Energy efficiency may not be the first thing a business thinks about when renting a commercial property. Location, rent and the size of the premises are often more immediate concerns. However, proposed changes to Minimum Energy Efficiency Standards (MEES) could make a property’s Energy Performance Certificate (EPC) rating an increasingly important consideration for both commercial landlords and tenants.

In June 2026, the Government published its interim response to consultations on improving energy efficiency standards in privately rented non-domestic properties in England and Wales. The proposals could have a significant impact on larger commercial properties, making it important for landlords and tenants to start thinking ahead.

What is changing?

The Government has confirmed its intention to introduce a higher minimum energy efficiency standard for larger privately rented commercial buildings.

From 2031, privately rented buildings over 1,000 square metres in England and Wales are proposed to require a minimum EPC rating of B, where improvements are cost-effective.

Buildings under 1,000 square metres will continue to be subject to the existing minimum EPC E standard.

The Government had previously proposed an interim EPC C requirement for larger buildings from 2027. However, this will no longer be taken forward, giving landlords and tenants more time to plan improvements and consider how work may fit around existing lease arrangements.

Existing flexibility measures, including the seven-year payback test and exemptions, are also expected to remain in place.

It is important to note that the proposed EPC B requirement will only take effect once the necessary secondary legislation has successfully passed through Parliament. Further details and guidance are expected.

Why is this relevant now?

2031 may seem some time away, but improving the energy efficiency of a large commercial property can require significant planning and investment.

Work may involve changes to heating or cooling systems, lighting, insulation or other parts of a building. Depending on the property, these improvements could be costly and may cause disruption to businesses operating from the premises.

Commercial leases can also last for several years. A landlord granting a new lease, or a tenant considering taking on new premises, could therefore enter into an agreement now that continues beyond the proposed 2031 deadline.

Thinking about energy efficiency at an early stage may help both parties avoid unexpected issues later.

What should commercial landlords consider?

Landlords of larger commercial properties may want to start by checking the current EPC rating of their buildings and considering whether improvements could be required.

An EPC is generally valid for ten years. However, assessment methods and energy efficiency requirements can change. Landlords should not necessarily assume that a building which previously achieved a particular rating will receive the same rating when it is reassessed.

Landlords may also need to consider the cost and practical impact of improvement works. If a building is occupied, when can the work take place? Will access to the tenant’s premises be required? Could the work affect the tenant’s business?

The terms of the lease will also be important. Landlords should consider what the lease says about access, repairs, alterations and service charges, particularly where energy efficiency improvements may be required.

Although the proposed deadline is not until 2031, understanding a property’s current position could give landlords more time to plan and budget for any necessary improvements.

What should commercial tenants consider?

Energy efficiency is also an important consideration for businesses looking to rent commercial premises.

Before signing a lease, a potential tenant may want to check the property’s EPC rating and understand whether significant improvements could be needed during the term of the lease.

One important question is who may be responsible for the cost of any work. Tenants should carefully consider the terms of the lease, including any service charge provisions and clauses relating to repairs and alterations.

There is also the practical impact of improvement work to consider. Contractors may need access to the property and some work could cause noise or disruption to staff, customers or the day-to-day running of the business.

The Government’s proposals have not yet answered every question. For example, it remains unclear whether tenants may be expected to play a greater role in helping landlords meet future energy efficiency targets.

For businesses entering a new commercial lease, understanding the property’s energy efficiency position and the terms of the lease could help prevent unexpected costs or disruption in the future.

Planning ahead for 2031

The Government’s interim response gives landlords and tenants a clearer indication of the direction of future energy efficiency standards. However, further detail is still expected, and the proposed changes will require secondary legislation before they take effect.

For landlords, now may be a good time to review the EPC ratings of larger commercial properties and consider whether future improvements could be necessary.

For tenants, energy efficiency should increasingly form part of the questions asked before entering a commercial lease.

How can Gepp Solicitors help?

At Gepp Solicitors, our Commercial Property team can advise landlords and tenants on how proposed changes to Minimum Energy Efficiency Standards may affect commercial property and lease arrangements.

We can help landlords understand their existing leases and consider issues relating to access, improvement works and the potential recovery of costs. We can also advise commercial tenants before they enter a lease, helping them understand how a property’s EPC rating and future energy efficiency work could affect their business.

Where improvements may be required, we can assist landlords and tenants with negotiations to help reach practical arrangements that consider the responsibilities and commercial interests of both parties.

If you own or rent a commercial property and would like advice on your lease or the potential impact of future energy efficiency requirements, please contact our Commercial Property team.

Please contact our Commercial Property Team on 01245 228115, or email commercialenq@gepp.co.uk or visit Commercial property – Gepp Solicitors