MEES Just Swallowed Your Commercial Portfolio: The EPC Band E Deadline Hits Now

MEES Just Swallowed Your Commercial Portfolio: The EPC Band E Deadline Hits Now

The Minimum Energy Efficiency Standards (MEES) just got wider. From 2024, the regulations that once applied mainly to domestic lettings now cover all non-domestic buildings in England and Wales. If you manage a commercial property, a hotel, or a mixed-use asset, this affects you directly.

What Changed in the MEES 2024 Update

MEES has been around since 2018. Until now, it mostly applied to domestic properties and some commercial lettings. The 2024 update extends the requirement to all non-domestic buildings that are let or rented. The baseline remains the same: your building must have an Energy Performance Certificate (EPC) rating of E or better.

If your building falls below E, you cannot grant a new tenancy or renew an existing one. The penalty for non-compliance is up to £150,000, plus publication of your breach on the PRS Exemptions Register. That last part matters more than most operators realise. A public listing signals to tenants, investors, and insurers that your asset is underperforming.

The new rules also introduce a revised exemption process. Previously, if you could show that the cost of improvements exceeded a certain cap, you could register an exemption. That cap has been tightened. The seven-year payback test is now more rigorous. You must provide clearer evidence that the measures are not cost-effective within that period.

Who This Hits Hardest

Three types of building owners will feel this most.

First, owners of older commercial stock. A 1970s office block in Manchester city centre with single-glazed windows and an ageing gas boiler is unlikely to hit E without significant work. The same applies to a 1980s hotel in Birmingham where the original HVAC system has been patched rather than replaced.

Second, multi-let buildings where individual units have separate EPCs. A single F-rated unit in a parade of shops can block the entire building from being let. The landlord is responsible for the common parts, but the tenant's unit also needs its own compliance. This creates a coordination problem that many asset managers have not yet solved.

Third, buildings that were previously exempt. Some categories of non-domestic building were excluded from MEES in earlier phases. That exemption has now been removed. If you manage a building that was previously outside the scope, check your EPC status now.

The New Exemption Process: What to Watch

The exemption register is not a free pass. You must apply for an exemption and provide supporting evidence. The grounds are limited: all relevant energy efficiency improvements have been made and the building still cannot reach E; the improvements are not cost-effective within a seven-year payback; or a third-party consent is required and has been refused.

The key change is the evidence standard. The government now expects you to have considered all improvements listed in the EPC recommendations report. If you skip one, you need a documented reason. A simple statement that the cost was too high will not suffice. You need quotes, payback calculations, and a clear explanation of why the measure was not viable.

Exemptions last five years. After that, you must reapply. The register is public. Tenants, buyers, and competitors can see exactly what you claimed and why.

What This Means for Your Operations

If you are a facilities manager or chief engineer, this is not just a compliance issue. It is an operational one. The quickest way to improve an EPC rating is to address the building's energy performance at the system level.

Start with the low-hanging fruit. Lighting upgrades to LED typically pay back within two years and can lift a D to a C. Heating controls and zoning improvements are next. A BMS that actually schedules plant operation rather than running everything 24/7 can reduce heating energy by 15-20%.

Then look at the fabric. Draught-proofing, insulation, and window upgrades are more expensive but deliver permanent improvements. If your building has a flat roof, that is often the cheapest place to add insulation.

For buildings with air conditioning, the efficiency of the chiller or heat pump matters. A chiller that is 15 years old and running on R22 refrigerant is almost certainly dragging your EPC down. Replacing it with a modern inverter-driven unit can lift the rating by one or two bands.

We covered the broader implications of EPC deadlines in a previous post: How to Navigate the 2026 EPC Standards Before Deals Stall. The same principles apply here, but the timeline is shorter.

The GCC Contrast

For readers in the GCC, the MEES update may feel distant. But the direction of travel is the same. Dubai's Al Sa'fat rating system and Abu Dhabi's mandatory efficiency audits are moving toward similar minimum standards. The difference is that the GCC starts from a higher cooling load and a different building stock.

A hotel in Dubai Marina with a 500-ton chiller plant and 24-hour occupancy has a different energy profile than a London office. But the principle is the same: if your building cannot meet a minimum efficiency standard, you cannot let it. The cost of non-compliance is lost revenue, not just a fine.

We wrote about Abu Dhabi's mandatory audits in Abu Dhabi's Mandatory Efficiency Audits Start Q4 2024—Here's Your Compliance Checklist. The same operational logic applies: measure first, then improve.

Where to Start

If you have not checked your EPC register recently, do it this week. Pull the EPC for every building in your portfolio. Sort by rating. Identify the ones at F or G. Those are your immediate risk.

For each one, review the recommendations report. Prioritise the measures that improve the rating most per pound spent. Get quotes. Document everything. If you need an exemption, apply early. The register is public, but a valid exemption is better than a breach.

If you want to track your energy performance across a portfolio and see which buildings need attention first, see how Herman handles this. The platform monitors energy, tracks maintenance, and lets you ask questions in plain English. No spreadsheets, no chasing data from three different systems.

— The HermanWa Team

Until next time — keep your buildings smart and your compliance tighter.

H
Herman
Head of Insights, HermanWa

Need help with your building management?

HermanWa helps commercial property owners and hospitality operators monitor, optimise, and future-proof their buildings.

Get in Touch