EPC B by 2031: what the proposal means for industrial landlords

What did the government announce on 18 June 2026?

An interim response to its 2019 and 2021 consultations on strengthening non-domestic MEES. It says the government is "confirming its intention" to implement four things:

• "from 2031, it is proposed that all private rented buildings over 1,000 square metres in England and Wales will need to reach a higher standard of energy efficiency of EPC B, where cost effective";
• "the intention is for buildings below 1,000 square metres to continue to be subject to the current minimum standard of EPC E";
• "the previously proposed interim EPC C milestone for 2027 will not be taken forward";
• "existing flexibility mechanisms, including the 7-year payback test and exemptions, will remain in place".

It estimates that tenants in the largest rented buildings could save £360 million a year on bills by 2031, a figure it says is "subject to refinement as the policy develops".

Is EPC B by 2031 the law?

No. The interim response says the change "will only take effect following the successful passage of secondary legislation through Parliament", and that the government "aims to introduce legislation and updated guidance at the earliest opportunity". When we last checked (12 October 2026), neither the full government response nor draft regulations had been published.

Until new regulations are made, the rules in force are today's: a let non-domestic building needs an EPC of E or better, or a registered exemption. See MEES for industrial and warehouse buildings.

What's decided, and what isn't yet?

Nothing about 2031 is legally decided. This is what the interim response says, and what it leaves open:

What happened to EPC C by 2027 and EPC B by 2030?

They were earlier proposals that were never made law. The 2021 consultation proposed EPC B by 2030 for privately rented non-domestic buildings of every size, reached through two-year compliance windows: present a valid EPC by 1 April 2025, reach EPC C by 1 April 2027, present a valid EPC by 1 April 2028, and reach EPC B by 1 April 2030.

The 2026 interim response replaces that with a narrower plan: B from 2031 only for buildings over 1,000 m², no 2027 C step, and smaller buildings left at E. Anything still describing "EPC C by 2027" or "EPC B by 2030" is out of date.

Why buildings over 1,000 m²?

The interim response calls it a targeted approach that "focuses action where it delivers the greatest benefits", while giving "additional flexibility to SMEs and high street landlords of smaller properties". The 2021 consultation's analysis had found that buildings over 1,000 m² were around 5% of the private rented non-domestic stock in England and Wales but used about half of its energy.

How many industrial buildings would it touch?

Across England and Wales, 25,619 industrial and warehouse buildings over 1,000 m² (10,764 sq ft) have a latest EPC rated C, D or E: 94.02 million m² (1.01 billion sq ft) of floorspace that meets today's E minimum but falls short of the EPC B standard proposed for 2031. Another 1,037, with 3.57 million m² (38.4 million sq ft), are rated F or G, below today's minimum. 11,492 are rated B or better. (EPC register, snapshot 30 Sep 2026; general industrial and storage or distribution uses.)

Most of that gap is one or two bands. Of the 25,619 rated C to E, 13,791 are rated C, 8,567 D and 3,261 E.

Of the 25,619 buildings over 1,000 m² rated C to E, 6,062 (23.7%) had an EPC that had already lapsed at the snapshot and 7,525 more were estimated to lapse before 2031: 13,587 in all (53.0%). We estimate expiry as the lodgement date plus 10 years, because the register's data has no expiry date (snapshot 30 Sep 2026).

For 11,499 of the C to E buildings (44.9%), the latest EPC was lodged for a letting. The register doesn't record whether a building is let today, so owner-occupied buildings, which the proposal wouldn't cover, are included in these figures.

Which regions and local authorities have the most C to E floorspace?

By floorspace rated C to E, the largest regions are North West, West Midlands and East Midlands, and the largest local authorities are Birmingham, West Northamptonshire and Leeds. Each authority's page has its own figures: start from the MEES map by local authority.

What does "where cost effective" mean?

Today it means the 7-year payback test. A measure, or package of measures, fails the test when the expected energy bill savings over 7 years from installation are less than the cost of buying and installing it. A landlord who shows that, with 3 installer quotes and the calculations, can register a 5-year exemption. The interim response says the test remains.

So being rated below B wouldn't, on its own, mean a building must reach B: it would need to make the improvements that pass the test. How the test will work for B isn't set out yet. More in MEES exemptions.

What can landlords and advisers do now?

• List which let buildings are over 1,000 m² (10,764 sq ft) and rated C, D or E: they're the ones the proposal would reach. Note how the floor area was measured on each EPC.
• Note when each EPC runs out. A new assessment is a chance to see what B would take, and a lapsed EPC will need replacing at the next letting or sale anyway.
• Read the recommendation report on each certificate and start costing measures against the 7-year payback test. See how to improve an industrial unit's EPC.
• For multi-let estates, map which EPC covers which unit, because the threshold's measurement is still open. See multi-let estates and the 1,000 m² threshold.
• Fix today's problems first: any let building rated F or G already needs an improvement or an exemption.
• Watch for the full government response and draft regulations.