The consultation that never got a response
In 2021 the UK government consulted on raising the Minimum Energy Efficiency Standards for commercial property in England and Wales. The proposals were clear: a minimum EPC C rating by 1 April 2027, rising to a minimum EPC B rating by 1 April 2030. Responses were overwhelmingly supportive — 91% backed the EPC B target and 86% supported 2030 as the implementation date.
That consultation closed in 2021. As of May 2026, the government's formal response has still not been published.
For institutional landlords managing large commercial portfolios, this creates a genuinely difficult planning environment. The trajectory is clear — commercial MEES will tighten, and significantly — but the precise deadlines and the technical standards that will apply remain unconfirmed.
What is law right now
The only confirmed commercial MEES position as of May 2026 is this: all privately rented non-domestic properties in England and Wales must hold a minimum EPC rating of E. Landlords cannot grant a new lease or continue to let a commercial property rated F or G without a registered exemption.
This has been in force since April 2023 for both new and continuing leases. Landlords with F or G rated assets that are currently let are already in breach unless an exemption applies.
The proposed EPC C milestone — originally suggested for 1 April 2027 — has not been legislated. Current indications from government suggest that EPC B will be required at some point between 2030 and 2035, but whether an interim C standard will be mandated, and when, remains unclear.
Why the uncertainty itself is a risk
Some landlords have interpreted the absence of confirmed deadlines as permission to defer action. This is a mistake for three reasons.
EPC improvement lead times are long. Fabric improvements — insulation upgrades, window replacement, heating system decarbonisation — require planning, procurement, contractor engagement, and in many cases tenant cooperation. For a large portfolio, a systematic improvement programme takes years to execute, not months. Waiting for regulatory certainty before beginning creates a timing problem that cannot be solved quickly.
The direction of travel is unambiguous. Whatever the final deadlines, the direction is confirmed: commercial MEES will rise to EPC B at some point. Every year without a programme is a year of lost lead time on an inevitable requirement.
Lease events create hard deadlines regardless of regulation. Even if the government delays EPC C to 2029 or later, a lease renewal or re-letting of a sub-C asset creates a commercial vulnerability. Institutional tenants are increasingly asking about EPC ratings at heads of terms stage. Lenders are beginning to reference EPC performance in green finance covenants. The commercial pressure is building independently of the regulatory timeline.
The EPC reform picture adds further complexity
Commercial MEES reform is happening alongside a broader review of the EPC framework itself. The government has been consulting on changes to EPC metrics for commercial buildings — potentially moving away from the current asset-based SBEM model towards metrics that better reflect operational energy performance.
This matters because an EPC rating achieved under the current methodology may not translate directly to a rating under a revised methodology. Landlords who are planning improvement programmes purely to hit a current EPC rating target may find the goalposts shift.
The prudent approach is to focus on genuine fabric and services improvement — measures that reduce actual energy consumption — rather than optimising narrowly for the current EPC methodology. This provides a more resilient compliance position regardless of how the metric evolves.
What the BPF data tells us
Research published by the British Property Federation found that 81% of commercial buildings in English cities could fail to meet an EPC Band B rating by 2030. That is not a marginal compliance problem — it represents the overwhelming majority of the commercial stock.
For portfolio landlords, the implication is that a significant proportion of assets will require material capital investment to achieve EPC B. The question is not whether to invest but when and in what sequence.
What prudent landlords should be doing now
Regardless of when the government publishes its formal response, there are four things institutional landlords should be doing now.
Current EPC audit. Establish the current EPC rating for every asset in your portfolio. Identify which assets are rated E (compliant but vulnerable), D or C (moderate risk), and B or above (well positioned). Many portfolios have EPCs that are out of date or that were produced when the building was in a different configuration — these need to be updated before planning any improvement programme.
Gap analysis against EPC C and B thresholds. For each asset, understand what measures would be required to achieve EPC C and EPC B under the current methodology, and at what cost. This gives you the information needed to sequence capital expenditure rationally across the portfolio.
Lease event mapping. Identify which assets have lease expiries, break clauses, or rent reviews in the next three to five years. These are the assets where EPC performance creates the most immediate commercial risk — either because a void would require a compliant EPC to re-let, or because a renewal negotiation with an institutional tenant will surface EPC performance as a point of discussion.
Improvement programme planning. For assets with near-term lease events or sub-E ratings, begin improvement planning now. For assets rated D or C, develop a programme timed to achieve B ahead of whichever deadline is eventually confirmed — without leaving it so late that contractor availability becomes a constraint.
The exemptions landscape
Commercial MEES includes a number of exemptions that can apply where compliance is not technically feasible or not cost effective. These include:
- The seven year payback exemption — where the cost of the required improvements cannot be recovered within seven years through energy savings
- The consent exemption — where the landlord cannot obtain necessary consents from tenants or planning authorities
- The devaluation exemption — where a qualified surveyor confirms that the required improvements would reduce the market value of the property by more than 5%
Exemptions must be registered on the PRS Exemptions Register. They are valid for five years and must be renewed. They are not a permanent solution — they are a time-limited deferral, and the underlying compliance obligation remains.
Relying on exemptions as a long-term strategy is not advisable. Lenders and institutional investors are increasingly scrutinising exemption reliance as a negative indicator in due diligence.
Our view
The landlords who will be best positioned — commercially, financially, and reputationally — are those who use the current period of regulatory uncertainty to build a systematic, evidence-based improvement programme rather than waiting for confirmation of deadlines that may arrive with less notice than expected.
The government's delay in confirming commercial MEES deadlines is frustrating for landlords trying to plan capital programmes. But the fundamentals are clear: commercial MEES will tighten, the direction is to EPC B, and the majority of the commercial stock does not meet that standard today.
NZC Consultants provides commercial EPC assessments, MEES compliance reviews, and portfolio-wide improvement planning for institutional landlords and property funds. We can help you establish where your assets sit today and what a credible improvement programme looks like. Get in touch with our team to discuss your portfolio.