What the New MEES Rules Mean for Your Commercial Property
The government has published its long-awaited interim response on commercial property energy efficiency standards, specifically the non-domestic Minimum Energy Efficiency Standards (MEES) in England and Wales, and the picture looks quite different from what was originally proposed.
For landlords and tenants of commercial property, the key message is this: the goalposts have moved, and in some cases, moved in your favour.
Breaking it down:
Rather than pushing all non-domestic buildings toward the same targets on the same timeline, the government has opted for a more targeted approach, concentrating regulatory pressure on larger commercial assets while easing the burden on smaller premises.
Here is what has been confirmed:
From 2031, buildings over 1,000 sq m must achieve EPC B (where it is cost-effective to do so). This applies to all privately rented non-domestic buildings above that size threshold and represents the clearest compliance deadline in the new framework.
Buildings under 1,000 sq m are not required to target EPC B or C. Smaller commercial premises — including much of the high street, will only need to meet the existing minimum standard of EPC E. This is a significant departure from earlier proposals and will come as a relief to many SME landlords and occupiers.
The 2027 EPC C interim milestone has been scrapped. Previously, landlords were expected to reach EPC C by 2027 as a stepping stone toward higher standards. That requirement has been formally dropped, giving both parties more flexibility to plan energy improvements around natural lease events rather than an arbitrary regulatory deadline.
Existing safeguards remain in place. The 7-year payback test, which means landlords are not required to carry out improvements that cannot be recouped within seven years, continues to apply. Valid exemptions also remain available where compliance is not financially or practically achievable.
What does this mean in practice?
If you own or occupy a commercial building over 1,000 sq m, 2031 is the date to plan around. That may sound a long way off, but achieving EPC B in a large building often involves meaningful capital investment: insulation upgrades, new heating systems, lighting overhauls, or renewable energy installations. The earlier you begin to assess your position, the more options you have, and the more control you retain over timing and cost.
If your building is under 1,000 sq m, the immediate compliance pressure has eased. EPC E remains the floor, and there is no current obligation to go further. That said, commercial property energy efficiency is increasingly factored into occupier decisions and asset valuations. and asset valuations, so proactive improvement still makes commercial sense even where it is not legally required.
For lease negotiations, rent reviews, and acquisitions currently in progress, these changes are directly relevant. The removal of the 2027 milestone alters the risk profile of properties that would have fallen short of EPC C, and that should be reflected in how deals are structured and priced.
What comes next:
These changes are not yet law. They will take effect once secondary legislation has successfully passed through Parliament. Full technical guidance is also still to be published, and we expect further detail on how the cost-effectiveness test will be assessed for larger buildings.
At Kinney Green, we are monitoring developments closely and will provide further updates as the legislation progresses. If you would like to discuss how these changes affect a specific asset or your wider portfolio, please get in touch with our team.

Kinney Green is a chartered surveyors and property advisors company operating on London Commercial property. This article is intended as general guidance and does not constitute legal or regulatory advice.
















