MEES Update: Larger Non-Domestic Buildings to Achieve EPC B by 2031
The UK Government has released its long-awaited interim response on proposals to strengthen Minimum Energy Efficiency Standards (MEES) within the non-domestic private rented sector (PRS). While the update brings some clarity on the future trajectory of MEES, its narrow focus on larger commercial properties is likely to raise concerns across the wider property industry.
What has been confirmed?
In the latest announcement, the Government has set out a revised approach to improving energy efficiency in non-domestic rented buildings across England and Wales.
Key proposals include:
- A requirement for all rented non-domestic buildings over 1,000m² to achieve EPC B by 2031, where cost effective.
- No change for smaller buildings (below 1,000m²), which will continue to be subject to the current minimum standard of EPC E.
- The removal of the proposed interim EPC C milestone by 2027, effectively delaying earlier improvement expectations.
- Continued use of existing exemptions and the 7-year payback rule, ensuring only viable upgrades are required.
The Government states that this targeted approach aims to focus action where it will deliver the greatest benefits, including an estimated £360 million in annual energy bill savings by 2031 for tenants in larger buildings.
A targeted approach, but too narrow?
While the interim response provides long-awaited direction, the decision to focus exclusively on properties over 1,000m² is likely to divide opinion, with smaller premises, including high street units, small offices, and local commercial spaces, effectively excluded from meaningful policy progression.
This raises questions about whether the policy will deliver the scale of impact needed to meet wider decarbonisation goals.
There is also a strong argument that larger buildings are already further along the energy efficiency journey, driven by corporate ESG requirements, investor expectations, and occupier demand. Many landlords in this segment are already investing in improvements, regardless of regulatory pressures.
What this means for landlords
For landlords with larger properties, the direction of travel is now clearer. Achieving EPC B by 2031 will require strategic planning, investment, and early action to avoid future compliance risks.
For the majority of landlords with smaller properties, however, the message remains the same. While there is currently no requirement to go beyond EPC E, it would be unwise to assume this position will remain unchanged in the longer term.
As seen in the domestic PRS, where MEES is expected to tighten to EPC C by 2030, policy can evolve quickly.
Landlords should therefore continue to:
- Review current EPC ratings across their portfolios
- Identify cost-effective improvement measures
- Consider longer-term asset strategies in line with likely future regulation
Elmhurst’s view
While we welcome the clarity provided in this interim response, more needs to be done in order to drive meaningful change across the broader non-domestic sector.
By focusing on buildings over 1,000m², the Government is targeting a smaller proportion of the market, one that is arguably already engaged with energy performance improvements.
A more balanced approach, combining clear long-term signals for smaller buildings alongside appropriate support mechanisms, would better align with the UK’s net zero ambitions.
What happens next?
The proposals will require secondary legislation before being implemented, and further detail is expected in a full Government response.
In the meantime, landlords, agents, and energy professionals should stay engaged and prepare for future changes, as MEES continues to evolve across both domestic and non-domestic sectors.
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