MEES regulations, short for Minimum Energy Efficiency Standards (MEES), set the minimum Energy Performance Certificate (EPC) rating a UK commercial property must meet before it can legally be rented out. This guide focuses specifically on non-domestic MEES, the version that applies to commercial real estate (CRE), rather than the separate rules covering residential rented property. MEES isn’t a rating system in its own right, it’s the legal enforcement layer that sits on top of the existing EPC rating, and here’s how that works, how it treats large buildings differently, and what changed in June 2026.
Key facts
- MEES regulations require commercial landlords in England and Wales to meet a minimum EPC rating before granting or renewing a lease. This guide covers non-domestic MEES specifically, the commercial real estate version of the rules.
- MEES is England and Wales legislation only. Scotland and Northern Ireland run their own separate energy efficiency frameworks, Scotland currently has no minimum EPC requirement for commercial landlords at all, though its own reform is underway.
- The current legal minimum is EPC E. It’s been illegal to grant a new commercial lease below this since April 2018, and illegal to continue an existing lease below it since April 2023.
- Owner-occupied commercial buildings fall outside MEES entirely, since the regulations only apply where there’s a landlord-tenant lease in place.
- Large commercial buildings, those over 1,000 square metres, face a distinct, tighter future requirement, an EPC B rating by 2031, confirmed in the government’s June 2026 interim response.
- Non-compliance carries real financial penalties, up to £50,000 for a breach under three months, and up to £150,000 for a breach of three months or more, both calculated against the property’s rateable value as set by the Valuation Office Agency (VOA).
- A previously proposed interim milestone of EPC C by 2027 has been scrapped entirely.
- These 2031 changes are not yet law, they require secondary legislation to pass through the UK Parliament before taking effect.
What is non-domestic MEES, and how is it different from domestic MEES?
Non-domestic MEES is the official term for the version of MEES that applies to commercial real estate, buildings let for retail, office, industrial, and other business use. It’s a distinct set of rules from domestic MEES, which covers residential rented property under its own separate requirements and timeline.
Both sit under the same underlying legislation, the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, but the thresholds, deadlines, and penalty structures differ between the two. This guide focuses entirely on the non-domestic, commercial side, since that’s the version relevant to CRE owners, asset managers, and building operators.
Does non-domestic MEES apply in Scotland or Northern Ireland?
No. MEES, as covered in this guide, is England and Wales legislation only, energy efficiency regulation is a devolved matter, and Scotland and Northern Ireland each run their own separate frameworks rather than falling under MEES at all.
Scotland currently has no minimum EPC requirement for commercial landlords whatsoever. The Scottish Government is running its own separate reform, the Energy Performance of Buildings (Scotland) Regulations 2025 introduce a new, multi-metric EPC methodology from 31 October 2026, but this reforms how energy performance is measured, it doesn’t yet impose a mandatory minimum standard on non-domestic property. A Heat in Buildings (Scotland) Bill may eventually introduce something closer to a Scottish equivalent of MEES, but as things stand, it remains a proposal rather than a compliance obligation. Northern Ireland similarly operates its own distinct energy performance framework, separate from both MEES and Scotland’s regime.
For a UK-wide portfolio, this means compliance obligations, and timelines, can differ significantly by jurisdiction, treating the whole portfolio as though it sits under a single MEES-style regime would be a mistake.
Is MEES a rating, or a legal requirement?
What is the current minimum EPC rating required under non-domestic MEES?
MEES is a legal requirement, not a rating. The EPC is the actual measurement, an A to G energy rating a property gets assessed against, and it already existed as its own scheme before MEES came along. MEES is the regulation that sits on top of that rating and says a landlord isn’t allowed to rent a commercial property out if its EPC falls below a set legal minimum.
A useful way to think about it, the EPC is like a speedometer, it measures something. MEES is like the speed limit sign, it doesn’t measure anything itself, it just sets the legally enforced minimum the measurement has to clear. There’s no MEES regulations scorecard and nothing a building “achieves” under MEES on its own terms, a property either has an EPC that clears the current legal floor, or it doesn’t.
The current legal minimum is EPC E. Since 1 April 2018, it’s been illegal to grant a new lease on a commercial property rated F or G, and since 1 April 2023, that extended to existing leases too, meaning a sub-standard lease already in place became unlawful to continue without a registered exemption.
That E minimum is still the actual law today for the vast majority of commercial properties. The 2031 EPC B requirement discussed below is a future threshold that only applies to large buildings, it hasn’t replaced the current E minimum for the market as a whole.
Does non-domestic MEES apply to owner-occupied commercial buildings?
No. MEES regulations only applies where a landlord-tenant lease exists. If a business owns and occupies its own commercial building outright, with no lease in place, there’s no landlord to be restricted from letting a sub-standard property, so MEES simply doesn’t engage.
This is worth being precise about, since it’s a common point of confusion for CRE owners assessing their portfolio’s exposure. A mixed portfolio might include both leased assets subject to MEES regulations and owner-occupied sites that sit outside its scope entirely, and treating them the same way when budgeting for compliance can lead to unnecessary work on assets that were never actually covered.
How does non-domestic MEES treat large commercial buildings differently?
Large commercial buildings sit under a distinct, tighter sub-layer of non-domestic MEES regulations. While the current E minimum applies across the board regardless of size, the government’s June 2026 interim response introduced a separate, higher threshold specifically for buildings over 1,000 square metres, requiring them to reach an EPC B rating by 2031.
Properties below that 1,000 square metre threshold remain on the current E minimum only, with no new deadline yet confirmed for them. This means non-domestic MEES regulations effectively now operates as two tiers, a baseline E requirement applying to all commercial properties today, and a stricter, size-triggered B requirement applying only to larger assets from 2031, subject to a seven-year payback test that limits landlords to works costing no more than their expected energy savings over that period.
