Commercial EPC changes 2026 to 2028: confirmed, proposed and dropped

Updated 23 October 2026 · SEO Dons Editorial

Are there new commercial EPC requirements in 2027?

No. No government source checked for this guide sets a new commercial EPC or MEES requirement for 2027. The one that had been proposed, an interim EPC C milestone, was dropped on 18 June 2026. This change log was checked on 22 October 2026. What binds a landlord today is the existing law, set out on the MEES compliance page, and guidance that still quotes earlier dates is out of date.

In force now in England and Wales:

EPC E minimum. A landlord of a covered letting must not grant, extend or renew a tenancy of a property whose valid EPC is below E unless an exemption is registered. Since 1 April 2023 the ban also covers continuing to let. Most fixed lettings of six months or less, and leases of 99 years or more, are outside the rules.
Validity. An EPC lasts 10 years unless a newer one replaces it.
Protected buildings. A listed or officially protected building needs no EPC only where the minimum energy performance requirements would unacceptably alter it.

What is the timeline for commercial EPC and MEES changes?

Status matters more than date. "Law" is in force. "Intends" is a stated plan to make regulations. "Proposed" needs secondary legislation before it binds anyone.

When	What	Status	Source
1 April 2018 and 1 April 2023	EPC E minimum for covered lettings: new, renewed and extended tenancies from 2018, continuing lettings from 2023	Law, England and Wales	SI 2015/962, regulation 27
21 January 2026	EPC at the point of marketing; heritage exemptions removed; 10-year validity kept; carbon-based rating kept as the non-domestic headline	Government intends, through regulations	EPC reform partial response
9 March 2026	Launch of the reforms, in an update about domestic EPCs, moved to the second half of 2027	Timetable	Consultation page
5 May 2026	Landlord guidance updated for a new exemptions service	In operation	gov.uk landlord guidance
18 June 2026	Interim EPC C milestone for 2027	Dropped	Interim response
18 June 2026	EPC B from 2031 for private rented buildings over 1,000 square metres, where cost effective; E intended below that	Proposed	Interim response
30 October 2026	Scotland: draft amendment would come into force	Draft, unmade on 22 October 2026	Draft amendment regulations
31 October 2026	Scotland: 2025 Regulations start	Law as made	SSI 2025/417, regulation 1
30 April 2028	Scotland: full commencement if the amendment is made	Draft	Draft amendment regulations

What does the government intend to change about EPCs?

The partial response to the EPC reform consultation says that, subject to parliamentary approvals, the government intends to bring forward regulations in 2026. For commercial buildings, four points matter.

EPC at the point of marketing. It intends to require an EPC when a property is marketed, rather than at sale or rent. Today an EPC must be commissioned before marketing, but the current regulations allow up to 28 days after marketing to obtain it.
Heritage properties. It intends "removing exemptions for heritage properties". The consultation proposed that "all heritage buildings are required to have an EPC" and does not confine that to homes, but neither document names commercial buildings separately. The listed-building exemption stands until regulations change it: see do listed commercial buildings need an EPC?
Validity and rating. It intends to keep 10-year validity for reformed EPCs and the carbon-based Environmental Impact Rating as the headline non-domestic metric.
EPCs throughout a tenancy. The government is "working to refine the position" on requiring a new EPC when one expires. A further response due in 2026 "will include an update on whether valid EPCs will be required throughout private rented tenancies". The consultation page still showed 9 March 2026 as its last update on 22 October 2026.

On 9 March 2026 the government "decided to move the launch of the reforms to the second half of 2027", in an update about reformed domestic EPCs. The new domestic metrics, HMO and short-let changes are domestic and not covered here.

What is proposed for MEES, and what was dropped?

The interim response of 18 June 2026 says "from 2031, it is proposed" that private rented buildings over 1,000 square metres reach EPC B, where cost effective. For smaller buildings "the intention" is to stay at the current EPC E minimum.

Dropped: the interim EPC C milestone for 2027 "will not be taken forward".
Kept: the 7-year payback test and exemptions "will remain in place".
Not yet law: the changes "will only take effect following the successful passage of secondary legislation through Parliament".
Still to come: "implementation of the threshold", meaning how the 1,000 square metres will be measured, is left to a forthcoming government response.

