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EPCs for shopping centres and multi-let retail

Updated 19 October 2026 · SEO Dons Editorial

Multi-let retail is where EPC rules get most technical. A centre can mix units with their own plant, units fed from central plant, a conditioned mall and unheated service corridors. The regulations are the same as for a single shop, but which certificate covers what depends on how the building is serviced. For single units and parades, see our retail and shop EPC page.

Does each shop unit need its own EPC, or does one cover the centre?

The regulations treat a unit as a building in its own right. A building unit is a section, floor or apartment within a building which is designed or altered to be used separately, and the government's own example is a unit in a shopping centre. When a unit is sold or let, there must be an EPC that covers it. Assigning a lease and sub-letting also need one.

That EPC does not always have to be unit-specific. Regulation 9 allows a unit's certification to be based on a common certification of the whole building, where the block has a common heating system. It can also be based on the assessment of a representative unit in the same block, though the assessor must visit enough units to check they really are representative.

Lease renewals and extensions are not treated as a sale or let for EPC purposes, but MEES still applies to them (see below). Our guide to EPCs for part of a building covers the general rules for separately let parts.

How are malls, common parts and central plant treated?

The GOV.UK non-dwellings guide works through shopping centres directly. The answer turns on two things: whether heating is central or provided by each unit, and whether the mall is conditioned.

Centre set-upWhole-building EPCUnit EPCs
Common heating, conditioned mallOne EPC including the conditioned communal space, usable for the whole building or any part sold or letMay be produced if required, excluding communal space
Common heating, unconditioned mallOne EPC including the unconditioned communal space, usable for any partMay be produced if required, excluding communal space
Independent heating in each unitOnly when the whole building is sold or let as one, including communal spaceOne EPC for each unit when sold or let, excluding communal space

With independent heating, a landlord selling or letting the whole centre can provide one EPC for the whole building, or EPCs for each unit plus one for the conditioned communal areas.

Some units fall outside the rules. Take a unit that does not open onto the mall, so does not share its conditioning, and has no heating of its own or the ability to have it. The guide says it does not need an EPC, because it is not a building for the purposes of the regulations. An unheated store reached only from a service yard might be an example, but each unit has to be judged on its own services.

What happens with shell units, fit-outs and reconfigured units?

A unit let as a bare shell still needs an EPC if it will be fitted out and is expected to use energy to condition the indoor climate. The EPC is based on the most energy-intensive fit-out allowed by Part L of the Building Regulations for the use class. The tenant's fit-out must then meet Part L, so the result should match the EPC or improve on it.

Reconfiguring units is a separate trigger. Merging two units, or splitting a large store into several, creates more or fewer parts for separate use. Where that work provides or extends fixed heating, air conditioning or mechanical ventilation, the person carrying out the work must provide an EPC to the owner on completion. A tenant's internal refit that leaves unit boundaries unchanged does not trigger one, though it must meet the Building Regulations.

When a unit is marketed, the asset rating from its EPC must be stated in commercial media, including online listings, where one is available.

Why do large shopping centres often need Level 5 (DSM)?

A small unit with simple heating and natural ventilation fits the government's Level 3 definition, and units with multi-split or VRF cooling or air handling plant are Level 4. Large enclosed centres can go further. Elmhurst Energy, an accreditation scheme, describes Level 5 buildings as having features such as atria, automatic shading, extensive thermal mass or highly glazed facades, and names large shopping centres among the typical examples. Such buildings cannot be modelled reliably with the simplified method and are assessed with Dynamic Simulation Modelling (DSM).

Scale also changes how the survey runs. On Level 4 and Level 5 buildings, data gatherers working under the assessor's supervision can help with larger and more complex buildings, but the assessor remains responsible and must validate the information with a site inspection. Our guide to SBEM Level 3, Level 4 and DSM explains the levels.

How does MEES apply to each let unit?

MEES applies to whatever is let. The government's landlord guidance confirms it covers retail units within larger buildings that need their own EPC, and explains which certificate counts when there are several. If there is an EPC for the whole building and one for the unit being let, the unit's EPC is the relevant one. If there is only a whole-building EPC, and the unit is not legally required to have its own, the building EPC is the relevant one.

The minimum is EPC E. Since 1 April 2018 a landlord can only grant, extend or renew a tenancy if the property rates at least E, and since 1 April 2023 that covers continuing lettings too, unless a valid exemption is registered. The landlord only has to install measures that improve the let property, though works to shared plant may lift other units as well, which the guidance says is acceptable.

In a multi-let centre, works may need someone else's agreement. The third-party consent exemption covers improvements that need consent from, for example, a tenant, superior landlord or planning department, where that consent cannot be obtained despite your best efforts.

The government's interim response, updated 18 June 2026, proposes EPC B from 2031 for private rented buildings over 1,000 square metres, with smaller buildings staying at E. It is a proposal, not law, and the government says detail on how the threshold is implemented will follow, so its effect on individual units inside a large centre is not yet known. Our guide to the EPC B 2031 proposal tracks it.

Which EPC has to be on display?

A non-domestic building over 500 square metres that is frequently visited by the public must display its EPC in a prominent place, if an EPC has been produced for its sale, letting or construction. In the regulations, a reference to a building includes a building unit, so the rule can apply to a large store within a centre as well as to the centre as a whole.

If you need EPCs for a centre or a group of units, you can request quotes from accredited assessors through the form on this site. Our retail EPC guide covers single shops and parades.

Sources

Common questions

Can one survey be used to certify several identical units?

Yes, within limits. A unit's EPC can be based on a representative unit in the same block, but the assessor must judge that the units genuinely match and visit a sufficient sample. Differences in age, construction, orientation, position, heating, insulation or glazing can rule a unit out.

Does a lease renewal on a unit need a new EPC?

A lease renewal or extension is not treated as a sale or let for EPC purposes, so it does not on its own trigger the duty to provide one. MEES does apply to renewals and extensions, so a unit rated F or G needs improving, or a registered exemption, before the tenancy is renewed.

Does a small standalone kiosk building in the car park need an EPC?

A detached building with a total floor space under 50 square metres does not need an EPC. Anything larger, or attached to the main building, follows the normal rules.

Will the 2031 EPC B proposal apply per unit or to the whole centre?

That has not been settled. The interim response says further detail on the proposals and on how the 1,000 square metre threshold is implemented will come in the government's full response. Until legislation passes, the legal minimum for let units remains E.

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