On 18 June 2026 the government published an interim response to its consultations on minimum energy efficiency standards for non-domestic rented buildings in England and Wales.1 The headline is a single threshold.
What has been confirmed
- Privately rented non-domestic buildings over 1,000 m² must reach EPC B from 2031, where cost-effective. That is a year later than the 2030 date first proposed.
- The proposed interim step to EPC C in 2027 has been dropped.
- Buildings of 1,000 m² or less stay at the current EPC E minimum, with no date set for a higher standard.
What is not yet settled
This is confirmed policy, not law. The government has said the interim response is not its final position, and a full response is expected later in 2026. The existing 2015 Regulations stay in force until amending regulations pass through Parliament. The meaning of "where cost-effective" will matter a great deal and has not yet been defined in regulations.1
How it should change decisions now
- Map assets by floor area. The 1,000 m² line now splits a portfolio into two very different risk groups.
- Look at lease events, not just the deadline. Break dates, renewals and voids before 2031 are the cheapest moments to do disruptive work.
- Price it into refinancing. Lenders and valuers will start asking about a credible route to B for larger assets well before 2031.
- Do not over-engineer. Lighting, controls and commissioning often move a commercial EPC further per pound than plant replacement. Fabric work fits best at refurbishment.
- Keep the cost evidence. If "cost-effective" becomes the test, the records that show what was considered and what it would cost will be what counts.
This note covers privately rented non-domestic buildings in England and Wales. It is general information, not legal advice. Check the final regulations before relying on any date or threshold.
Sources
- Non-domestic MEES: UK government confirms EPC B target for larger commercial buildings from 2031, Jones Day, September 2026.
The EPC Upgrade Decision Matrix covers commercial property too →