Commercial EPC rated E: can you still let the building?
Updated 23 October 2026 · SEO Dons Editorial
Can you let a commercial building rated E?
Yes, if the letting is a covered one in England and Wales. Regulation 22 of the MEES regulations sets the minimum level of energy efficiency at band E, and a property is sub-standard only where its valid EPC is below that. The landlord guidance says that since 1 April 2018 landlords have been permitted to grant, extend or renew a tenancy if the property has at least EPC E, and that from 1 April 2023 the same applies to existing lettings. A building at E meets the test, so no exemption is needed: properties improved to at least E "will not need to be registered". The full rules are on the MEES compliance page.
The regulations apply to England and Wales, and many lettings are outside them, for example fixed terms of six months or less (with exceptions) and leases of 99 years or more. For those the rating does not decide whether the building can be let.
What does an E rating measure?
A non-domestic EPC rates a building from A+ at the efficient end to G at the other. MHCLG's guide says the rating is "a carbon dioxide (CO2) based index" and an asset rating, based on the fabric of the building and services such as heating, ventilation and lighting, that reflects "the age and condition of the building". The consultation adds that modelled carbon dioxide emissions per square metre form the basis of the headline rating.
The reform response says the government will keep that carbon-based Environmental Impact Rating as the headline metric for non-domestic EPCs. Any change to non-domestic metrics would be made through updates to the National Calculation Methodology.
How common is an E rating on commercial EPCs?
MHCLG's Table A counts non-domestic EPCs lodged in England and Wales by rating. Lodgements are not the building stock, because an EPC is required when a building is constructed, sold or let and no valid certificate is in place, but they show what new certificates say. The figures below are calculated from the table, with data to 30 June 2026, and E has become less common.
| Year | EPCs lodged | Rated E | Share rated E |
|---|---|---|---|
| 2018 | 90,035 | 17,654 | 19.6% |
| 2020 | 72,721 | 11,491 | 15.8% |
| 2022 | 112,487 | 11,671 | 10.4% |
| 2024 | 102,851 | 7,567 | 7.4% |
| 2025 | 93,343 | 6,193 | 6.6% |
| January to June 2026 | 45,180 | 2,800 | 6.2% |
The pattern is local. In the four quarters to June 2026, E was 6.4% of lodgements across England and Wales but 12.0% in Hull and in Nottingham.
| Area, four quarters to June 2026 | EPCs lodged | Rated E | Share rated E |
|---|---|---|---|
| England and Wales | 90,448 | 5,755 | 6.4% |
| Kingston upon Hull | 468 | 56 | 12.0% |
| Nottingham | 491 | 59 | 12.0% |
| Leeds | 1,213 | 78 | 6.4% |
| Bristol | 850 | 41 | 4.8% |
For context, MHCLG's release for April to June 2026 says 44% of English non-domestic EPCs were rated A+, A or B (35% in Wales). MHCLG revised its local authority tables on 19 May 2026 after a processing error and says the overall impact was small.
What can move a building off E?
E is not a fixed property of the building. Four things can change the rating on the register.
- A newer EPC. Under regulation 22 an EPC is valid if it was lodged within the last 10 years and no other EPC has since been entered. A certificate commissioned for a sale, a new letting or after works therefore becomes the valid one, whatever band it shows.
- A change to the building. A new EPC is required where the number of parts used for separate occupation changes and the change involves providing or extending fixed heating, air conditioning or mechanical ventilation.
- The methodology. The asset rating must be calculated in accordance with the methodology approved by the Secretary of State. The consultation says the transition should aim to ensure that "those who have already met requirements are not penalised under the new metrics".
- Inputs outside the owner's control. Respondents to the consultation observed that the current rating "is influenced by the carbon-intensity of electricity generation, which is outside the building owners' control".
Does an E rating meet the proposed EPC B standard?
No, and that matters for larger buildings. The interim response of 18 June 2026 says "from 2031, it is proposed" that private rented buildings over 1,000 square metres in England and Wales reach EPC B, where cost effective, while "the intention" is for smaller buildings to stay at EPC E. The changes "will only take effect following the successful passage of secondary legislation through Parliament", and the payback test and exemptions stay in place.
For example, a 1,400 square metre warehouse let to one tenant with a valid EPC at E can be let today. If the proposal becomes law as described, it would sit in the group expected to need B from 2031, where cost effective. EPC B by 2031 explains the proposal, and how to improve a commercial EPC rating covers routes to a higher band.
No regulation tells buyers or lenders how to treat an E. The reform response records financial institutions as benefiting from up-to-date energy performance information, but what a particular buyer or lender requires is for them to say.
What should the landlord of an E-rated building check?
- Find the EPC on the register and confirm it covers the right unit, when it was lodged and when its 10 years end. The commercial EPC checker tests the dates.
- Read the recommendation report: the measures it lists show where headroom could come from.
- List coming lease events, because each renewal or extension is tested against the rating on the valid EPC.
- If the building is let and over 1,000 square metres, note the gap to B but treat 2031 as a proposal.
- Before commissioning a new EPC for any reason, remember that it replaces the existing one whatever it shows.
A reader who needs a current EPC can send an enquiry through the form on this site. The wider rules, including exemptions, are on the MEES compliance page.
Sources
- 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, 22 and 27, legislation.gov.uk, checked 22 October 2026.
- Energy Performance of Buildings (England and Wales) Regulations 2012, regulation 9, legislation.gov.uk, checked 22 October 2026.
- Guide to EPCs for the construction, sale and let of non-dwellings, MHCLG, GOV.UK, updated 11 December 2017, checked 22 October 2026.
- Energy Performance Certificates for your business premises, GOV.UK, checked 22 October 2026.
- MEES in the non-domestic private rented sector: interim response, DESNZ, GOV.UK, updated 18 June 2026, checked 22 October 2026.
- EPB reform: partial government response and the consultation document, MHCLG, GOV.UK, checked 22 October 2026.
- Live tables on Energy Performance of Buildings Certificates (Table A, non-domestic), MHCLG, GOV.UK, data to June 2026, last updated 7 September 2026, checked 22 October 2026. Figures in the tables above are calculated from Table A.
- EPB Certificates statistical release: April to June 2026, MHCLG, GOV.UK, published 30 July 2026, checked 22 October 2026.
Common questions
Can I renew a lease on a building rated E?
Yes, as far as MEES goes. A building at E is not sub-standard, so renewing or extending the tenancy does not need an exemption. The rating on the valid EPC must still be E or better when the tenancy is granted, so check the register first.
Does an E rating expire sooner than other ratings?
No. All EPCs are valid for 10 years from lodgement, whatever the band, and a newer EPC replaces an older one. The reform response says the government intends to keep the 10-year period for reformed EPCs.
Will an E-rated building still be lettable if EPC B becomes law?
Not necessarily. Under the proposal a private rented building over 1,000 square metres would need EPC B from 2031 where cost effective, so E would not be enough for those buildings. For smaller buildings the intention is to stay at E, and the existing exemptions remain.
Does the E minimum apply in Scotland?
No. The MEES regulations set a minimum for rented property in England and Wales. Scotland uses separate section 63 regulations for owners of non-domestic buildings, which work through an Action Plan rather than a minimum band.