Commercial EPCs for managing agents and portfolios
Quick answer
Start by checking the register for what each building already holds and when it was lodged, then rank the portfolio by exposure: let buildings rated F or G first, then those sitting at E with no headroom, then privately let buildings over 1,000 sqm in view of the proposed EPC B standard.
Managing a portfolio changes the EPC problem. The regulations are identical to those facing a single landlord, but the failure mode is different: it is rarely a considered decision that causes a compliance gap, it is an expiry nobody was tracking across two hundred certificates and forty clients.
This page covers the portfolio version of commercial EPC compliance - assessing at scale, ranking buildings by risk, evidencing the position to the landlords you act for, and keeping it that way.
Start with an inventory, not with assessments
The instinct is to commission assessments. The cheaper first step is to establish what already exists. Non-domestic EPCs are lodged on the national register and can be looked up against each property, so a portfolio inventory will typically show three groups: buildings with a live certificate, buildings whose certificate has expired or is close to it, and buildings with nothing on record.
Two fields matter on every row. The lodgement date, because the 10-year validity runs from lodgement rather than from the last transaction. And the assessed extent, because a certificate that covers a different demise - common where a building has been subdivided since - is valid on paper and useless at the point of a letting.
Rank the portfolio by risk, not by expiry date
Once you know the ratings, the useful ordering is by exposure rather than by calendar. Buildings rated F or G that are currently let are the urgent group: since 1 April 2023 it has been unlawful to continue letting a non-domestic property below EPC E, so those are in breach now rather than at the next lease event.
Next come buildings sitting at E - compliant, but with no headroom, so any change to the building or the methodology could put them below the line. Then buildings over 1,000 sqm that are privately let, because that is the cohort the proposed EPC B standard targets. Everything else is a scheduling exercise around expiry dates.
Assessing at scale
Assessing a portfolio as a single exercise generally reduces the per-building fee, because survey visits can be routed efficiently and the assessor is working to one brief across similar stock. The saving is largest where the portfolio is consistent in age and specification, which is common in purpose-built estates and less so in mixed acquired holdings.
The fee per building still follows the same drivers: floor area, the number of separately serviced zones, the assessment level, and how much has to be measured on site because drawings and plant records are missing. A managing agent is usually better placed than anyone to close that last gap, because the plans, plant schedules and commissioning records are often already held - they are simply not in one place.
Reporting the position to your landlords
The output a landlord client needs is not a folder of certificates. It is a position: which buildings are lettable today, which are not, what it would cost to fix the ones that are not, and what is coming.
The recommendation report attached to each certificate is the raw material for that. It is building-specific and costed, which makes it far more useful than generic advice, and across a consistent portfolio the same measures usually recur - lighting and controls, heating controls and zoning, ventilation control and plant replacement. That recurrence is what allows a single improvement specification to be procured once and applied across many units.
Where a building genuinely cannot be improved, the PRS Exemptions Register is the correct route. Exemptions are time-limited and must be renewed, which makes them another tracked item rather than a closed matter.
Getting the future dates right
A managing agent is the person most likely to be asked what is coming, so it is worth being precise. The live proposal is that privately rented non-domestic buildings over 1,000 sqm reach EPC B by 2031, subject to secondary legislation. In the government response of 18 June 2026, the interim EPC C milestone for 2027 was dropped.
That means two of the dates still circulating widely are wrong. There is no interim EPC C deadline in 2027, and "EPC B by 2030" was never the proposal. Advising a client to commit capital against either would be advising against a standard that does not exist. Buildings under 1,000 sqm remain on the EPC E standard with no new deadline announced.
Build the tracking in
Almost every portfolio compliance failure we see is an administrative one. A certificate lapses, a building is subdivided and the old certificate no longer matches the demise, an exemption expires unrenewed, or a unit changes hands internally and nobody re-checks.
The fix is unglamorous: hold lodgement dates rather than issue dates, diarise expiry well ahead of a likely letting rather than at the point of one, re-check the assessed extent whenever a demise changes, and treat exemption renewals as diary items. None of that is difficult. It is simply the difference between a portfolio that is compliant and one that believes it is.
Cost recovery and who pays
Whether the assessment and any improvement works are recoverable depends on the lease and the service charge provisions, and it varies more than clients expect across a mixed portfolio. It is worth establishing the recovery position per building before commissioning a programme, because the answer changes which buildings the landlord will want to prioritise.
Where works are not recoverable the landlord carries them directly, which makes the ranking exercise more important, not less - capital goes to the buildings where the letting risk is greatest rather than the ones where the works are easiest.
Handover between agents
Compliance records are among the most commonly lost items when management changes hands. Certificates, lodgement dates, recommendation reports and any registered exemptions should transfer as a set, with the exemption expiry dates called out explicitly, because an exemption that lapses unnoticed puts a building straight back into breach.
If you are taking on a portfolio, treat the inbound records as unverified until checked against the register. It is common to inherit a folder that is complete on paper and out of date in fact.