After years of consultation and uncertainty, the government has finally set a commercial property EPC deadline. According to Green Street News, the new regime will take a 'targeted approach' focused on larger buildings rather than sweeping across the entire non-domestic stock at once.
For landlords and asset managers, this is the signal to stop waiting for final policy clarity and start acting. The direction is now set: minimum energy performance standards are tightening, and the buildings in scope will need to meet them or face letting restrictions.
What we know so far
The headline is that a deadline has been confirmed, with the policy expected to focus on larger commercial buildings first. This mirrors the phased logic used in other recent energy regulations: start where the carbon and lettable floor area are concentrated, then widen the net over time.
A targeted approach is tactically sensible. Larger buildings typically account for a disproportionate share of operational carbon, and their owners usually have the data and capital to plan upgrades. It also gives smaller landlords more runway before compliance bites.
What 'targeted' probably means in practice
While the full details are not yet public, 'targeted' usually implies thresholds based on floor area, rating band or both. We expect the regime to set a minimum EPC rating — most likely C or B, consistent with previous MEES consultations — and to apply it first to buildings above a certain size.
Exemptions are likely to remain for buildings where improvements are not technically feasible, cost-effective or where third-party consent cannot be obtained. The key is that owners will still need to register those exemptions properly; assuming an exemption without evidence is not a defence.
Key questions answered
Is there now a firm deadline? Yes — the policy direction is confirmed, even if secondary legislation and exact dates follow. The era of 'maybe it will be delayed' is over.
Will all buildings be caught at once? No. The government's stated 'targeted approach' points to a phased rollout, with larger buildings first.
What rating will be required? Previous government consultations pointed to EPC C as the next step, with EPC B further out. The latest announcement is consistent with that trajectory.
What should owners do today? Pull an EPC register for every lettable unit, identify the buildings most at risk, and model the cost-to-comply. The earlier you start, the more you can sequence works around lease events and planned capex.
What landlords should do now
First, segment your portfolio. Buildings currently rated D, E, F or G that are also large enough to fall into the first tranche are the priority. Cross-check expiry dates and meter data: an EPC that looks safe on paper may expire before the deadline.
Second, build a costed intervention plan. The goal is not a perfect retrofit on day one, but a prioritised list of measures — LED and controls, fabric upgrades, HVAC replacement, on-site generation — mapped against lease breaks, rent reviews and capex cycles.
Third, stress-test valuations and lending covenants. A building that cannot lawfully be let is a stranded asset. Lenders and investors are already pricing MEES risk into due diligence; having a credible plan is becoming a competitive advantage.
How we help
Oak Tree Rule advises commercial landlords, funds and occupiers on MEES strategy, EPC improvement planning and compliance roadmapping. We combine accredited EPC and energy-audit expertise with portfolio-level programme management, so you get a plan that is both technically sound and commercially deliverable.
If you want a rapid portfolio screen or a cost-to-comply model for the new EPC deadline, get in touch.
Frequently asked questions
- Has the government confirmed a commercial EPC deadline?
- Yes. Green Street News reports that a commercial property EPC deadline has now been set, with a targeted approach focused on larger buildings. Exact thresholds and dates are expected to follow in secondary legislation.
- Will smaller commercial buildings be included from day one?
- Probably not. The government's 'targeted approach' suggests larger buildings will be in scope first, with smaller stock likely added in later phases.
- What EPC rating will be required?
- The announcement is consistent with the previously consulted trajectory of EPC C as the next step, followed by EPC B. The precise ratings and timelines will be confirmed when detailed regulations are published.
- What counts as a 'larger' building?
- That has not been confirmed, but thresholds are likely to be based on lettable floor area. We expect offices, retail warehouses, distribution centres and large multi-let estates to be early priorities.
- Can Oak Tree Rule help us prepare?
- Yes. We provide portfolio EPC screening, cost-to-comply modelling, improvement planning and MEES compliance roadmaps for commercial property owners and funds.
Source: Green Street News — 22 June 2026