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EPCs and change of use: when a conversion needs a new certificate

Updated 19 October 2026 · SEO Dons Editorial

Changing what a commercial building is used for is not, on its own, one of the events that require an EPC in England and Wales. The duty attaches to construction, sale and letting. A conversion often still ends with a new certificate, because the works or the next transaction trigger one, or because the old EPC no longer describes the building.

Does a change of use trigger a new EPC?

The Energy Performance of Buildings (England and Wales) Regulations 2012 tie the EPC duty to three situations. Government guidance for non-domestic buildings puts it plainly: an EPC is only required when a building is constructed, sold or rented out. It adds that it is the action of selling, renting out or construction that triggers the requirement.

A change of use is not on that list, whatever some online advice suggests. The better question is whether one of the three triggers is happening and, if so, whether the certificate you hold still describes the building being sold, let or completed. Our guide to whether you need a commercial EPC walks through those triggers in full.

What counts as a material change of use?

Regulation 5 of the Building Regulations 2010 says there is a material change of use where there is a change in the purposes for which or the circumstances in which a building is used, so that afterwards it falls into a category it was not in before. For commercial premises, the common ones are a building that becomes:

  • a dwelling, or a building containing a flat;
  • a hotel or boarding house;
  • an institution;
  • a public building;
  • a shop, where previously it was not;
  • a building containing a room for residential purposes.

Where there is a material change of use of a whole building, regulation 6 requires whatever work is needed for the building to meet a set of requirements in Schedule 1, and that set includes L1, the conservation of fuel and power requirement in Part L. So a conversion can bring energy efficiency work with it even before any EPC is due.

Planning is a separate test, and gov.uk notes that building regulations approval is different from planning permission. In England, planning practice guidance says a change of use needs planning permission if it is a material change of use, and that moving between uses within the same use class is not development. Class E groups former shops, offices, cafes and restaurants with uses such as nurseries, health centres and gyms, so many commercial changes of use need no planning application. None of that alters the EPC position.

When does a conversion count as construction for EPC purposes?

The conversion works themselves can trigger an EPC. Regulation 7A applies where a building is erected, or where a building is modified so that it has a greater or lesser number of parts designed or altered for separate use than it previously had, and the modification includes providing or extending fixed services for heating, hot water, air conditioning or mechanical ventilation.

Both halves of that test must be met. For example, a hypothetical two-storey office converted into four separately let suites, each with its own heating, would need an EPC once the work is finished. Turning one shop into one cafe, with no subdivision, would not trigger regulation 7A. Government guidance says an internal refit with new services would not trigger the requirement unless the building were also converted into more or fewer parts for separate use, although the work may still need to meet building regulations.

Where regulation 7A does apply, the person carrying out the building work must give the EPC to the owner and give notice to building control, quoting the certificate's register reference number, no later than five days after the work is completed. Building control will not issue a completion certificate until they are satisfied this has been done. Our guide to EPCs for part of a building explains how separately used units are treated.

Is the old EPC still good enough after a conversion?

An EPC stays valid for 10 years from the date it was entered on the register, unless a newer certificate for the same building has been lodged since. So a certificate produced for the previous use can still be legally valid after a conversion. Whether it is the right one is another matter.

Government guidance says the EPC provided should reflect the accommodation being sold or rented out. The approved software rates each space according to the activity in it, because different activities mean different hours of occupancy, temperatures, lighting and hot water. Where a building is sold or let without fixed services but services will be installed, the guidance says the EPC should be based on the building's use class under planning legislation, so the use feeds directly into the rating.

The same guidance says that where accommodation has been renovated, for example with upgraded heating or a change of use, it would be preferable to have an updated EPC, even though one is not required. If you are letting after a conversion, the rating matters twice: once for the EPC duty and again for the minimum energy efficiency standard, covered on our MEES compliance page.

What if the building was exempt before the conversion?

Some buildings sit outside the EPC rules, including industrial sites, workshops and non-residential agricultural buildings that do not use much energy, temporary buildings used for two years or less, and detached buildings under 50 square metres. A conversion can move a building out of those categories.

Building regulations have a term for this: a change to a building's energy status, meaning any change which results in a building becoming one to which the energy efficiency requirements apply, where previously it was not. Regulation 22 then requires the work needed for the building to comply with Part L. Government guidance describes low-energy-demand industrial buildings as those used for industrial activity in spaces where the air is not conditioned. A hypothetical unheated storage building converted into heated offices no longer fits that description, so it should expect to need an EPC when it is next sold or let.

What changes when commercial space becomes homes?

Converting commercial space into homes is a material change of use, because the building is used as a dwelling where previously it was not. Each new home is a separate dwelling and needs its own EPC, produced with the Standard Assessment Procedure used for dwellings rather than the SBEM model used for commercial space. Any commercial part that remains, such as a ground-floor shop, is still assessed as a non-dwelling.

Where the conversion creates more parts for separate use with new heating or hot water, regulation 7A applies, so whoever carries out the work must provide the certificates on completion. For buildings that combine shops or offices with flats, see our mixed-use EPC page.

How should you plan the EPC around a conversion?

  1. Check the register for an existing certificate and note its lodgement date and what it covers. The government's find an energy certificate service covers business properties and public buildings in England, Wales and Northern Ireland.
  2. Work out whether the works create more or fewer separately used parts with new or extended heating, hot water, air conditioning or mechanical ventilation. If they do, the EPC is part of completion, so build it into the programme.
  3. If the building will be sold or let and has no valid EPC, the seller or landlord must commission one before it is put on the market.
  4. Commission the assessment once the works and layout are settled, so the certificate describes the building as it will be used.

The certificate itself must come from an accredited non-domestic energy assessor, who has to confirm the building's details by inspecting it. If you are still unsure which trigger applies, start with our checklist of when a commercial EPC is required. You can request quotes from assessors through the form on this site.

Sources

Common questions

If my shop becomes a cafe, do I need a new EPC straight away?

Not straight away. A change of use is not an EPC trigger on its own, and an internal refit without subdivision does not trigger the construction rule. You will need a valid EPC when the premises are next sold or let, and government guidance says an updated certificate is preferable after a change of use.

Does a planning application for change of use require an EPC?

No. The EPC regulations are triggered by construction, sale and letting, not by a planning application. Planning permission and building regulations approval are separate, and gov.uk notes that a project might need both.

Who provides the EPC when a building is split into separate units?

Where the works create more or fewer parts for separate use and add or extend heating, hot water, air conditioning or mechanical ventilation, the person carrying out the building work must give the EPC to the owner. The certificate and notice to building control are due no later than five days after the work is completed.

Can the EPC from before the conversion still be used?

It stays legally valid for up to 10 years from lodgement, unless a newer certificate for the building has been lodged. But the EPC should reflect the accommodation being sold or let, so a certificate modelled on the old use may not describe the converted building.

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