodate? Can the work be phased around the tenant? Those answers determine the specification and the programme.
A U-value describes heat transfer through a building element. The EPC assesses the building more widely. Improving the roof fabric gives the assessor better-performing construction to include, but a roof U-value is not an EPC band and a single insulation measure does not establish MEES compliance. See the roof's U-value for your EPC assessor.
On our 2,340 m² asbestos-cement roof project, 50 mm closed-cell foam was applied below sheets that stayed in place. The calculated treated-roof U-value was about 0.53 W/m²K. The customer reported that underside condensation was mitigated. That calculation belongs to that roof build-up; it is not an EPC result.
HOLVEM does not test for asbestos or replace roof sheets, and never removes asbestos sheets. If the roof is safe to keep, we encapsulate it; if not, removal is a job for asbestos removal professionals, licensed where HSE requires it.
At the Midlands distribution warehouse, we applied 75 mm closed-cell foam below the corrugated metal roof, bay by bay, while the building remained open. The client reported a substantial fall in energy use and cost. It demonstrates a working programme around an occupied building, without giving your building a promised saving or rating.
Ask for the proposed build-up, its U-value calculation, the condensation risk analysis and the handover evidence. This gives the assessor a documented construction rather than an assumption, and gives your surveyor a record of what was specified and installed.
08The action order
A landlord's action order
Bring those strands together before asking anyone to price a material. You will get a more useful answer if the team sees the same EPC, lease dates and building information from the outset.
- Locate the current EPC and recommendation report. Establish the scope of the commercial letting with your adviser.
- If the rating is F or G, decide the improvement or exemption route against the current rules and required evidence.
- Record the floor area and lease dates so future planning uses the correct building and timetable.
- Ask the assessor to review the measures as a package, then obtain specifications and comparable quotations.
- Plan access and work areas with the tenant. Separate construction decisions from the legal decision to let.
- Retain the calculations, installation evidence and any Register submission. Diary the next review and exemption expiry.
For the roof part, send photographs or drawings for a free estimate, no survey needed. Clear photographs often let us return that estimate the same day. A virtual survey lets us measure and check the roof remotely using aerial imagery alongside your material. Straightforward jobs are confirmed on install; larger or complex jobs receive a free survey and then a firm written quote. There is no obligation either way.
