The Government has published an interim response to its 2019 and 2021 consultations on proposals to strengthen the Minimum Energy Efficiency Standards (MEES) regime applicable to commercial properties in England and Wales. The announcement provides some clarity on the future direction of the regime and represents a departure from previous proposals.
At present, the existing MEES requirements continue to apply.
Commercial properties that are let must generally achieve a minimum EPC rating of E unless a valid exemption applies.
The changes outlined by our Commercial Property Lawyers below are not yet law and will require secondary legislation before they take effect.
What are Minimum Energy Efficiency Standards?
Minimum Energy Efficiency Standards (MEES) were introduced under the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, and are designed to improve the energy efficiency of privately rented properties in England and Wales.
The regime prevents landlords from granting new leases or continuing to let commercial properties with an Energy Performance Certificate (EPC) rating below the prescribed minimum standard unless a valid exemption applies. Since April 2023, most non-domestic properties have been required to achieve a minimum EPC rating of E.
The regulations form part of the Government's wider net zero strategy and are intended to reduce carbon emissions, lower energy consumption and improve the sustainability of the built environment.
The Proposed Changes
The Government has refined its approach, which now targets larger commercial buildings. From 2031 privately rented non-domestic buildings exceeding 1,000 square meters will be required to achieve an EPC rating of B, provided this is cost effective. Buildings below 1,000 square meters will remain subject to the current standard of a rating of E.
The Government has also confirmed that the previously proposed interim requirement of achieving an EPC rating of C by 2027 will not be implemented. This will be welcomed by many landlords who may otherwise have faced significant expenditure within a relatively short timeframe to improve the energy efficiency of their properties.
The changes can be summarised as follows:
| Previous Proposal | Revised Proposal |
|---|---|
| EPC rating of C by 2027 | No interim EPC C requirement |
| EPC rating of B by 2030 for most commercial properties | EPC rating of B by 2031 for non-domestic buildings over 1,000 sq m |
| Broad application across the commercial sector | Targeted approach focusing on larger buildings |
Looking Ahead
The removal of the proposed EPC C requirement by 2027 will provide some relief for landlords facing significant upgrade costs in the short term.
However, the Government's latest announcement suggests that improving the energy efficiency of commercial buildings remains a key policy objective.
Investors, lenders and occupiers are increasingly factoring sustainability credentials into real estate decisions, meaning that energy performance is likely to remain an important consideration for the commercial property sector in the years ahead.
Need Advice on MEES Compliance?
Whether you are a landlord, tenant, investor or developer, understanding your obligations under the MEES regime is becoming increasingly important.
For advice on EPC requirements, exemptions and the impact of the proposed reforms, contact Myerson's Commercial Property team.
0161 941 4000
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Josh Durkin
Trainee Solicitor
Josh joined Myerson as a Trainee Solicitor in September 2025. Prior to joining the firm, Josh obtained his law degree from the University of Sheffield, then completed his LPC LLM at the University of Law in Manchester in 2024, achieving a Distinction.
About Josh Durkin