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Commercial property · England and Wales

MEES: minimum energy efficiency standards for commercial property

A landlord in England or Wales may not let commercial property whose valid EPC is below band E, unless an exemption is registered first.

The ban has covered new lets since 1 April 2018 and every continuing let since 1 April 2023.

EPC C by 2027 has been dropped, and EPC B from 2031 for larger buildings is a proposal, not law.

What it covers

What is MEES for commercial property?

A ban on letting a non-domestic property with a valid EPC below band E, in England and Wales, without a registered exemption.

The rules are Part 3 of the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 (SI 2015/962).

The letInside MEES?Provision
An ordinary commercial lease of a property that needs an EPCYes: band E or a registered exemptionregs 20, 22, 27
A property that is not required to have an EPCNoreg 20(2)
A let of six months or less, with no right to renew and no prior 12 months’ occupationNoreg 20(3)(a)
A lease of 99 years or moreNoreg 20(3)(b)
Property in Scotland or Northern IrelandNo: the Act says “situated in England and Wales”Energy Act 2011 s.42

An EPC is “valid” when it was lodged no more than 10 years before it is relied on and no newer one has been lodged since, so the newest certificate is the one that counts (reg 22(c)).

Listed status is not an exemption in itself; it matters only if no EPC is required or a consent is refused.

Where it applies

Is MEES the law across the UK?

No. It is law in England and Wales; Scotland runs a different regime, and no Northern Ireland equivalent has been found.

The recast EU buildings directive does not reach the UK; it applies “within the Union” (Directive (EU) 2024/1275).

The domestic regime shares the band E floor but has different dates, a £3,500 cost cap and lower fines; this page covers commercial lets only.

A commercial let in the UK

England and Wales

SI 2015/962: band E minimum, or a registered exemption.

Enforced by trading standards.

Scotland

Section 63: an action plan for buildings over 1,000 m² on sale or a new let.

No EPC band at all.

Northern Ireland

No private rented energy standard was found as at October 2026.

A search result, not a proven absence.

Energy Act 2011 s.42 · SSI 2016/146

One office

What does MEES mean for one office?

A 4,000 m² office in Leeds with a band F EPC lodged in 2019 cannot continue its lease without an exemption or an upgrade.

It is an illustration, not a real building.

With a rateable value of £45,000, the ceiling for a breach of three months or more is £10,000, the greater of £10,000 and 20% of rateable value.

The same building in Glasgow would owe a section 63 action plan on its next new let, not a band.

  1. 1

    Is it in scope?

    Yes: an office in England let on an ordinary lease, which needs an EPC (reg 20).

  2. 2

    Is the EPC valid?

    Yes: lodged in 2019, within 10 years, with no newer one since (reg 22(c)).

  3. 3

    Can the lease continue at band F?

    No: since 1 April 2023 continuing the let is a breach without a registered exemption (reg 27).

  4. 4

    Is the upgrade required?

    Only measures that pass the 7-year payback test; one costing more than seven years of savings is not (reg 28).

  5. 5

    What if nothing passes?

    Register the “all relevant improvements made” exemption, which lasts five years from registration (reg 29).

Penalties

What happens if a landlord breaches MEES?

Fines scaled to rateable value up to £150,000, publication for at least 12 months, and no void lease.

Enforcement is by local weights and measures authorities, that is trading standards (reg 34). The lease stays valid (reg 30), and appeals go to the First-tier Tribunal after a review (reg 43).
BreachMaximumProvision
Letting below band E for less than three monthsThe greater of £5,000 and 10% of rateable value, capped at £50,000reg 41(2)
Letting below band E for three months or moreThe greater of £10,000 and 20% of rateable value, capped at £150,000reg 41(3)
Any penaltyPublication on the PRS Exemptions Register for at least 12 monthsreg 39
Compliance noticeCan reach back 12 monthsreg 37
Penalty noticeCan reach back 18 monthsreg 38

“MEES fines are capped at £5,000” is the domestic aggregate cap, not the commercial rule.

