Commercial EPCs for Property Owners
Commercial property sits under two separate sets of rules, with very different penalties. One requires a certificate when you sell or let. The other sets a minimum rating — and breaches there run to six figures.
Below: what a commercial EPC covers, what MEES requires since April 2023, the actual penalty scale, and when a Display Energy Certificate applies instead.
Do I need a commercial EPC?
Yes, whenever a commercial building is sold or let. The certificate must be commissioned before the property is marketed and made available to a prospective buyer or tenant free of charge at the earliest opportunity — in practice before the particulars go out, not when heads of terms are agreed.
A commercial EPC is valid for ten years. It is produced using SBEM rather than the RdSAP method used for homes, and is graded from A to G on the same scale.
Which level applies?
| Level | Applies to |
|---|---|
| Level 3 | Existing buildings with simple construction and simple heating, ventilation and air conditioning. Typically small retail units, offices and workshops. |
| Level 4 | Existing buildings that are more complex, or that have services which cannot be modelled simply. |
| Level 5 | New buildings and complex services, assessed using dynamic simulation modelling. |
The level is not chosen for convenience — it follows the building. An assessor who quotes without establishing which level applies is guessing at the price.
The minimum rating: band E
The Energy Efficiency (Private Rented Property) Regulations set a minimum rating for rented commercial property. The timetable is:
- 1 April 2018 — new lettings, extensions and renewals require at least band E.
- 1 April 2023 — the requirement extended to all privately rented non-domestic property, including tenancies that have not changed.
Property let on a term certain of six months or less is outside the regulations, as is a term of 99 years or more. If you are letting on a short rolling basis to sidestep it, note that the exclusion disappears where the agreement allows renewal beyond six months, or where the tenant has already been in occupation for more than twelve months.
What it costs to get it wrong
There are two distinct penalty regimes, and the difference between them matters.
Letting below band E
| Duration of breach | Maximum financial penalty |
|---|---|
| Less than three months | The greater of £5,000 or 10% of rateable value, capped at £50,000 |
| Three months or more | The greater of £10,000 or 20% of rateable value, capped at £150,000 |
| False information on the register, or ignoring a compliance notice | Up to £5,000 |
A publication penalty also applies, publishing the landlord, the property address, the breach and the fine on the PRS Exemptions Register for at least twelve months. For a property company that is often the more expensive half.
Not having an EPC at all
Where the breach is the certificate duty itself — marketing with no EPC — the penalty is 12.5% of the rateable value, with a minimum of £500 and a maximum of £5,000. Enforced by trading standards rather than the weights and measures authority.
In short: a missing certificate costs hundreds. Letting below band E for a year can cost a hundred thousand.
Exemptions
If a property cannot reasonably be improved to band E, the regulations provide exemptions. The two that matter most:
- Seven-year payback test. The recommended improvement, or package of measures, would not repay its cost through energy savings within seven years. You need three quotes from qualified installers and the supporting calculations.
- All improvements made. Every relevant improvement has been installed and the property still falls short.
Both are registered on the PRS Exemptions Register and last five years, after which you must try again or register a further exemption. Registering an exemption you cannot evidence is itself a breach, and attracts its own penalty.
Display Energy Certificates
A DEC is a different document with a different purpose: it reports actual metered energy use rather than modelled performance. It is required for buildings occupied by a public authority and frequently visited by the public, with a total useful floor area over 250m², and must be displayed where the public can see it.
A DEC is valid for twelve months where the floor area exceeds 1,000m², and ten years otherwise. An advisory report must be held alongside it.
What is coming
The government has consulted on raising the non-domestic minimum further, to band B. No implementing dates have been set, so treat it as direction of travel rather than a deadline. The practical point today is that a property sitting just inside band E has the least headroom of any in a portfolio.
Why instruct us
- Accredited commercial assessors at Level 3 and Level 4, not a residential assessor producing a commercial certificate.
- The level is confirmed before the price, not discovered on site.
- Nationwide coverage, including multi-site portfolios and properties with unusual construction or services.
- Certificates lodged on the register and emailed on completion, with the recommendation report that supports a MEES case if you later need one.
Frequently asked questions
Do I need a commercial EPC to sell or let?
Yes. A commercial building being sold or let needs a valid EPC, which lasts ten years. It must be commissioned before marketing and made available to a prospective buyer or tenant at the earliest opportunity.
What EPC level does my building need?
Existing buildings are usually assessed at Level 3 where the building and its services are simple, and Level 4 where they are more complex. Level 5 applies to new buildings and to complex services, and uses dynamic simulation modelling.
What is the minimum EPC rating for a commercial let?
Band E. The requirement has applied to new lettings and renewals since 1 April 2018, and to all privately rented non-domestic property since 1 April 2023, even where the tenancy has not changed.
What is the penalty for letting a commercial property below band E?
Up to the greater of £5,000 or 10% of rateable value if the breach is under three months, capped at £50,000. Where the breach is three months or more, up to the greater of £10,000 or 20% of rateable value, capped at £150,000. A publication penalty also applies.
What is the penalty for not having a commercial EPC at all?
That is a separate regime. Under the Energy Performance of Buildings Regulations the penalty for a non-dwelling is 12.5% of the rateable value, with a minimum of £500 and a maximum of £5,000.
Do I need a Display Energy Certificate?
A DEC is required for buildings occupied by a public authority and frequently visited by the public, with a total useful floor area over 250 square metres. It is valid for 12 months where the floor area exceeds 1,000 square metres, and 10 years otherwise.
When can I use a MEES exemption?
Exemptions include the seven-year payback test, where the recommended improvements would not repay their cost within seven years, and the all-improvements-made ground. Both are registered on the PRS Exemptions Register and last five years.
Get a commercial quote
Quote a commercial EPC Talk to an assessor
Or call 0208 522 0001.
Sources: Energy Performance of Buildings (England and Wales) Regulations 2012, regs 6, 7, 14 and 38; Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, regs 27 and 41; GOV.UK non-domestic MEES landlord guidance. This page reflects the position in October 2026.