Key Points
- MEES relates to properties which are offered for or have been rented.
- The current MEES threshold requiring a Band E Energy Performance Certificate (EPC) for private rented properties – unless a property exemption has been registered – which has been in place since 2018 is to change.
- Current Government Policy for Residential properties is that a Band C Rating will be required by October 2030 on all properties, and will additionally extend to all Social Housing which although always required EPCs on letting did not have to comply with the MEES requirements of the properties being in Band E.
- The Policy for Non-Domestic Policy is that by 2031 commercial buildings of ≥ 1,000m2 will need to have a Band B Rating, commercial buildings of < 1,000m2 remaining in Band E.
- The proposed MEES Requirements have not been finalised or presented to parliament.
The Current Situation
All properties, residential (domestic) and commercial (non-domestic), require an EPC in Band E to be in place when a property is advertised for letting, unless an exemption has been registered or the dwelling is Social Housing but which still requires an EPC in place. If a property is awarded a Band F or G EPC Rating, for the Private Rental Sector, an exemption can be applied for which remains in force for 5 years.
When an EPC is Required
The current semi-flexible 7/21 day period of grace to obtain an EPC before a property (domestic or non-domestic) is advertised for letting or sale will be removed, with a valid EPC being required from the point a property is advertised for sale or letting.
The current arrangements that an EPC does not need renewing if it expires during a tenancy will also change, with an updated MEES Compliant EPC being required when an existing EPC expires.
The Proposed MEES Requirements – Overview
There will initially be different rules for Private Rented Properties and Social Housing, but which will finally merge by October 2039.
The proposed changes for non-domestic or commercial properties were disclosed to Parliament on the 21st June 2026, and are referred to later.
Private Residential Rented Sector – Proposed MEES Requirements
It is highly likely that the EPC title will change to something different, and instead of containing a single graded (A->G) metric (broadly relating to the estimated cost of supplied energy), it will contain four graded (A->G) metrics relating to: Energy Cost, Fabric Performance, Heating System, and Smart Readiness (PV, Battery Storage, and Solar Thermal systems). There will be a secondary metric relating to carbon emissions, and delivered energy.
The duration, or validity period of the ‘EPC’ is expected to remain at 10 years from the date of issue or unless updated in the interim.
Short-term lets (such as Holiday Lets) will not require mandatory EPCs. Housing in Multiple Occupancy (HMO) will require MEES Compliant EPCs, as will Listed/Heritage Buildings for which MEES Compliant EPCs will be required for sale or letting.
Dual Metric Requirement. For Private Rental Sector Dwellings there will be a requirement that two (of the four) metrics will be required to be met, the first of which will be the Fabric Metric, the second one of either the Heating or Smart Metric, that requirement being mandatory from 1st October 2030, with both being in Band C.
Existing EPC to new ‘EPC’ transition. It is proposed that if a dwelling has an existing EPC in place on 30th September 2030 and the Rating is in Band C, the dwelling will not require an ‘EPC’ in the new format with the Dual Metrics (both in Band C) until the existing EPC expires which would then be replaced by the Dual Metric new ‘EPC’.
Improvement Spending Cost Cap increase. The current Cost Cap of £3,500 per dwelling will increase to £10,000, but with landlords being able to include spending from 1st October 2025 within the higher limit.
Penalty for non-compliance. Increased to £30,000 per dwelling from the current £2,000 – £4,000 penalty depending upon the duration of the breach.
Exemptions. Exemptions will be able to be registered in much the same way as it is possible to do currently, but the exemption period will be extended to 10 years.
Exemptions are expected to be permitted for:
High-Cost Exemptions;
Cost Cap Exemptions;
Third Party Consent Exemptions;
Negative Impact Exemptions;
Property Value Adjustment Exemptions; and
Solid Wall Insulation Exemptions.
Compliance Date. 1st October 2030
PRS Exemption Register
Changes to the PRS Register have already been made, the Register now being publicly accessible and visible to all. searches can be made by postcode, street name, and town, and show the landlord’s name, the exemption type, and degree of penalty awarded.
Caveats and Limitations.
The proposals have yet to be submitted for parliamentary approval.
The proposals could change if there was a change in Government elected with a different approach or mandate.
It is not yet known what the ‘pass/fail’ criteria for achieving a Band C award in any of the four metrics will be, although there is an expectation that providing fabric improvements can be supported by accredited documentary evidence confirming compliance with the Building Regulations Part L requirements at the date the improvements were made, an existing Band C EPC would achieve a Band C ‘EPC’ under the new criteria. It should be noted that ‘sign-off’ by a Local Authority’s Building Control official or similar, does not constitute confirmation that Building Regulation Part L requirements were met.
Social Housing Sector – Proposed MEES Requirements.
By 1st October 2030 all Social Housing properties must achieve an ‘EPC’ Rating in Band C in one of the 4 metrics, whether in the existing EPC or revised ‘EPC’ formats.
By 1st October 2039, a second metric (of the four) is required to have been achieved, with the Social Housing Provider selecting which of the second metric they wish to comply with.
Social Housing Exemptions. It is anticipated there will be no difference in the exemptions between the Private Rental and Social Housing Sectors.
The Non-Domestic / Commercial Sector
The proposed 2027 Band C EPC requirement for Non-Domestic properties will now not happen.
A two-tired approach from 2031 will be adopted:
For commercial buildings of ≥ 1,000m2 will need to have a Band B Rating;
For commercial buildings of < 1,000m2 the threshold will remain at Band E.
Enforcement of the MEES Regulations
Enforcement will remain with the Respective Local Authorities’ Trading Standards departments, which HMG expect will be strengthened and enhanced.
What can West London Energy Assessors do to support this?
Property owners proposing to undertake improvements to a property in the expectation of then being able to rent that property are encouraged to check with their selected building contractor before any work starts or a contract is awarded, that documentation will be provided at the end of the project with evidence and confirmation Building Regulation’s requirements and expectations have been complied with and achieved.
If in doubt as to whether proposed work will satisfy Building Regulation’s requirements, the failure of which might then impact on the ‘EPC’ matrix Rating being achieved, the building owner is encouraged to discuss their concerns with West London Energy Assessors.