The rateable value is set as if the property could be let: the Valuation Office disregards the ban (VOA Rating Manual).

Exemptions

Which exemptions can a commercial landlord rely on?

Six routes, each registered before it is relied on; five run five years and one runs six months.

Each exemption goes on the public PRS Exemptions Register first (GOV.UK).

The government’s guidance expects three installer quotes to support a payback exemption; that is guidance, not the regulation (DESNZ).

An exemption may not pass to a buyer, who gets its own six months instead.

The six routesExplore

The six routes

7-year payback

No listed measure pays back within seven years, so none is required.

The payback test

How does the 7-year payback test work?

Seven years of energy-bill savings must be at least the ex-VAT cost multiplied by a Bank Rate interest factor.

Cost divided by annual saving is not the statutory test: the interest factor raises the bar as Bank Rate rises.

The savings use the landlord’s own 12 months of bills where they exist, without VAT (reg 28(7)).

  1. Step 1

    The measure is listed and recommended

    On the statutory lists, and recommended in an EPC report or a surveyor’s report.
  2. Step 2

    Price it without VAT

    Purchase and installation, labour included: the cost C.
  3. Step 3

    Apply the interest factor

    C times a factor F based on Bank Rate gives the repayment cost R.
  4. Step 4

    Compare seven years of savings

    If savings S over seven years are at least R, the measure is required.

SI 2015/962 reg 28(1)–(8)

Your let

Can your property be let?

Enter the let, the EPC and two figures: whether you can let, how long the EPC lasts, a payback screen and the fine ceiling.

The payback screen compares seven years of savings with the cost before the interest factor; a measure that fails it cannot pass the statutory test.

The penalty ceiling uses the reg 41 formula and your rateable value.

MEES · your commercial let

Choose where the property is, then the let and the EPC.

The 7-year payback screen

Enter a cost and an annual saving.

The penalty ceiling

Enter the rateable value to see the maximum fine.

Rules: SI 2015/962 regs 20, 22, 27, 28, 29–33, 36, 41; Climate Change (Scotland) Act 2009 s.63 and SSI 2016/146.

A first reading, not advice on a particular lease. Nothing you enter leaves your browser.

What is changing

Is MEES getting stricter?

Proposed, not enacted: EPC B from 2031 for buildings over 1,000 m², and nothing new for smaller ones.

None of the trajectory has ever been law, and the 2021 compliance-window design was not mentioned in the interim response (DESNZ).

  1. 15 October 201901

    EPC B by 2030 consulted on

    The first non-domestic trajectory consultation.

    BEIS

  2. 17 March 202102

    EPC C by 2027 and B by 2030 proposed

    With two-year compliance windows; never enacted.

    BEIS consultation

  3. 18 June 202603

    Interim response

    The EPC C 2027 milestone dropped; the payback test and exemptions stay.

    DESNZ

  4. 15 July 202604

    Impact assessment “in due course”

    No regulations made; 93% of non-domestic buildings are 1,000 m² or smaller.

    UIN 17668

  5. Second half of 202705

    EPC reform

    Commercial EPCs keep the carbon-based Environmental Impact Rating.

    EPB reform

  6. 2031 (proposed)06

    EPC B for buildings over 1,000 m²

    Only after secondary legislation passes through Parliament.

    DESNZ

Domestic MEES is on a different track, a dual-metric standard from October 2030; it does not move the commercial test.

Reporting

How does MEES connect to company reporting?

Through the EPC itself, the real estate disclosure topics and business rates, not through any reporting rule that names MEES.

No primary text links MEES to ESOS or to UK SRS, so treat any such link as a planning choice, not a rule.

Building certification is a separate, voluntary layer: see BREEAM certification and NABERS UK.

Portfolio data for the disclosures usually sits in real estate carbon accounting software.

