Commercial EPC and MEES rules are changing for larger privately rented non-domestic buildings in England and Wales. The UK Government confirmed in June 2026 that it intends to take a more targeted approach, focused on larger rented premises, with EPC B from 2031 being discussed for commercial buildings over 1,000 square metres where improvements are cost-effective.

For landlords, property managers and facilities teams, the practical message is clear:

Do not wait until 2031 to understand what your building needs.

The best first step is to review the building’s current EPC rating, energy performance, lighting, HVAC, insulation, roof condition, ventilation, controls, fabric defects and planned refurbishment schedule.

Energy upgrades are easier to manage when they are built into wider maintenance and refurbishment works.

Why This Topic Matters Now

Energy performance has become one of the biggest commercial property issues in the UK.

It affects:

• lettability

• running costs

• tenant appeal

• refurbishment planning

• capital expenditure

• asset value

• compliance risk

• sustainability reporting

In June 2026, the UK Government published an interim response to earlier consultations on strengthening Minimum Energy Efficiency Standards in the non-domestic private rented sector. The update confirmed a more targeted approach, focused on helping businesses renting larger premises cut energy costs and improve energy efficiency.

Legal and property sector commentary has highlighted the key headline: EPC B from 2031 for larger commercial buildings over 1,000 square metres, where cost-effective, while smaller commercial premises are expected to remain subject to the existing EPC E minimum for now.

For commercial landlords, this is not just a compliance update. It is a building planning issue.

What Is MEES?

MEES stands for Minimum Energy Efficiency Standards.

In simple terms, MEES sets minimum energy performance requirements for privately rented property.

For commercial buildings, this links to the building’s Energy Performance Certificate, or EPC.

An EPC rates a building’s energy efficiency from A to G, with A being the best rating and G being the worst.

The existing non-domestic MEES framework has already required minimum standards for privately rented commercial property. The Government’s latest update gives the market a clearer direction for larger rented premises, even though detailed implementation will still matter.

Who Should Pay Attention?

This topic is especially relevant to:

• commercial landlords

• property investors

• managing agents

• facilities managers

• office landlords

• industrial unit owners

• hospitality property owners

• school and public estate managers planning energy works

• tenants negotiating leases or refurbishments

• businesses occupying larger rented buildings

Even where a building is not immediately affected by the proposed larger-building threshold, energy performance is still becoming a commercial priority.

Tenants increasingly want better buildings. Running costs matter. Older buildings with poor efficiency can become harder to market, harder to manage and more expensive to operate.

What Buildings Are Most Likely to Need Attention?

Older commercial buildings are often the ones that need the most careful review.

Common risk areas include:

• outdated lighting

• poor insulation

• inefficient heating systems

• ageing air conditioning

• poor ventilation control

• old boilers

• single glazing

• roof heat loss

• uncontrolled energy use

• poor zoning

• tired building fabric

• gaps, leaks or draughts

• plant rooms that have not been reviewed for years

A building does not need to be visibly run down to perform poorly.

Sometimes the issues are hidden inside lighting layouts, controls, roof voids, HVAC systems, old pipework or plant equipment.

Upgrade Area 1: LED Lighting and Controls

Lighting is often one of the most practical first upgrades for commercial buildings.

Many offices, schools, warehouses and hospitality buildings still have inefficient or poorly controlled lighting.

A lighting review can look at:

• LED upgrades

• emergency lighting

• occupancy sensors

• daylight sensors

• zoning

• controls

• external lighting

• corridor lighting

• meeting room lighting

• staff area lighting

Good lighting upgrades can improve the building’s feel, reduce wasted energy and support wider refurbishment goals.

This is often one of the most sensible works to combine with office refurbishment, redecoration, ceiling works or electrical upgrades.

Upgrade Area 2: HVAC, Heating and Ventilation

Heating, cooling and ventilation can have a major impact on commercial energy performance.

This is particularly important in:

• offices

• schools

• hospitality buildings

• healthcare settings

• large venues

• warehouses

• mixed-use buildings

Poorly performing HVAC systems can increase energy use and make buildings uncomfortable.

Before investing in new finishes, landlords and facilities teams should review:

• plant age

• service history

• heating efficiency

• air conditioning performance

• zoning

• controls

• ventilation rates

• filters

• ductwork

• insulation to pipework

• room-by-room comfort issues

• whether systems match the current layout

The office market is also changing because hybrid working has altered occupancy patterns. Industry guidance on office fit-out trends continues to emphasise smarter, more flexible and more responsible refurbishments that support how people work now.

Upgrade Area 3: Roofs, Leaks and Building Fabric

Energy performance is not only about plant and systems.

The building fabric matters too.

Roofs, windows, doors, walls and external defects can all affect heat loss, comfort and long-term maintenance cost.

Before planning major energy upgrades, review:

• roof condition

• roof leaks

• insulation

• guttering

• water ingress

• damaged flashing

• draughts

• ageing windows

• door seals

• external defects

• moisture problems

A poor roof or building envelope can undermine the benefit of internal upgrades.