What changed with MEES regulations in June 2026?
The government scrapped a five-year-old proposal and replaced it with a narrower, later one. The original 2021 consultation proposed a staged tightening across the whole non-domestic rented sector, an interim EPC C requirement by 2027, then EPC B by 2030. The June 2026 interim response dropped the 2027 milestone entirely.
Instead, as covered above, only buildings over 1,000 square metres face the new EPC B requirement, and only from 2031, later than the original 2030 proposal. The government estimates raising the standard for these largest premises could save tenants £360 million a year in energy costs by 2031. Net effect for CRE owners, smaller assets got more breathing room, while owners of larger buildings got a clearer, though more distant, deadline than originally proposed.
What are the penalties for non-compliance with non-domestic MEES?
Penalties for non-domestic MEES scale with both the length of the breach and the property’s rateable value. For a breach lasting less than three months, the penalty is the greater of £5,000 or 10% of the property’s rateable value, capped at £50,000. For a breach of three months or more, it rises to the greater of £10,000 or 20% of rateable value, capped at £150,000.
Separately, submitting false or misleading information to the PRS Exemptions Register, or failing to comply with a compliance notice, can carry its own penalty of up to £5,000. Enforcement authorities can also publish details of a breach publicly, which carries its own reputational risk beyond the financial penalty itself. Local authorities, generally acting through Trading Standards, are responsible for enforcement.
Non-domestic MEES requirements at a glance
| Building size | Current minimum | Future requirement | Deadline |
|---|---|---|---|
| Under 1,000 sq m | EPC E | No new deadline set | Not yet confirmed |
| Over 1,000 sq m | EPC E | EPC B, where cost effective | 2031 |
Non-domestic MEES penalties for non-compliance
| Breach | Penalty | Maximum cap |
|---|---|---|
| Under 3 months | Greater of £5,000 or 10% of rateable value | £50,000 |
| 3 months or more | Greater of £10,000 or 20% of rateable value | £150,000 |
| False or misleading PRS Exemptions Register information, or failure to comply with a compliance notice | Up to £5,000 | £5,000 |
MEES by UK jurisdiction
| Jurisdiction | Current minimum standard | Status |
|---|---|---|
| England & Wales | EPC E, rising to EPC B for buildings over 1,000 sq m | In force now, 2031 change pending secondary legislation |
| Scotland | No minimum standard for commercial landlords | Own EPC reform underway, no compliance deadline yet |
| Northern Ireland | Separate framework | Runs independently of MEES |
Are there exemptions to non-domestic MEES regulations?
Yes, a range of exemptions can be registered on the national PRS Exemptions Register where compliance genuinely isn’t achievable, including where all cost-effective improvements have already been made, where the cost of the required works exceeds the payback cap, where a qualified assessor has flagged a genuine risk to the building’s fabric, or where a required third party has withheld necessary consent.
Exemptions aren’t permanent, most last five years, with a shorter six month exemption available for landlords who’ve just acquired a property. An exemption is also tied to the landlord who registered it, not the property itself, so a new owner acquiring the building needs to re-register the exemption rather than inheriting it automatically.
Why doesn't the government just call this a minimum EPC requirement?
Because keeping the legal minimum separate from the EPC methodology itself lets the government change the policy without touching the underlying measurement standard. The EPC’s assessment method needs to stay stable and comparable over time, if the minimum threshold, the deadline, or the exemptions lived inside the EPC scheme itself, adjusting any of them would mean rewriting the measurement standard every time policy changed.
This isn’t unique to MEES regulations. NABERS is a rating, and Australia’s Building Energy Efficiency Disclosure Act is the separate legal layer that makes disclosing it mandatory. New York’s Local Law 97 doesn’t invent its own emissions measurement either, it borrows an existing benchmarking standard and applies its own legal cap and penalty on top. Keeping the rating and the legal requirement as two separate things is a deliberate, common regulatory pattern, not a UK-specific oddity.
How can commercial building owners get ahead of the 2031 MEES regulations deadline?
By treating an EPC as a starting point rather than an answer. An EPC reflects a building’s assessed performance on the day it was issued, it says nothing about whether that building is actually tracking toward or away from a future threshold years later. Continuous monitoring of a building’s energy use, heating, ventilation and air conditioning (HVAC) performance, and equipment faults gives owners ongoing visibility into where a property genuinely sits against the 2031 requirement, well before a fresh EPC assessment would reveal it.
For a portfolio with mixed building ages and building management system (BMS) vintages, that visibility matters even more, since identifying which assets are genuinely at risk of falling short, which are large enough to fall under the 2031 sub-layer, and which retrofit investments will actually move the needle, is far harder without ongoing data behind it. The Royal Institution of Chartered Surveyors (RICS) has also flagged energy performance as an increasingly central factor in commercial valuation, meaning this isn’t purely a compliance question, it’s a value one too. For more on how this applies to other UK building performance frameworks, see Bueno’s NABERS UK guide and LEED certification explainer.
Useful links
- gov.uk, Private Rented Property Minimum Standard, landlord guidance, the official government guidance on non-domestic MEES obligations and exemptions.
- legislation.gov.uk, The Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, the underlying legal text MEES is built on.
- gov.uk, Find an energy certificate, the official register for checking a property’s current EPC rating.
- Valuation Office Agency, find the rateable value of a property, the official source for the rateable value figure used to calculate MEES penalty exposure.
Talk to Bueno about MEES regulations and building performance
Want to know more? Contact Bueno for a demonstration of how continuous building analytics helps commercial real estate owners track performance against non-domestic MEES ahead of the 2031 deadline, not just at the point of a new EPC assessment.
