In June 2026 the government finally set out the next stage of the Minimum Energy Efficiency Standards (MEES) for commercial property. If you own or let commercial premises in Lancashire or Greater Manchester, here's what has changed, what hasn't, and what you should be doing now.
The short version
Let buildings over 1,000 m² (roughly 10,760 sq ft) will need to reach EPC B from 2031, where it's cost-effective to do so.
Buildings under 1,000 m² stay at the current minimum of EPC E.
The previously proposed EPC C requirement for 2027 has been dropped.
The 7-year payback test and existing exemptions stay.
Full details are still to come, and the changes need secondary legislation before they become law.
What MEES requires today
Since 1 April 2023, landlords in England and Wales can't continue to let a non-domestic property rated F or G unless a valid exemption is registered. The rules apply to tenancies of more than six months and less than 99 years, where the building is legally required to have an EPC.
What's changing in 2031
The government's interim response, published on 18 June 2026, confirms that from 2031 privately rented commercial buildings over 1,000 m² must reach EPC B where this is cost-effective. Smaller buildings stay at E. The government estimates the change could save tenants in larger buildings up to £360 million a year on energy bills by 2031.
The proposed interim step of EPC C by 2027 will not go ahead, which gives landlords more time to plan improvements. Exactly how the size threshold will be measured, and the full guidance, will follow in the government's final response.
Which Lancashire buildings are affected?
Across Lancashire and Greater Manchester, plenty of let commercial property sits above the 1,000 m² line: larger warehouses and industrial units, distribution buildings, office blocks and bigger retail units. If you own or manage buildings of that size, the 2031 deadline applies to you. If your units are smaller, the E standard still applies, so it's worth checking you're comfortably above it.
Why 2031 is closer than it looks
Getting from an E or D to a B is a big jump for many older buildings. Improvements often need to be planned around lease ends, refurbishments and budgets, and some work can only be done when a unit is empty. Common measures include lighting upgrades with better controls, improved heating and hot water systems, insulation, glazing and smarter building controls, but the right mix depends on the building.
EPCs are valid for 10 years, so a certificate produced now could still be in date in 2031. However, if you carry out improvements, you'll want a fresh EPC so the rating reflects the work.
Exemptions: still there, but not a loophole
The existing exemptions remain, including:
the 7-year payback test, where the cost of the works is more than the expected energy bill savings over seven years
all relevant improvements have already been made
wall insulation that would damage the building
third-party consent being refused
improvements that would reduce the property's value by more than 5%
a temporary six-month exemption for new landlords
Exemptions must be registered on the PRS Exemptions Register to count, and most last five years. They need evidence, so it pays to get proper advice.
The cost of getting it wrong
Under the current rules, letting a non-compliant property can lead to a penalty of £5,000 or 10% of the rateable value (up to £50,000) for a breach of less than three months, and £10,000 or 20% of the rateable value (up to £150,000) for three months or more. Details of the breach can also be published.
What to do now
Check your current EPC rating and expiry date on the government EPC register.
Check the floor area to see which side of the 1,000 m² line you're on.
Get an up-to-date assessment with recommendations, so you know which improvements will move the rating and by how much.
Plan works around lease events and budgets, rather than leaving everything until 2030.
Keep an eye on the final government response, which will confirm the details.
How I can help
I'm Tom, a Level 4 Non-Domestic Energy Assessor accredited with Elmhurst and ECMK, with over 8 years in the energy efficiency sector. I carry out Commercial EPCs and provide practical MEES advice for landlords, agents and businesses across Lancashire and Greater Manchester. If you'd like to know where your building stands, get in touch for a quote.
This article reflects the government's interim response published on 18 June 2026. Details may change when the final response and legislation are published. It is general guidance, not legal advice.