Drone surveys can help identify roof or high-level defects without unnecessary access disruption.

Upgrade Area 4: Insulation and Heat Loss

Insulation can be harder to address in commercial buildings than in homes, but it should not be ignored.

Heat loss can occur through:

• roofs

• walls

• poorly insulated voids

• service penetrations

• old doors

• windows

• uninsulated pipework

• poorly sealed spaces

• plant areas

Where insulation works are practical, they may be best planned alongside roof works, ceiling works, refurbishment projects or plant upgrades.

This is why a planned approach matters.

Energy upgrades are often cheaper and less disruptive when they are combined with works that are already scheduled.

Upgrade Area 5: Controls, Zoning and Smarter Operation

Many commercial buildings waste energy because systems are not controlled properly.

Examples include:

• lights left on in unused areas

• heating and cooling running at the same time

• poor zoning

• outdated timers

• no occupancy-based control

• meeting rooms treated the same as open-plan areas

• staff areas heated or cooled when empty

• plant running outside occupation hours

Controls can be particularly important where hybrid working has changed when and how office space is used.

If the building is only fully occupied on certain days, systems should reflect that where possible.

Why Landlords Should Link EPC Planning to Refurbishment

A common mistake is treating EPC upgrades as a separate project.

In practice, energy performance works often overlap with refurbishment and planned maintenance.

For example:

• LED lighting can be upgraded during ceiling works

• HVAC can be reviewed during layout changes

• insulation can be improved during roofing works

• fire doors can be checked during compliance upgrades

• electrical capacity can be reviewed during fit out

• ventilation can be improved during workplace redesign

• external defects can be addressed during fabric repairs

This is why landlords should review upcoming refurbishments, lease events, void periods and planned maintenance before deciding when to act.

What Should Commercial Landlords Do First?

Before starting upgrade works, landlords and facilities teams should build a clear action plan.

Step 1: Confirm the current EPC position

Understand the existing rating, recommendations and building assumptions.

Step 2: Review the building condition

Check roof, fabric, services, lighting, HVAC, ventilation, leaks, draughts and obvious inefficiencies.

Step 3: Identify planned works

Look at upcoming refurbishment, fit out, tenant changes, lease events, void periods and maintenance schedules.

Step 4: Prioritise practical upgrades

Focus first on works that reduce risk, improve operation and can be delivered without unnecessary disruption.

Step 5: Build improvements into future projects

Do not wait for a single major upgrade if smaller planned works can move the building in the right direction.

What Tenants Should Ask Before Signing or Renewing a Lease

Tenants should also pay attention to energy performance.

Before committing to a space, ask:

• what is the current EPC rating?

• are upgrades planned?

• who pays for energy improvement works?

• are HVAC systems efficient and maintained?

• are lighting and controls modern?

• is ventilation suitable for the intended use?

• are there known leaks or fabric defects?

• will fit out works improve or worsen energy performance?

• are landlord approvals needed for tenant improvements?

• could energy works affect occupation or service charges?

Energy performance is becoming part of commercial decision-making, not just landlord compliance.

EPC Upgrade Planning Checklist

Use this as an early-stage review:

• Current EPC rating confirmed

• EPC recommendations reviewed

• Lighting condition checked

• HVAC performance reviewed

• Ventilation checked

• Heating controls reviewed

• Roof and fabric inspected

• Leaks and draughts identified

• Insulation opportunities considered

• Electrical capacity reviewed

• Planned maintenance schedule checked

• Refurbishment opportunities identified

• Tenant or landlord responsibilities clarified

• Fire safety and compliance works considered

• Budget and phasing discussed

Mistakes to Avoid

Waiting until the deadline is close

Commercial building upgrades take time to plan, price and deliver.

Treating EPC works separately from refurbishment

This can lead to duplicated disruption and missed savings.

Focusing only on visible finishes

A newly decorated building can still perform poorly if services and fabric are weak.

Ignoring roof and fabric defects

Leaks, draughts and poor insulation can undermine other energy improvements.

Forgetting tenant disruption

Works may need phasing, access planning or out-of-hours delivery.

Not checking cost-effectiveness and exemptions

The detailed rules and cost-effectiveness tests matter. Landlords should take proper professional advice where required.

How BTS Can Support Commercial Building Upgrade Planning

Barry Turner and Son Ltd supports commercial clients across London and the South East with practical building works that can form part of wider EPC, refurbishment and planned maintenance strategies.

Final Thoughts

The latest commercial EPC and MEES update gives landlords more direction, but it should not be treated as a reason to wait.

Larger commercial buildings may need meaningful energy performance improvements before 2031, and those works are easier to manage when planned early.

For landlords, tenants and facilities teams, the smart approach is to review the building now, understand the current EPC position and connect energy upgrades with planned refurbishment, maintenance and compliance works.

Barry Turner and Son Ltd can support commercial building upgrades across London and the South East, including electrical works, HVAC, roofing, plumbing, fire doors, fire stopping, decorating and wider refurbishment delivery.

To discuss upcoming commercial upgrade works, visit Commercial Services or request a Free Quotation.

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