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The government has now set out a revised direction for non-domestic Minimum Energy Efficiency Standards, giving commercial landlords a clearer view of the likely route ahead.
The headline change is that larger privately rented non-domestic buildings in England and Wales are expected to achieve EPC B by 2031, where this is cost-effective. The previously proposed EPC C milestone for 2027 will not be taken forward.
Until now, many landlords had been working on the basis of a staged pathway. EPC E has been the minimum requirement for some time, with an anticipated move to EPC C by 2027, followed by EPC B by 2030. The latest position removes that interim step and instead focuses directly on EPC B by 2031 for buildings over 1,000 square metres.
The seven-year payback test is also expected to remain in place. This means that landlords should only be required to carry out improvements that are practical, affordable and cost-effective. For listed buildings, constrained sites or properties where upgrade costs are significant, this will remain an important consideration.
Although the final target has not changed significantly, the route to reaching it has. Removing the EPC C milestone gives landlords more time on paper, but it also removes a stepping stone that would have encouraged earlier action.
In practice, this could create a more compressed pathway. Without an interim checkpoint, there is a risk that improvement works are deferred, even though the technical challenge of achieving EPC B remains. For many buildings, waiting until the deadline is closer may leave too little time to plan, fund, procure and deliver the necessary works.
For many existing buildings, achieving EPC B will not be delivered through one simple measure. It often requires a combination of plant replacement, fabric improvements and better controls, all assessed against the payback criteria.
Some potential improvements may not be viable once cost, disruption and payback are considered. This can narrow the available options, which is why early modelling is so important. In our experience, Level 5 modelling provides the clearest route to understanding what is realistically required to reach an EPC B rating.
Even where improvements are technically and financially achievable, they rarely happen in isolation. Works often depend on lease events, capital expenditure cycles, tenant access, design development and procurement windows.
The removal of the interim milestone does not remove these practical constraints. It simply shortens the visible runway while keeping the final requirement in place. For landlords and asset managers, the sensible response is to use the time available now to understand the gap, test the options and align any works with wider asset planning.
The proposals still need to pass through Parliament before the higher standard takes effect. Further detail is also expected through updated guidance and the government’s full response to the consultation.
However, the direction of travel is now clear enough for landlords to begin planning. The key issue is not only whether a building can reach EPC B, but how and when the required improvements can be delivered in a way that is proportionate and commercially realistic.
We recommend that landlords and asset managers start with accurate modelling and a realistic capital expenditure plan. Level 5 modelling can help identify the most credible route to EPC B, including which measures are likely to be viable and how they can be phased.
Our in-house CIBSE Low Carbon Assessors can support this planning process, while our projects team can assist with implementation. If you would like to understand what the revised MEES direction could mean for your building, please contact us on info@karsonsconsulting.com for further information or a free consultation.
Karsons Consulting are members of the Chartered Institute of Building Services Engineers, The Association of Consultancy and Engineering, British Institute of Facilities Managers and the Building Services Research and Information Association.
