MEES Standard: What the EPC Minimum Rating Changes Mean for Landlords

The UK Government has confirmed its long awaited position on the future of Minimum Energy Efficiency Standards (MEES) for the non-domestic private rented sector, setting a new compliance deadline of 2031 for all commercial buildings over 1,000 sqm to achieve a minimum EPC of ‘B’ by law. This interim response to consultations first issued in 2019 and 2021 gives landlords, investors, and occupiers the clarity they've been waiting years for.

What's Actually Changing?

The new MEES framework introduces a "dual metric" standard rather than a single overall EPC score, which changes how compliance is assessed.

• From 2031, all privately rented commercial buildings over 1,000 square metres in England and Wales must achieve a minimum EPC rating of B, where cost-effective.

• Alongside fabric performance, landlords must meet either the heating system metric or the smart readiness metric, giving flexibility between installing low-carbon heating (like heat pumps) or smart measures such as solar and battery storage.

• The previously proposed interim milestone of EPC C by 2027 has been dropped entirely, giving landlords more time to plan improvements around their lease cycles.

• Beyond compliance, energy performance will influence key decisions including asset valuations, lending criteria, ESG reporting obligations and Net Zero commitments.

• Commercial buildings below the 1,000 square metre threshold will remain subject to the current minimum standard of EPC E, with no set deadline to go further.

  
  

This is a materially different timeline to earlier proposals, which had suggested EPC C by 2027 and EPC B by 2030 across the board. The government has instead taken a proportionate approach, giving SMEs and high street landlords of smaller properties considerably more breathing room while focusing pressure on the largest, most energy-intensive buildings first.

Why This Matters: The Benefits, Exceptions and Penalties

Five years may sound like plenty of time, but retrofit works, planning consents, and contractor availability all take longer than expected once demand spikes closer to the 2031 deadline. Buildings currently sitting at EPC D, E, or below will typically need a more substantial fabric and services upgrade than the previous two-step trajectory assumed, since the interim EPC C milestone for 2027 has been scrapped.

• Bigger jump required: Going straight from E or D to B is a larger technical leap than the old E to C to B pathway, so buildings further from compliance need earlier, more detailed assessment.

• Portfolio complexity: Landlords with multiple assets over 1,000 sqm face harder prioritisation decisions on which buildings to upgrade first, based on cost, lease events, and compliance risk.

• Acting early spreads cost: Starting retrofit planning now avoids competing for contractor and assessor capacity during the expected crunch as 2031 approaches.

• Benefits of early compliance: Buildings rated B typically command stronger rental demand, lower void periods, and higher asset valuations, alongside reduced energy running costs for occupiers.

• Benefits for ESG positioning: Improved EPC ratings support investor and occupier ESG reporting requirements, which increasingly influence leasing and investment decisions.

• Exceptions: The retained 7-year payback test means landlords only need to carry out improvements that pay for themselves in energy savings within 7 years, existing exemptions for cases such as third-party consent refusal, devaluation of the property, or temporary hardship also remain in place.

• Penalties for non-compliance: under the current non-domestic MEES regime, landlords letting a sub-standard building without a valid exemption can face civil penalties of up to 20% of the property's rateable value, capped at £150,000 for breaches lasting longer than three months.

How JAW Sustainability Helps Clients Get Ahead of MEES

JAW Sustainability has spent years supporting landlords, developers, and asset managers through Part L compliance, EPC assessments, and energy strategy work across residential and commercial portfolios. Our building physics team translates these regulatory shifts into a clear, cost-effective action plan tailored to each property or portfolio.

Our services include:

• MEES compliance roadmaps

• Energy Strategy Statements and energy audits

• Building performance & Comfort assessments

• EPCs

• Thermal bridging calculations (Psi and Chi values)

• Decarbonisation & Net zero strategy roadmaps

• ESG and on-going regulatory support

  
  

If your commercial portfolio includes buildings over 1,000 square metres, get in touch with JAW Sustainability to understand your current EPC position and build a cost-effective route to B ahead of 2031.