Government update on changes to non-domestic EPCs
The UK government has published a partial response to its consultation on reforming the Energy Performance of Buildings (EPB) regime, confirming several changes to domestic and non-domestic EPCs in England and Wales.
It doesn’t answer everything – a fuller response is promised later in 2026 – but it does give us a clearer picture of what’s staying the same, what’s changing, and what’s still up in the air.
We’ve put together an explainer on upcoming changes for owners, landlords and tenants of non-domestic properties.
Non-domestic EPC changes: What we know (for now)
- The headline metric for non-domestic EPCs stays the same. Non-domestic EPCs will keep a single carbon-based environmental impact rating (EIR) as the main metric. This is to support businesses in the net zero transition and facilitate ongoing compliance with non-domestic Minimum Energy Efficiency Standards (MEES) regulation.
- EPCs will still last 10 years. The current 10-year validity period is being retained. The idea of reducing the time period had been explored to allow building upgrades such as fabric changes, to be captured more frequently. This has now been discounted due to feedback on the increased cost and administrative burden of commissioning more regular EPCs.
- EPCs will be required at the point of marketing, not just at sale or letting. This is intended to give buyers and tenants better information earlier and make compliance clearer and easier to enforce.
- EPC exemptions for heritage buildings will be removed. EPCs will now be required for all heritage properties when marketed, let or sold. The majority of respondents opposed this change, but many agreed that removing the exemption would provide greater clarity and help landlords and tenants to better understand the energy performance of their buildings.
What we don’t yet know
- Whether landlords need a new EPC when the old one expires. The government hasn’t yet confirmed whether all privately rented non-domestic buildings will need a new EPC when an existing one runs out. This is being looked at alongside wider changes to the non-domestic MEES.
- What’s happening to Display Energy Certificates (DECs): The government is questioning the effectiveness of DECs, and whether other approaches might drive greater energy improvements. Changes being considered include reducing the validity period of DECs and DEC recommendation reports from 10 years to 7 years for buildings between 250-1,000m², and the validity period of DEC recommendation reports from 7 years to 5 years for buildings over 1,000m².)
- EPC rules for social landlords: EPC rules for the social rented sector are tied to a separate MEES consultation. The government says it will respond in early 2026.
- Air Conditioning Inspection Reports (ACIRs) improvements. These are mandatory inspections, for all air conditioning systems with an effective rated output of more than 12kW. The government wants to improve compliance with the ACIR regime, (which is currently low), and improve the format of ACIRs. We don’t yet have an update on this.
- Opting out of public EPC data. Currently, building owners can opt out of having their EPC publicly visible on the register. The government is considering removing this opt-out, but hasn’t confirmed anything yet.
What happens next (and when)
The full government response to the remaining consultation questions is due later in 2026.
Then, it is aiming to introduce new-style EPCs from October 2026, acknowledging that the timeline is ambitious. Further engagement with industry is promised to help manage the transition.
In summary, this update confirms some important points for non-domestic EPCs but many practical questions won’t be answered until later this year. We are also awaiting some clarity on the trajectory of the non-domestic MEES, also due this year.
We’ll be keeping an eye on the next phase, and helping our commercial clients navigate the uncertainty in the meantime. If you’d like advice on what the changes mean for you, get in touch.
