MEES regulations 2026: what commercial landlords must do now, and by 2031

MEES and commercial EPCs: the facts in 30 seconds

MEES regulations: what changed on 18 June 2026

For five years, commercial landlords planned around a trajectory of EPC C by 2027 and EPC B by 2030. The 2020 Energy white paper had confirmed EPC B by 2030 as the target, and the 2021 consultation floated an interim C step. On 18 June 2026 the government published an interim response that rewrites that plan. In its own words, the government "is confirming its intention to implement the following":

• "from 2031, it is proposed that all private rented buildings over 1,000 square metres in England and Wales will need to reach a higher standard of energy efficiency of EPC B, where cost effective"
• "the intention is for buildings below 1,000 square metres to continue to be subject to the current minimum standard of EPC E"
• "the previously proposed interim EPC C milestone for 2027 will not be taken forward"
• "existing flexibility mechanisms, including the 7-year payback test and exemptions, will remain in place"

And the catch: "The changes to raise MEES to EPC B for larger buildings will only take effect following the successful passage of secondary legislation through Parliament." Further detail, including how the 1,000 square metre threshold will be measured, is promised in a full government response. For smaller properties the government says there is "no set deadline for going beyond this level".

What MEES means for your commercial property: by building size and lease

Find your row. Floor areas are the useful floor area of the building as the rules will define it; the government has said it will set out how the threshold works in its full response.

Based on GOV.UK's non-domestic MEES landlord guidance (updated 5 May 2026) and the interim response of 18 June 2026. The EPC B proposal is not yet law.

MEES for commercial property today: the EPC E rule

The minimum energy efficiency standards come from the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015. For commercial property they have worked in two stages:

1. From 1 April 2018: landlords could only grant a new tenancy, or extend or renew one, if the property had at least an EPC E, unless a valid exemption was registered.
2. From 1 April 2023: the same rule applies to all privately rented non-domestic property, even where there has been no change of tenancy.

The regulations cover non-domestic rented property that is legally required to have an EPC. GOV.UK's rule of thumb: if the property has been marketed for sale or let, or modified, in the past 10 years, it probably needs one. They don't apply to tenancies with a term certain of 6 months or less (with conditions) or of 99 years or more.

The test is the EPC rating, not your actual bills. A building with low real-world energy use can still fail on its certificate, and a fresh assessment after upgrades is the only way to prove a better rating. Check your current certificate on the GOV.UK EPC register.

MEES penalties: how much a breach can cost

MEES is enforced by Local Weights and Measures Authorities (trading standards). They can serve a compliance notice up to 12 months after a suspected breach, asking for the EPC, the lease, details of works and any energy advice report. Fines are set by regulation 41 of the 2015 regulations:

The "publication penalty" means details of the breach go on the public register. Anyone, including your tenants, buyers and lenders, can search it for exempt properties and penalties issued to non-compliant landlords. For an institutional landlord, that can hurt more than the fine.

MEES exemptions and the PRS Exemptions Register

If you can't reach EPC E, you can only keep letting if a valid exemption applies and you have registered it on the Private Rented Sector (PRS) Exemptions Register. Registration is self-certified, and the exemption only applies from the moment you register it. There are six types:

• Exemptions don't travel. If you sell a let property, the exemption stops working and the new owner must upgrade or register their own.
• They expire. After 5 years you have to try again to reach E, then register a fresh exemption if you still can't.
• How to register: sign in with One Login, enter the address, choose the exemption and upload the evidence on the GOV.UK PRS Exemptions Register. GOV.UK's assisted digital helpline is 0800 098 7950.

The 7-year payback test is the one that matters most for upgrade planning, and it survives the June 2026 changes. That cuts both ways: it protects you from uneconomic works, but it also means cheap, fast-payback measures such as lighting and controls will almost always be expected.

EPCs for commercial property: when you need one and what it costs to skip it

A commercial EPC rates the building from A (most efficient) to G. Separate from MEES, you must have an EPC for commercial property when you:

• sell or rent out the premises
• finish a building under construction
• change the number of parts used for separate occupation, where that involves providing or extending fixed heating, air conditioning or mechanical ventilation

If you don't make an EPC available to a prospective buyer or tenant, you can be fined £500 to £5,000, based on the building's rateable value. All EPCs are valid for 10 years. You must display the EPC in the building if the useful floor area is over 500 square metres, the building is frequently visited by the public, and an EPC has already been produced for its sale, rental or construction.

Some buildings don't need an EPC at all, including listed or officially protected buildings where the energy requirements would unacceptably alter them, temporary buildings used for 2 years or less, places of worship, low-energy industrial sites, workshops and non-residential agricultural buildings, detached buildings under 50 square metres, and buildings due for demolition with the consents in place.

Your commercial EPC rating is produced by an accredited non-domestic energy assessor, and it comes with recommendations for improving the building. That report is your starting point for any MEES plan, because it is what the 7-year payback test and the "all improvements made" exemption work from.

Which upgrades lift a commercial EPC rating?

Every building is different, so start with your EPC's recommendations and ask the assessor to model a package before you spend anything. These are the measures that come up most often on commercial buildings, and the money that can help pay for them:

On business rates: In England, plant and machinery used to generate or store power from on-site renewables (solar included, and batteries where the power stored is mainly or exclusively renewable) is excluded from rateable value until 1 April 2035. Wales (from 1 April 2024) and Scotland (from 1 April 2023) have equivalent exemptions running to 2035. Adding panels to your roof shouldn't raise your rates bill. For every route to funding, from tax allowances to the Boiler Upgrade Scheme and regional loans, see our business energy grants guide.

Scotland, Wales and Northern Ireland

• Wales: the MEES regulations cover England and Wales, so everything on this page applies, including the June 2026 proposals.
• Scotland: MEES doesn't apply. Under Scotland's own Assessment of Energy Performance of Non-domestic Buildings (Scotland) Regulations 2016, owners selling or letting a non-domestic building over 1,000 square metres must make an action plan for the building available.
• Northern Ireland: MEES doesn't apply. EPCs are still needed when a building is built or marketed for sale or rent, they last 10 years, and district councils enforce the rules.

Your MEES checklist: what to prepare now

1. Pull every EPC. Look up each property on the EPC register. Note the rating, the date it expires and the floor area.
2. Flag F and G lets first. If any are let without a registered exemption, that's a live breach. Fix those before anything else.
3. Sort the estate by size. Separate buildings over 1,000 square metres from smaller ones. The big ones carry the 2031 risk.
4. Map lease events against 2031. Breaks, expiries and renewals are your windows for works with the least disruption.
5. Get an upgrade model. Ask an assessor to model the route from your current rating to E (or B for large buildings) and cost each step, so you can apply the 7-year payback test honestly.
6. Get real quotes for the big items. You'll need 3 quotes anyway to register a 7-year payback exemption. Heat pumps and solar usually need a site survey.
7. Line up the money. Check the Annual Investment Allowance, the Boiler Upgrade Scheme and any regional loans before you commit. Talk to your accountant about timing.

When you're ready to price the heavy-lifting measures, we'll pass your enquiry to one suitable commercial installer. You won't be passed round a list or sold on.