Where MEES shows upExplore

Where MEES shows up

The EPC metric

Commercial EPCs keep the carbon-based Environmental Impact Rating to support MEES.

Order of work

What should a landlord do first?

Check which lets are in scope, then the EPCs, then the upgrades or exemptions, before any lease event.

A company leasing its premises can ask the landlord for the EPC and any registered exemption; both are public on the register.

Energy audit duties are separate: see ESOS Phase 4 and ESG reporting requirements in the UK.

  1. 1

    List every let and its term

    Short lets and 99-year leases are outside.

  2. 2

    Find the newest EPC for each

    Its band and lodgement date decide validity.

  3. 3

    Price the recommended measures

    Run the payback test on each, without VAT.

  4. 4

    Upgrade or register an exemption

    Before a new let, a renewal or any reliance.

  5. 5

    Diarise expiries

    EPCs at 10 years, exemptions at five years.

SI 2015/962 Part 3 · Exemptions Register

Band E is the law today, so every commercial let needs a valid EPC at E or better or an exemption on the register before it is relied on.

  1. Band E

    The legal minimum for commercial lets is still band E

    C and B are proposals.
  2. 1 April 2023

    Continuing a sub-standard let has been a breach since this date

    New lets since 1 April 2018.
  3. 7 years

    An upgrade is required only if seven years of savings cover its cost

    There is no £3,500 cap for commercial property.
  4. £150,000

    The fine can reach this for a breach of three months or more

    Scaled to rateable value.
  5. 2031

    EPC B is proposed for buildings over 1,000 m², not law

    EPC C by 2027 was dropped.

What applies to commercial property in Scotland?

Section 63: an action plan for buildings over 1,000 m² on sale or a new let, and then improvements or annual DECs.

It has applied since 1 September 2016 and sets no EPC band, so “MEES applies in Scotland” is wrong (Scottish Government).

The owner may defer the improvements for as long as an annual DEC is in place.

Section 63Explore

Section 63

Who

The owner of a non-domestic building over 1,000 m² being sold or let to a new tenant.

Frequently asked

What else do landlords ask about MEES?

What is MEES for commercial property?

MEES is the minimum energy efficiency standard in the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015.

A landlord may not grant a new let, or since 1 April 2023 continue an existing one, of a commercial property whose valid EPC is below band E, unless an exemption is registered first.

What EPC rating does a commercial property need to be let?

Band E or better.

The regulations set band E as the minimum level for domestic and non-domestic property alike.

Band C and band B are proposals, not law.

Is EPC C required for commercial property from 2027?

No. The government said on 18 June 2026 that the proposed interim EPC C milestone for 2027 will not be taken forward.

It now proposes EPC B from 2031 for private rented buildings over 1,000 m², where cost effective, and only after secondary legislation is passed.

What are the penalties for breaching MEES on a commercial let?

Up to the greater of £5,000 and 10% of rateable value, capped at £50,000, for a breach of less than three months, and up to the greater of £10,000 and 20% of rateable value, capped at £150,000, for three months or more.

The breach is also published on the PRS Exemptions Register for at least 12 months.

Is a lease void if the property is below band E?

No. Regulation 30 says a breach does not affect the validity or enforceability of any provision of the tenancy.

The landlord faces penalties, not a void lease.

Does the £3,500 cost cap apply to commercial property?

No. The £3,500 cap is the domestic rule.

A commercial improvement is required only if seven years of energy-bill savings are at least its cost, excluding VAT, multiplied by an interest-rate factor based on Bank Rate.

Which exemptions can a commercial landlord register?

Six routes: the payback test, all relevant improvements made, wall insulation that would harm the fabric, consent refused by a tenant or third party, a devaluation of more than 5%, and six months for a new landlord.

Each must be registered before it is relied on, and most last five years.

Does MEES apply in Scotland or Northern Ireland?

No. The regulations reach England and Wales only.

Scotland has its own section 63 regime for non-domestic buildings over 1,000 m², which requires an action plan rather than an EPC band.

