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EPCs for new commercial buildings

Updated 19 October 2026 · SEO Dons Editorial

Every new non-domestic building in England and Wales needs an EPC when it is finished. The duty sits with whoever carries out the building work, not the eventual buyer or tenant, and it is tied into building control sign-off. Behind the certificate sits a second document, the BRUKL report, which shows building control that the design meets Part L. This guide explains both, and what changes from March 2027.

What is an on-construction EPC?

Regulation 7A of the Energy Performance of Buildings (England and Wales) Regulations 2012 applies when a building is erected. Government guidance summarises the result: when a building being constructed is physically complete, the person carrying out the construction must give an EPC and recommendation report to the owner.

It is the same kind of certificate as any other commercial EPC, an asset rating on a scale of A+ to G, calculated with an approved implementation of the National Calculation Methodology, which means SBEM or an approved dynamic simulation model. The assessor must hold the right level of accreditation; government guidance notes that Level 3 does not require competence in new build. Our explainer on SBEM Level 3, Level 4 and DSM covers which level suits which building. Construction is one of three triggers; sale and letting are the others, set out in our guide to whether you need a commercial EPC.

Who must provide it, and when?

The regulations treat the person who carries out the construction as the relevant person, so who that is depends on how the project is contracted. Regulation 7A requires that person to:

  • give the EPC to the owner of the building;
  • give notice to the local authority that this has been done, including the reference number under which the certificate was registered;
  • do both no later than five days after the building work has been completed.

In England, where a registered building control approver is supervising the work, the notice goes to the approver instead of the local authority. Either way, building control will not issue a completion certificate until it is satisfied the EPC has been given. Complaints about missing or invalid EPCs on newly built property go to building control; the duty is also enforced by local weights and measures authorities, with a non-domestic penalty worked out by formula between £500 and £5,000.

Once the building is occupied, the certificate may also need to go on the wall. If a building over 500 square metres is frequently visited by the public, an EPC produced on construction must be displayed, as explained in our guide to displaying a commercial EPC.

How does building control check the energy design?

A new building has to meet energy targets, not only produce a certificate. It must not exceed its target CO2 emission rate and, in England, its target primary energy rate, and it must be a nearly zero-energy building. Regulation 27 sets the reporting timetable for the emission figures:

  1. Before work starts: no later than the day before, the person carrying out the work gives building control a notice of the target and designed emission rates with a list of specifications.
  2. After completion: no later than five days after the work is completed, a second notice gives the as-built figures and any changes to those specifications.

Building control is authorised to accept a certificate from an accredited energy assessor as evidence that the emission target has been met, and the design-stage and as-built reports described below let it check that what was designed has been built. That makes the design-stage figures worth getting right.

What is the BRUKL report, in plain words?

BRUKL stands for Building Regulations UK Part L. It is a compliance report that SBEM produces as a standard output, showing the building's calculated primary energy rate and emission rate against the targets, with the list of specifications behind them. Approved Document L Volume 2 expects two versions:

  • Design stage, produced before works begin, based on the design.
  • As built, produced at completion, based on what was actually installed. The software compares the two input files and lists the changes.

The as-built report is signed by the energy assessor to confirm the calculations are accurate, and by the client, usually the developer, to confirm the building was constructed to the specification. Think of the BRUKL as a pass or fail check against Part L for building control, and the EPC as the A+ to G rating lodged on the register that buyers and tenants see. The same calculation engine sits behind both, so late changes to glazing, lighting or plant feed into each.

What about shell-and-core and speculative buildings?

Shell-and-core buildings are often sold or let before the heating, ventilation and air conditioning are installed. Government guidance says a shell-and-core EPC is based on the most energy intensive fit-out allowed by Part L, and that where no services are installed, Part L defaults to the worst energy rating it allows. When the fit-out is done, the services will be as assumed or more efficient if the tenant chooses a better specification.

Two practical consequences follow. A speculative unit's first EPC can look worse than the finished building will be. And the first fit-out of a shell-and-core building follows the Part L guidance for new buildings, according to Approved Document L, so the fit-out has to meet Part L in its own right, even though it does not automatically produce a new certificate.

What changes for new buildings from March 2027?

In England, the regulations implementing the Future Homes and Buildings Standards come into force on 24 March 2027, and on 24 September 2027 for higher-risk building work. They do not apply where a building notice, initial notice or full plans application was given before 24 March 2027, provided the work starts before 24 March 2028. Among the changes, fixed building services will include lifts, escalators and moving footways in new non-domestic buildings.

A 2026 edition of Approved Document L Volume 2 has been published for the new standards, while earlier versions continue to apply to buildings under previous standards. The same transitional protection lets earlier versions of the calculation methodologies continue to be used. In Wales, a revised Volume 2 for buildings other than dwellings takes effect on 4 March 2027. In England, for projects near those dates, the notice date and start date decide which targets the BRUKL report, and the EPC, are calculated against.

What happens to the certificate after completion?

Once produced, the EPC is lodged on the central register and is valid for 10 years. It can be reused if the building, or a unit it covers, is sold or let in that period. The refurbishment and extension guide explains when later works call for a new one. If you are commissioning an on-construction EPC, you can request quotes from accredited assessors through the form on this site; it helps to have the design-stage BRUKL and specification ready. Before marketing completed units, check whether each unit needs its own EPC, because the certificate should reflect the accommodation being sold or let.

Sources

Common questions

Can we market a new development before the EPC exists?

Yes. The regulations say nothing requires an EPC to be given to a prospective buyer or tenant before construction of the building is complete. Once it is complete, the normal duties on sale and letting apply.

Is the BRUKL report the same thing as the EPC?

No. The BRUKL report shows building control that the design and the as-built building meet the Part L targets. The EPC is the A+ to G asset rating lodged on the register, which the owner receives and later buyers and tenants see.

Who pays the penalty if the on-construction EPC is not provided?

The duty sits with the person carrying out the building work, so that person is exposed to enforcement. For a non-domestic building the penalty is calculated by formula, with a minimum of £500 and a maximum of £5,000, and building control can withhold the completion certificate.

Does a tenant fit-out after completion need another EPC?

Not automatically. A new EPC is needed if the fit-out changes the number of separately used parts and adds or extends heating, hot water, air conditioning or mechanical ventilation, or when the unit is next sold or let without a valid certificate.

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