Beyond EPCs: How commercial property owners in England and Wales can prepare for the next phase of MEES

‍The Government's latest announcement on non-domestic Minimum Energy Efficiency Standards (MEES) has provided much-needed clarity for the commercial property sector. While the direction of travel remains firmly towards improved energy performance and lower carbon emissions, the latest proposals represent a significant shift from some of the more ambitious measures originally consulted upon.

‍For landlords, investors and occupiers, the challenge now is understanding which assets are likely to be affected, where investment should be prioritised, and how compliance can be achieved in the most cost-effective manner.

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A More Targeted Approach to Non-Domestic MEES

‍The original consultation proposed a substantial tightening of energy efficiency requirements across the non-domestic private rented sector. Among the most significant proposals were:

• A requirement for rented commercial properties to maintain a minimum EPC rating at all times throughout a tenancy, and potentially a shorter validity period (via revised EPC regulations).

• The introduction of a trajectory towards EPC B, via EPC C.

‍However, in the Government's partial response to the EPC consultation published in January 2026, several of the more immediate proposals were pushed back for further consideration, and now the MEES requirement is also somewhat watered down.

In January the requirement for rented properties to have an EPC at all times was referred for further consultation, and the validity period was confirmed to be remaining at 10 years.

‍The latest Written Ministerial Statement on MEES (https://questions-statements.parliament.uk/written-statements/detail/2026-06-18/hcws126) continues this trend towards a more targeted approach. Rather than imposing blanket requirements across the entire commercial property market, the Government has indicated that the future EPC B target will be only for rented buildings exceeding 1,000m², with implementation proposed from 2031. All current exemption pathways (Seven-year payback, consent exemptions etc) will remain.

‍What is not yet confirmed is how larger buildings split into smaller units will be treated. Under the EPC regulations a 9,000 m² office split into 10 equal demises could mean one EPC for the whole thing, or 10 smaller unit EPCs. The devil will be in the detail.

‍For many property owners, this announcement represents a welcome reduction in immediate regulatory pressure. However, it should not be interpreted as a relaxation of long-term expectations. Commercial buildings will need to become more energy efficient, and those with poor-performing assets will face increasing pressure from tenants, investors, lenders and, potentially, future regulation.

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The Benefits of Combining SBEM and Dynamic Simulation Modelling

‍SBEM remains the recognised methodology underpinning most non-domestic EPC assessments and will continue to play a critical role in demonstrating regulatory compliance.

‍However, relying solely on SBEM can result in missed opportunities.

‍Dynamic Simulation Modelling (DSM) allows building performance to be analysed on an hourly basis throughout the year.

‍DSM can identify more targeted improvement measures and avoid unnecessary capital expenditure. For larger commercial assets now falling within the scope of future MEES regulations, undertaking both SBEM and DSM assessments at an early stage can provide a powerful evidence base for decision-making and potentially significantly reduce the capital expenditure required to meet the future target.

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Different Building Types Face Different Challenges

‍One of the difficulties with a blanket EPC target is that commercial property is far from uniform.

‍The route to compliance for a logistics warehouse is very different from that of a city-centre office building.

‍Warehouses and Industrial Buildings

‍For modern logistics facilities and industrial buildings, the pathway to improvement is often relatively straightforward though de-gassing large spaces can be an issue.

‍These buildings typically benefit from:

• Large roof areas

• Lower occupancy densities

• Simpler servicing requirements

• Significant opportunities for solar PV deployment

‍In many cases, rooftop photovoltaic installations can deliver substantial EPC improvements while simultaneously reducing operational energy costs.

‍LED lighting upgrades, controls improvements and targeted fabric enhancements can often deliver further gains at comparatively low cost.

‍The challenge tends to be less about technical feasibility and more about investment timing, landlord-tenant arrangements and grid connection capacity.

‍Retail Warehouses

‍Retail warehouse assets share many of the same characteristics as industrial buildings.

‍Large roof areas provide excellent opportunities for solar PV, while extended trading hours can help maximise on-site utilisation of generated electricity.

‍However, retail operators are often highly sensitive to disruption. Asset owners therefore need carefully planned upgrade programmes that align with lease events and operational requirements.

‍DSM can be particularly valuable in identifying the optimum balance between renewable generation, HVAC improvements and lighting upgrades.

‍Deep Plan Offices

‍Office buildings frequently present a more complex challenge.

‍Many office assets constructed between the 1980s and early 2000s rely heavily on gas-fired air handling systems and all-air conditioning strategies.

‍These buildings may suffer from:

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• High heating demand

• Significant fan energy consumption

• Ageing controls infrastructure

• Limited plantroom space

• Constraints associated with occupied refurbishment

‍Simply replacing gas-fired systems with electric alternatives is rarely straightforward.

‍Heat pump retrofits can require extensive modifications to distribution systems, electrical infrastructure and controls. Occupant comfort considerations must also be carefully managed.

‍This is where DSM can provide significant value. Rather than defaulting to wholesale replacement, building owners can develop evidence-based improvement strategies that help with managing capital expenditure.

‍Older Multi-Let Commercial Buildings

‍Older town-centre offices, mixed-use assets and multi-let commercial properties may prove among the most challenging building types.

These buildings often combine:

• Poor fabric performance

• Historic alterations

• Limited landlord control over energy use

• Space constraints for new plant

‍Achieving significant EPC improvements can require a combination of fabric upgrades, services improvements and renewable technologies.

Early-stage modelling becomes particularly important to avoid investing in measures that deliver limited regulatory benefit.

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Looking Ahead

‍For owners of larger rented assets, the key question is no longer whether change is coming, but how to prepare for it in the most commercially sensible way.

Those who begin evaluating their portfolios now, using both SBEM and Dynamic Simulation Modelling, will be far better positioned to identify cost-effective upgrade pathways, minimise stranded asset risk and avoid unnecessary capital expenditure.

As future MEES requirements increasingly focus on larger commercial buildings, understanding potential opportunities in each building will prove to be the difference between an efficient investment strategy and an expensive compliance exercise. And bear in mind that the future regulations may not cover buildings under 1,000m², but tenants, investors and lenders may well not see the distinction between buildings over the threshold and those under it.

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Contact MEES Solutions on 0333 566 0182 for common sense compliance advise.

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