Commercial MEES Update 2026: What EPC B Means for Larger Commercial Buildings

The Government’s June 2026 interim response on non-domestic Minimum Energy Efficiency Standards is the most important commercial property energy update this month.

For several years, the market has worked around the expectation that non-domestic rented buildings would need to move towards EPC B by 2030. The latest position is more targeted. The Government has indicated that larger commercial buildings above 1,000 m² will be required to meet EPC B from 2031, subject to secondary legislation. Smaller buildings are expected to remain at EPC E, subject to exemptions.

That does not remove the problem. It sharpens it.

For landlords and asset managers, the key question is no longer whether every building is exposed in the same way. It is which buildings in the portfolio are large enough, inefficient enough, or strategically important enough to need attention first.

Why this matters commercially

Energy performance is now a leasing, valuation and capital planning issue. EPC risk can affect:

• lettability

• lease renewals

• dilapidations strategy

• refurbishment scope

• acquisition due diligence

• capital expenditure planning

• occupier ESG requirements

• investor reporting

Across many commercial projects, one of the common issues we see is that EPC improvement is considered too late. By the time a lease event, refinancing exercise or sale process starts, there may be limited time to review the building properly, test options and agree a sensible improvement plan.

That usually leads to reactive decisions. LED lighting is installed because it is visible and easy to procure. Controls are adjusted because they are low cost. Plant replacement is discussed, but often without enough modelling to confirm whether it will move the EPC rating far enough.

A proper EPC strategy needs to look at the building as a system.

What has changed?

The June 2026 Government response gives the market a clearer direction. The most important points are:

Larger buildings are the priority

The proposed EPC B requirement is focused on commercial buildings above 1,000 m². This is likely to capture many office, retail, industrial, healthcare and education assets, especially multi-let or managed properties.

Timing has shifted

The target date is now indicated as 2031, subject to legislation. That may feel like a long way away, but for buildings requiring major services upgrades, it is not. Chillers, boilers, VRF systems, controls, risers and electrical infrastructure all sit within wider refurbishment and leasing cycles.

EPC E remains relevant for smaller buildings

Smaller buildings are not removed from MEES altogether. EPC E remains the baseline expectation, subject to exemptions. This still matters for older retail units, small offices, light industrial premises and local authority portfolios.

Practical implications for landlords

Landlords should start by identifying which assets are above 1,000 m² and what their current EPC position is. The next step is to separate quick wins from capital works.

Typical measures may include:

• LED lighting and improved lighting controls

• BMS optimisation

• boiler replacement or low-carbon heat options

• chiller or VRF upgrades

• heat recovery improvements

• ventilation control improvements

• domestic hot water rationalisation

• metering and energy monitoring

• fabric upgrades where practical

• solar PV where commercially viable

The highest risk buildings are usually older assets with gas-fired heating, poor controls, inefficient lighting, high ventilation loads, or cooling systems approaching end of life.

What this means for managing agents

Managing agents will be on the front line. They will need to help clients understand which buildings need attention, what evidence is available and which works can be aligned with service charge, planned maintenance or refurbishment.

In our experience, managing agents benefit from having a clear technical summary for each building. This should include current EPC rating, expiry date, likely improvement measures, plant condition, landlord-controlled systems, tenant-controlled systems and known constraints.

Without that, discussions become fragmented.

What this means for developers

For developers and refurbishment teams, the MEES update strengthens the need to design beyond basic compliance. A refurbishment that reaches practical completion with a weak EPC rating may create a future letting problem.

Design teams should test EPC outcomes early, especially where the project involves:

• replacement heating or cooling plant

• major lighting changes

• ventilation strategy changes

• shell and core upgrades

• change of use

• Cat A refurbishment

• landlord demise works

• major tenant fit-out interfaces

What this means for occupiers

Occupiers should not ignore MEES. The cost and disruption of improvement works can affect lease negotiations, reinstatement obligations and operational continuity.

For larger buildings, occupiers should ask:

• Who controls the main plant?

• Who pays for upgrades?

• Are planned works likely during the lease term?

• Will tenant fit-out affect the EPC?

• Are sub-metering and energy data reliable?

• Can ESG reporting requirements be supported?

What this means for project teams

Project teams should treat EPC performance as a design constraint, not a certificate exercise at the end.

A sensible process would include:

1. Establish the current position

Review the existing EPC, recommendation report, building services condition and known operational issues.

2. Test realistic improvement options

Model practical measures rather than theoretical upgrades that may never be delivered.

3. Align with capex planning

Link EPC improvement to plant replacement, lease events and refurbishment programmes.

4. Review constraints

Consider electrical capacity, riser space, roof plant zones, planning constraints, tenant occupation and maintenance access.

5. Record decisions clearly

Keep a clear audit trail showing which measures were reviewed, which were viable and which were not.

Common client questions

Do we need to upgrade every commercial building to EPC B?

Not on the current June 2026 position. The Government’s interim response points towards EPC B for buildings above 1,000 m² from 2031, subject to legislation. Smaller buildings remain linked to EPC E, subject to exemptions.

Should we wait for the final legislation?

No. For low-risk buildings, monitoring may be enough. For larger, older or strategically important assets, waiting could make future works more expensive and harder to programme.

Is an EPC review the same as a decarbonisation plan?

No. EPCs are compliance tools. A decarbonisation plan should also consider real energy use, operational carbon, plant life, maintenance, occupier needs and investment timing.

Can lighting alone achieve EPC B?

Sometimes it helps significantly, but it should not be assumed. Heating, cooling, ventilation, controls and fuel type can all materially affect the rating.

How J-WEBS can help

J-WEBS supports landlords, managing agents and project teams with:

• EPC Portfolio Reviews

• MEES Readiness Plans

• Building Performance Reviews

• Decarbonisation Strategies

• Technical Due Diligence

• Plant replacement feasibility studies

• Cat A and landlord refurbishment advice

• Licence to Alter reviews

The most useful starting point is usually a short technical review of the asset or portfolio. This identifies the buildings that need attention first and avoids spending money on measures that do not materially improve compliance or performance.

Call to action

Landlords and managing agents should use 2026 to identify their exposed assets. A short EPC and building services review now can avoid rushed decisions later, especially for larger buildings where plant replacement, electrical capacity and tenant occupation need proper planning.