MEES and EPC B by 2031: What the Latest Update Means for Industrial and Commercial Roofs
UK Industrial Roofing | Updated 14 October 2026
MEES EPC B 2031: On 18 June 2026, the government published an interim response on Minimum Energy Efficiency Standards (MEES) for non-domestic buildings. It confirmed its intention to introduce an EPC B requirement from 2031 for privately rented non-domestic buildings over 1,000 square metres in England and Wales, where improvements are cost effective.
The earlier proposal for an EPC C milestone in 2027 will not be taken forward.
The proposed EPC B requirement is not yet law and will require secondary legislation. This article explains what the government has announced, what remains subject to change, and what the proposals could mean for industrial and commercial roofs.
MEES EPC B 2031: the short answer
Short on time? Here is what you need to know.
Proposed standard: EPC B for privately rented non-domestic buildings over 1,000 square metres, from 2031.
Condition: it applies where the improvements are cost effective.
Smaller buildings: buildings under 1,000 square metres are intended to stay at the current minimum of EPC E, with no set deadline for going further.
Dropped: the proposed EPC C milestone for 2027 will not be taken forward.
Where it applies: England and Wales.
Status: not yet law. Secondary legislation must pass through Parliament first.
What has the government announced?
The interim response, published by the Department for Energy Security and Net Zero, sets out a more targeted approach than the original consultations in 2019 and 2021.
Instead of raising the standard across all rented non-domestic buildings, the government intends to focus on the larger ones, and has given landlords and tenants more time by removing the 2027 interim step.
The response also says the existing flexibility mechanisms, including the 7-year payback test and exemptions, will remain in place. The stated aim is that only improvements that are practical, affordable and cost effective will be required.
The government estimates that tenants in larger non-domestic buildings could save up to £360 million a year on energy bills by 2031. That figure comes from the department's own modelling, covers all larger buildings together rather than any single site, and is subject to refinement as the policy develops.
Is EPC B by 2031 law yet?
No. The government has confirmed its intention and a proposed timetable, but the change only takes effect after secondary legislation has passed. A fuller government response, covering the detail of the 1,000 square metre threshold and how the rules will operate, is still to come. Until then, the sensible position is to treat 2031 as the confirmed direction of travel and to watch for the legislation and guidance.
Which buildings are affected?
MEES applies to privately rented buildings. Under the current rules it is unlawful to let a non-domestic property with an EPC rating below E unless a valid exemption is registered. The proposed EPC B requirement would sit on top of that for larger buildings.
The proposal covers privately rented buildings over 1,000 square metres in England and Wales. Separate arrangements apply in Scotland and Northern Ireland. Owner-occupied buildings are not covered by the MEES lettings regime, although a building's energy performance still affects its running costs and its appeal to future tenants and buyers.
Owners of smaller buildings have some breathing space for now, but should not assume the standard will stay at EPC E indefinitely.
A previous UK Industrial Roofing project. Whatever the size of your building, the starting point is the same: a survey to see what your roof actually needs.
What does "where cost effective" mean?
The 7-year payback test remains. In practice it asks whether the cost of an improvement can be recovered through energy savings within seven years.
Where it cannot, or where another exemption applies, the improvement is not required. The detail of how this will work alongside the new EPC B standard is expected in the full response, so it is worth getting building-specific advice rather than relying on a rule of thumb.
Why the roof matters, and why to plan early
On a large industrial or commercial building the roof is typically one of the biggest parts of the building envelope. Its thermal performance can have a real effect on heating demand and on the EPC calculation. How much it moves the rating depends on the building, including its existing insulation, heating, lighting and use, which is why an assessment of the specific building should come first.
The roof options we typically look at for industrial and commercial buildings include:
Overcladding: adding a new insulated roof system over the existing roof, which can improve thermal performance without a full strip-out.
Roof replacement: replacing an ageing roof with a modern insulated system, such as composite panels.
Thermal upgrades: improving insulation and addressing heat loss as part of wider roof works.
Solar panels: where the roof structure and orientation suit them.
Where a roof is already approaching the end of its life, adding insulation at the same time as overcladding or replacement is often more economical than treating thermal upgrades as a separate project later.
Every roof is different, so UK Industrial Roofing always starts with a survey.
What should owners and managers do now?
Check the size and status of the building. Is it let, and is it over 1,000 square metres?
Check the current EPC. Find the rating and the expiry date, and read the recommendations listed.
Survey the roof. A roof condition survey shows what state the roof is in and what is realistic to do with it.
Compare the options. Overcladding, replacement and thermal upgrades have different costs and different effects, so weigh them against the payback test and your own plans for the building.
Plan around the business. Work on a live building needs phasing and careful health and safety planning, which takes time to organise with tenants.
Watch for the detail. Keep an eye on the full government response and the secondary legislation.
Why speak to us before the legislation arrives
The roof is usually the largest single piece of work on the route to a better EPC, and it is not a project to start in a hurry. A survey, a specification, budget approval and coordination with tenants all take time. Starting early means you choose the approach and the timing. Waiting until the rules are final means working to someone else's deadline.
UK Industrial Roofing has more than 25 years' experience in construction. We are based in Oxford and work across the Midlands, the South and nationwide on industrial, commercial and public sector buildings, including live sites where the business has to keep running. Our services include roof surveys, overcladding, roof replacement, thermal upgrades and solar panels.
If you own or manage an industrial or commercial roof and want to know where you stand, get in touch through our contact page to arrange a no-obligation roof survey: www.ukindustrialroofing.co.uk/contact
Frequently asked questions
What is MEES? Minimum Energy Efficiency Standards (MEES) set the lowest EPC rating a privately rented building can have and still be legally let in England and Wales. The current minimum for non-domestic buildings is EPC E.
What EPC rating do commercial properties need now? A minimum of EPC E. Letting a non-domestic property rated F or G is unlawful unless a valid exemption is registered.
What happened to the EPC C 2027 proposal? The government confirmed in its June 2026 interim response that the interim EPC C milestone for 2027 will not be taken forward.
Does EPC B by 2031 apply to buildings under 1,000 square metres? No. The intention is for buildings under 1,000 square metres to remain at EPC E, with no set deadline for going beyond that.
Does this apply in Scotland or Northern Ireland? The proposals cover England and Wales. Scotland and Northern Ireland have separate arrangements.
How much could tenants save? The government estimates up to £360 million a year in energy bill savings for tenants in larger non-domestic buildings by 2031. This is a modelled estimate for all larger buildings combined, not a figure for an individual building.
Can a roof upgrade alone get a building to EPC B? It depends on the building. A roof upgrade can make a meaningful contribution, but the result depends on the existing roof, the insulation, heating and lighting, and the size of the gap to EPC B. A building-specific assessment is the only reliable way to find out.
Our Sources
GOV.UK, Department for Energy Security and Net Zero: Minimum Energy Efficiency Standards (MEES) in the non-domestic Private Rented Sector: interim response (18 June 2026)
UK Parliament: Written Ministerial Statement HCWS126, Non domestic minimum energy efficiency standards (MEES) (18 June 2026)
This article is general information and not legal, financial or technical advice. EPC ratings should be assessed by an accredited assessor, and owners should take advice on their own legal position.
About the author
Simon Dawson, Director, UK Industrial Roofing
Simon Dawson is a director of UK
Industrial Roofing, based in Oxford, alongside fellow director Dominic Sandford.
All project photographs in this article were taken by Simon himself, using his own drone, on UK Industrial Roofing projects.
Questions about a roof or one of our projects?
Get in touch through our contact page: www.ukindustrialroofing.co.uk/contact
\
UK Industrial Roofing Ltd | Company number 16147726