MEES update: EPC C for 2027 is dead. Here's what's replacing it

MEES Update: EPC C London

The Government has just confirmed its long-awaited response to the MEES consultation — and commercial landlords finally have clarity.

The headline: the proposed EPC C by 2027 requirement will not go ahead.

Instead:

  • EPC B becomes the target for buildings over 1,000m² — from 2031
  • Smaller buildings stay at the current EPC E minimum, with no fixed deadline yet
  • The 7-year payback test and existing exemptions remain in place, so only cost-effective upgrades will be required

The catch: EPC E is still today's legal minimum. Waiting for 2031 isn't a strategy — it's a risk.

For owners of larger commercial assets, the additional time should therefore be viewed as a planning window rather than a reason to postpone investment. The condition of the building today, its current EPC rating, lease structure, planned capital works and the remaining lifecycle of its M&E systems can all influence when intervention makes the most commercial sense.

An office building that already requires refurbishment, for example, may present an opportunity to address several priorities within one coordinated programme rather than reopening completed areas later to carry out additional energy-related works.

Delay and you're more likely to face:

  • Higher construction costs
  • Reduced contractor availability
  • More disruption to tenants
  • Fewer chances to bundle upgrades into wider refurb plans

Bundling is particularly important. If lighting, HVAC, controls, building fabric or other systems are approaching replacement anyway, incorporating energy-performance objectives into that programme can reduce duplicated work and help owners make capital expenditure work harder.

The same principle applies to tenant changeovers and major fit-outs. Vacant periods can create a valuable window for intrusive works that would be considerably more disruptive once a new occupier is in place.

At SHATRO | London, we help commercial property owners plan turnkey refurbishments now — so you're ahead of 2031, not scrambling for it.

Get in touch to review your portfolio's EPC exposure.