Exploring Minimum Energy Efficiency Standards: Application and Upcoming Changes

Published: 07/05/2025

What are Minimum Energy Efficiency Standards?

Minimum Energy Efficiency Standards (MEES) set the baseline energy efficiency requirements for commercial properties in England and Wales. Introduced as part of the government’s broader commitment to achieving Net Zero by 2050, these regulations mandate that commercial properties meet specific Energy Performance Certificate (EPC) ratings in order to be legally let.

Since April 2023, the Minimum Energy Efficiency Standards (MEES) have required all commercial properties let under new and existing leases to achieve a minimum E rating on their EPC, marking a significant shift from previous regulations that only affected new lettings.

Read our article on Commercial EPCs to learn how Commercial EPCs are produced and how to interpret your property’s EPC rating.

Where does MEES apply?

MEES does apply to a commercial property if:

It is a building, meaning it has a roof, walls, and uses energy to regulate its indoor climate.
It has a valid EPC, meaning the property must have had an EPC commissioned in the last 10 years.
It is let under a lease, including periodic tenancies, reversionary leases, lease renewals, or tenancies at will.

MEES does not apply to a commercial property if:

It is legally exempt from having an EPC; and/or
It is owner-occupied rather than let, and/or
The property is subject to:

1. A licence to occupy.
2. A short lease (less than six months, with no renewal option, or where the tenant has already occupied the property for more than 12 months).
3. A long lease (more than 99 years).

Qualifying exemptions

Landlords may apply for an exemption to remain compliant with MEES, even if their property does not meet the required EPC rating. This allows them to continue letting a commercial property with an ‘F’ or ‘G’ rating, provided one of the following exemptions applies:

Third-Party Consent – Necessary approval from a third party (e.g., a tenant or local planning authority) is required for the works, but has been refused, or consent has been granted with conditions the landlord cannot reasonably meet.
Property Devaluation – The required improvements would reduce the property's value by 5% or more or cause damage (supporting valuation evidence required).
“All Improvements Made" Exemption – The landlord has undertaken all viable energy efficiency upgrades, but the EPC rating remains below ‘E’.
The Seven-Year Rule – It can be demonstrated that the cost of improvements would not be recouped through energy savings within seven years.
Temporary exemption for a new landlord – If you have recently become a landlord under certain circumstances, you will not be expected to take immediate action to improve your property to EPC E. You may claim a 6-month exemption from the date you became a landlord.
Wall insulation exemption – This exemption is for properties where the only recommended improvements include the installation of the following, and in doing so, there would be damage to the fabric or structure of the property:

- Cavity wall insulation
- External wall insulation systems
- Internal wall insulation systems

Registering an Exemption

Exemptions are not automatic and must be registered on the Government’s PRS Exemptions Register. Landlords can register exemptions for both domestic and non-domestic properties via the PRS Exemptions Register here: PRS Exemptions Register

Exemptions must be renewed every five years, and unlike an EPC, an exemption is linked to the landlord and not the property, meaning a new landlord must re-register the exemption if ownership changes.

Proposed Changes to MEES Regulations (2025 – 2030)

The regulatory landscape for commercial properties is set to become significantly more demanding as the UK government pursues its Net Zero target by 2050. The Government published their proposed plans for future MEES reforms in 2021, which included the following targets:

2025

All leased commercial properties must have a valid EPC.

Property owners with expired EPCs must apply for new certification.
This creates a baseline for future improvements.

2027

Minimum EPC rating of 'C' required for all commercial properties.

2030

Further increase to the minimum EPC rating of 'B'.

Represents a significant step-up in energy performance requirements.

To date, there has been no response to the 2021 consultation, leaving commercial property owners questioning what the future holds for their portfolios.

Risks of Non-Compliance

Commercial property owners must ensure that their buildings maintain valid EPCs throughout their lettable period that meet the required minimum rating. Local authorities enforce these regulations with substantial penalties for non-compliance:

Breaches under three months: £5,000 or 10% of rateable value penalty (up to £50,000)
Breaches over 3 months: £10,000 or 20% of rateable value penalty (up to £150,000)

These sanctions may also result in the publication of non-compliant landlords on the PRS Exemptions Register, which could cause potential reputational damage.

All EPCs are recorded on the government's register, which is government-maintained, and allows buyers, tenants, and enforcement bodies to verify their validity. The EPC register can be accessed here https://www.gov.uk/find-energy-certificate.

Opportunities for Landlords

While MEES compliance may seem like a series of additional costs, it also presents valuable opportunities to commercial landlords:

Cost Savings – Identifying energy efficiency improvements can lead to lower operating costs.
Increased Property Value – Energy-efficient buildings are more attractive to buyers and investors.
Greater Market Appeal – Sustainable properties appeal to eco-conscious tenants and businesses.
Regulatory Preparedness – Investing in improvements now can future-proof properties against tighter energy regulations.

In an increasingly environmentally conscious market, energy efficiency is more than just a compliance requirement, it is a key differentiator that can drive business success. Landlords who prioritise energy efficiency, meet regulatory standards, reduce operational costs, enhance their reputation, and appeal to eco-conscious tenants and investors.

As sustainability becomes a core value for businesses and consumers, organisations that proactively improve their energy performance can get a strategic edge. In today’s market, having an energy-efficient portfolio is not just about regulatory compliance, it’s about maintaining market appeal and staying ahead of the competition.

How Harris Associates Can Help

At Harris Associates, we support commercial landlords in meeting Minimum Energy Efficiency Standards (MEES), enhancing sustainability, and unlocking greater long-term value from their properties.
Whether you require a commercial EPC, need to improve your building's energy performance rating, or are looking to implement a long-term sustainability strategy, our team of experienced project managers, building surveyors, and cost consultants is equipped to guide you through every stage.

From compliance to carbon reduction, we deliver tailored advice and practical solutions that ensure your portfolio remains efficient, legally compliant, and resilient to future regulation. Contact us today to learn how we can help you create a more efficient, compliant, and future-proof property portfolio.

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Article By Lewis Denbow