Read the verbs. "Proposed", "the intention is" and "intend" describe plans, and "will not be taken forward" describes a dropped step. Only regulations made by Parliament change what a landlord must do. The 2031 proposal is covered in EPC B by 2031: what the new commercial MEES standard means.

What is changing in Scotland?

The England and Wales MEES rules do not apply in Scotland, which has separate section 63 regulations for owners of non-domestic buildings, explained in commercial EPCs in Scotland. The changes below concern EPCs themselves.

The Energy Performance of Buildings (Scotland) Regulations 2025 say that, apart from a few provisions that started on 1 January 2026, they "come into force on 31 October 2026". A draft amendment, laid for approval by resolution of the Scottish Parliament, would substitute "30 April 2028" for that date and move the transitional dates to match. On 22 October 2026 legislation.gov.uk still described it as a draft that "has not yet been made as a Scottish Statutory Instrument". As drafted, its main provisions would come into force on 30 October 2026, the day before the 2025 Regulations' main start date.

The Scottish Government's update of 24 August 2026 says the regulations "will now be amended to come into force on 30 April 2028", for domestic and non-domestic EPCs alike. Once in force, a non-domestic EPC ceases to be valid after 5 years. Check the instrument's status on legislation.gov.uk before relying on either date.

What should owners and landlords do with this?

Treat EPC E as the working minimum for covered lettings, and check each renewal or extension against the current MEES rules.
For privately let buildings over 1,000 square metres, note the gap between the current rating and B, but treat 2031 as a proposal until regulations are made.
Check the date on any guidance. Anything older than the 18 June 2026 response may quote dates that were dropped.
Watch for the further EPC reform response, MEES regulations and, in Scotland, the made instrument.

For a building with no valid EPC, an enquiry can be sent through the form on this site. The commercial EPC law explainer shows how the underlying regulations fit together.

Sources

MEES in the non-domestic private rented sector: interim response, DESNZ, GOV.UK, updated 18 June 2026, checked 22 October 2026.
Reforms to the Energy Performance of Buildings regime: partial government response, MHCLG, GOV.UK, checked 22 October 2026.
Reforms to the Energy Performance of Buildings regime, consultation page, GOV.UK, last updated 9 March 2026, checked 22 October 2026.
Non-domestic private rented property: landlord guidance, DESNZ, GOV.UK, last updated 5 May 2026, checked 22 October 2026.
Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, regulations 20 and 27, legislation.gov.uk, checked 22 October 2026.
Energy Performance of Buildings (England and Wales) Regulations 2012, regulations 5, 7 and 9, legislation.gov.uk, checked 22 October 2026.
Energy Performance Certificates for your business premises, GOV.UK, checked 22 October 2026.
Energy Performance of Buildings (Scotland) Regulations 2025, regulations 1 and 8, legislation.gov.uk, checked 22 October 2026.
Draft Energy Performance of Buildings (Scotland) Amendment Regulations 2026, legislation.gov.uk, checked 22 October 2026.
Energy Performance Certificate Reform: updates, Scottish Government, published 27 August 2026, checked 22 October 2026.
Energy performance of existing non-domestic buildings: information, Scottish Government, checked 22 October 2026.

Common questions

Will commercial EPCs stop being valid after 10 years?

Not in England and Wales on current evidence. The reform response says the government intends to keep the 10-year validity period for reformed EPCs, and existing EPCs keep their 10 years. In Scotland, once the 2025 Regulations are in force, an EPC ceases to be valid after 5 years.

Is the listed building exemption for EPCs changing?

It is meant to, but it has not changed yet. The reform response says the government intends to remove exemptions for heritage properties. Regulation 5 of the 2012 Regulations still applies, so the existing protected-building exemption governs.

Does the proposed EPC B standard affect a building I occupy myself?

The interim response refers to private rented buildings, and MEES is a rule about letting: regulation 27 says a landlord of a sub-standard property must not let it. A building you occupy yourself is not let, although it needs an EPC if you sell or let it. Check the regulations when they are made, because the threshold detail is left to a later document.

Which Scottish date should I plan around, 31 October 2026 or 30 April 2028?

The 2025 Regulations as made say 31 October 2026. The draft amendment would change that to 30 April 2028, and the Scottish Government has said it will, but on 22 October 2026 the instrument had not been made. Check legislation.gov.uk for the made instrument before relying on either date.