What is the expected minimum EPC rating for commercial property by 2028?

A minimum EPC rating of C is widely anticipated for commercial property lettings by 2028 under tightening MEES regulations. The current minimum is E. Buildings currently rated D or E will need to improve to remain lawfully lettable.

Which commercial properties are most at risk under MEES 2028?

Buildings currently rated E face the highest exposure, requiring improvement of at least two grades to meet a minimum C requirement. D-rated buildings are also at risk. Even some C-rated buildings should be reviewed if ratings are marginal or based on older assessments.

What are the risks of delaying MEES 2028 preparation?

Delaying MEES preparation increases contractor costs as deadlines approach, reduces flexibility to phase works around tenants, removes the option to align improvements with planned maintenance or lease events, and can undermine tenant confidence during renewal negotiations.

What improvements can raise a commercial EPC rating ahead of MEES 2028?

Cost-effective measures include LED lighting upgrades, HVAC optimisation and controls adjustments, BMS upgrades, sub-metering, fabric improvements such as insulation and glazing, and evidence verification to remove conservative default modelling assumptions without physical works.

How should MEES 2028 improvements be aligned with capital planning?

The most efficient approach aligns energy improvements with planned refurbishments, fit-out works, lease events, and maintenance cycles. This reduces duplication and incremental cost, as contractors are already mobilised and disruption is already occurring.

MEES 2028 Commercial Property: Portfolio Readiness Guide

03 Jun 2026

MEES regulations are tightening. While the current minimum EPC rating for letting commercial property is E, a move to minimum C is widely anticipated by 2028. For many portfolios, this represents a significant shift that will require action.

The buildings most at risk are those currently rated D or E. Without improvement, these properties may become unlettable when regulations change. The time to understand exposure and plan improvements is now, not when deadlines approach.

This guide explores what the expected MEES 2028 requirements mean for commercial property portfolios and how landlords can prepare effectively.

A female property advisor pointing to F-rated assets on a large whiteboard portfolio EPC matrix showing colour-coded A to F ratings across multiple asset references, whilst holding a Regulatory Timeline document, with a male colleague reviewing an asset-by-asset EPC data sheet on a laptop and a capital planning schedule, timeline and lease event calendar laid out on the table

The regulatory direction is clear and the evidence is on the board: a portfolio adviser identifying the assets whose F ratings place them at greatest compliance risk, with the regulatory timeline, capital planning schedule and lease event calendar already in hand to structure the response.

The Regulatory Direction

The trajectory of MEES regulation has been clear for some time. The minimum standard has tightened progressively, and further tightening is expected.

The current position requires non-domestic properties to have a minimum E rating before they can be let. Properties rated F or G cannot lawfully be let unless they qualify for an exemption.

The expected position by 2028 is a minimum C rating. While the precise timing and details may evolve, the direction is clear. Significant portions of the existing commercial building stock will need to improve to remain lettable.

For portfolios with substantial D and E-rated assets, this represents material compliance risk that requires proactive planning.

Assessing Portfolio Exposure

Understanding current EPC positions across a portfolio is the essential first step in preparing for MEES 2028.

This involves more than simply counting ratings. It requires understanding the distribution of ratings, the proximity of assets to threshold boundaries, and the likely cost and complexity of achieving required improvements.

Assets currently rated E face the most immediate exposure. These buildings will need to improve by at least two grades to meet a minimum C requirement.

Assets rated D are also at risk. While closer to the threshold, they still require improvement and should not be assumed to be compliant.

Even assets rated C should be reviewed. If ratings are marginal or based on older assessments, there may be risk that re-assessment could result in lower ratings.

A split-scene composite showing an LED lighting installation in progress behind a dust sheet on the left, with a Phased Works Programme Schedule on the wall at the dividing point, and a fully occupied open-plan office on the right where a facilities manager reviews an EPC improvement projection on a tablet

The cost of waiting is measured in disruption, compressed timelines and occupier inconvenience: landlords who act now can phase improvements around lease events and working hours, whilst those who delay face urgent works in occupied buildings with no room to manoeuvre.

The Cost of Waiting

Delaying action on MEES preparation carries several risks that can increase costs and reduce options.

Contractor availability tends to tighten as deadlines approach. When multiple landlords are seeking similar improvements simultaneously, costs increase and timelines extend.

Disruption becomes harder to manage when works must be completed quickly. Phasing improvements over time allows better coordination with tenant schedules and reduces operational impact.

Options narrow as time compresses. With adequate lead time, improvements can be aligned with planned maintenance, refurbishment cycles, or lease events. Under time pressure, this flexibility disappears.

Tenant confidence can be affected by uncertainty. If tenants perceive that a building may face compliance challenges, this can influence lease negotiations and renewal decisions.

Planning Effective Improvements

Effective MEES preparation involves understanding which improvements deliver the best results for each building.

LED lighting upgrades are typically among the most cost-effective interventions. They deliver immediate energy savings and meaningful EPC improvements with relatively straightforward installation.

HVAC optimisation can improve performance without equipment replacement. Controls adjustments, commissioning improvements, and maintenance enhancements all contribute.

BMS upgrades and sub-metering provide better data for energy management and can support EPC improvement through more accurate modelling.

Fabric improvements may be necessary for some buildings. Insulation upgrades, glazing improvements, and draught reduction all contribute to better energy performance.

Evidence verification is often overlooked but can be highly effective. Many EPCs are based on default assumptions that do not reflect actual building specifications. Providing evidence to remove conservative defaults can improve ratings without physical works.

Two property professionals reviewing a large-format multi-year capital programme Gantt chart colour-coded across planned maintenance works, lease expiry events, refurbishment programmes and energy improvement measures, alongside a MEES risk register and an EPC certificate, with a capital expenditure model visible on a laptop

Aligning energy improvement measures with capital cycles and planned maintenance is where compliance strategy becomes commercially intelligent: the right works, at the right assets, timed to lease events and existing expenditure commitments rather than imposed on top of them.

Alignment with Capital Cycles and Planned Maintenance

Align any improvement works with existing capital projects and planned maintenance programmes to reduce duplication, disruption, and cost.

Where possible, obtain early budgetary guidance to support forward planning across both service charge and capital expenditure strategies, ensuring improvements are financially structured and transparently managed.

The most efficient approach to MEES preparation aligns energy improvements with broader capital planning.

Where refurbishment or fit-out works are planned, incorporating energy improvements can significantly reduce incremental cost. Disruption is already occurring, contractors are already mobilised, and the marginal cost of adding energy measures is often lower than standalone works.

Where lease events are approaching, energy improvements can be coordinated with vacant possession or tenant negotiations. This allows works to proceed without operational disruption.

Where maintenance cycles are due, energy improvements can replace like-for-like replacements. Installing efficient equipment rather than simply renewing existing systems achieves multiple objectives simultaneously.

Building a MEES Strategy

A structured approach to MEES preparation helps ensure that portfolios are ready when regulations change.

This involves assessing current positions across all assets, identifying those at risk, prioritising improvements based on risk and opportunity, aligning works with capital and maintenance planning, and monitoring progress over time.

The outcome should be a clear pathway that ensures all assets can meet future requirements without last-minute pressure or unnecessary cost.

Conclusion

MEES 2028 represents a significant tightening of energy performance requirements for commercial property. Portfolios with D and E-rated assets face particular exposure.

The time to assess positions and plan improvements is now. Proactive preparation reduces cost, maintains options, and protects asset value.

Understanding where your buildings stand is the essential first step.

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