No Northern Ireland equivalent has been found as at October 2026.

Does a low EPC lower my business rates?

No. The Valuation Office disregards the letting ban and values the property as if it could be let, so MEES does not reduce rateable value.

Sources

Where does each figure come from?

Every figure, date and status on this page traces to the instrument’s owner.

Secondary commentary is never the source for a number.

Checked against 21 sources fromlegislation.gov.ukDepartment for Energy Security and Net ZeroBEISUK ParliamentMHCLG and DESNZGOV.UK
  1. legislation.gov.uk
    The Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 (SI 2015/962), Part 3

    Regs 20 and 22: scope, band E and a “valid” EPC; reg 27: 1 April 2018 and 1 April 2023.

  2. legislation.gov.uk
    SI 2015/962, regulation 28

    The 7-year simple payback test, with the cost multiplied by a Bank Rate factor.

  3. legislation.gov.uk
    SI 2015/962, Part 3 Chapter 4

    The exemptions: consent, devaluation of more than 5% and the new-landlord six months.

  4. legislation.gov.uk
    SI 2015/962, Part 3 Chapter 6

    Reg 41 penalties, up to £50,000 or £150,000, and publication for at least 12 months.

  5. legislation.gov.uk
    SI 2015/962, regulation 24

    The £3,500 cost cap, which is the domestic rule.

  6. legislation.gov.uk
    Energy Act 2011, section 42

    A non-domestic private rented property is one “situated in England and Wales”.

  7. Department for Energy Security and Net Zero
    Non-domestic private rented property: minimum energy efficiency standard, landlord guidance

    Updated 5 May 2026; three quotes for the payback exemption; enforcement by Local Weights and Measures Authorities.

  8. Department for Energy Security and Net Zero
    MEES in the non-domestic private rented sector: interim response (18 June 2026)

    The EPC C 2027 milestone dropped; EPC B from 2031 proposed for buildings over 1,000 m².

  9. BEIS
    Non-domestic PRS MEES: EPC B implementation (consultation, issued 17 March 2021)

    The interim EPC C by 2027 proposal and two-year compliance windows.

  10. BEIS
    Non-domestic PRS MEES: future trajectory to 2030 (consultation, 15 October 2019)
  11. UK Parliament
    Written answer UIN 17668 (15 July 2026)

    93% of non-domestic buildings are 1,000 m² or smaller; the impact assessment “in due course”.

  12. MHCLG and DESNZ
    Reforms to the Energy Performance of Buildings regime: partial government response

    Commercial EPCs keep the carbon-based Environmental Impact Rating “to facilitate ongoing compliance with non-domestic MEES”.

  13. MHCLG and DESNZ
    Reforms to the Energy Performance of Buildings regime (consultation page, update of 9 March 2026)

    Reform moved to the second half of 2027.

  14. GOV.UK
    View private rented sector energy standards exemptions

    The public search of registered exemptions and penalties.

  15. GOV.UK
    Register a private rented sector energy standards exemption
  16. legislation.gov.uk
    The Assessment of Energy Performance of Non-domestic Buildings (Scotland) Regulations 2016 (SSI 2016/146)

    Over 1,000 m²; an action plan; 42 months or annual DECs; £1,000 penalty charges.

  17. legislation.gov.uk
    Climate Change (Scotland) Act 2009, section 63
  18. Scottish Government
    Energy performance of existing non-domestic buildings: information
  19. IFRS Foundation
    SASB Standards: Real Estate, IF-RE-130a.4

    The share of a portfolio with an energy rating; EU EPCs are named, UK EPCs are not.

  20. Valuation Office Agency
    Rating Manual section 2, Part 10: Energy regulations (MEES) and rating

    The letting ban is disregarded when rateable value is set.

  21. EUR-Lex
    Directive (EU) 2024/1275 (recast EPBD), Article 1

    EU law “within the Union”; it does not apply in the UK.

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