MEES for industrial and warehouse buildings, in plain English

What is MEES?

MEES is the Minimum Energy Efficiency Standard for privately rented property in England and Wales. For non-domestic buildings it is set by Part 3 of the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, and today's minimum is an EPC rating of E.

In the regulations' words, a let building is "sub-standard" when it has a valid EPC rated below E, which means F or G. A landlord must not let a sub-standard building unless an exception or exemption applies and has been registered. The rules apply to any landlord, including public bodies, and to industrial units and warehouses as much as to offices and shops.

When does the E minimum apply to an industrial unit or warehouse?

Regulation 27 sets two dates. Since 1 April 2018, a landlord must not grant a new tenancy of a sub-standard property, or extend or renew an existing one. Since 1 April 2023, a landlord must not continue to let one, even where the tenancy hasn't changed.

DESNZ's landlord guidance puts the test as three questions. If the answer to all three is yes and the EPC is F or G, the landlord must act:

1. Is the property non-domestic? Most commercial buildings, including industrial units and warehouses, are.
2. Is it legally required to have an EPC? A building generally needs one when it's sold, let or built, so one marketed, let or modified in the last 10 years probably does.
3. Is it let on a tenancy for a fixed term of more than 6 months and less than 99 years?

Which industrial buildings are outside MEES?

Several common situations fall outside the rules, so a poor rating alone doesn't mean a breach:

• Buildings that aren't let. An owner-occupied unit isn't caught, and the guidance says an empty building needs no action until the owner decides to let it. See owner-occupied or let: when MEES applies.
• Short and very long leases. Regulation 20 excludes tenancies granted for a fixed term of 6 months or less (unless the lease can be renewed or extended beyond 6 months, or the tenant has already been in occupation for more than 12 months) and tenancies of 99 years or more.
• Licences and agreements for lease. The full guidance says property occupied other than under a tenancy, for example on a licence, is unlikely to be required to meet the minimum standard.
• Buildings that don't need an EPC. GOV.UK lists "an industrial site, workshop or non-residential agricultural building that does not use much energy". The 2016 definition reproduced in the landlord guidance includes storage and warehouses where the air is not fully heated or cooled. Whether a given building qualifies is a judgement for the owner and their advisers: the government says it can't advise on individual buildings.
• Voluntary EPCs. If a building didn't legally need an EPC and the owner commissioned one anyway, the full guidance says registering it doesn't, by itself, require the landlord to meet the standard.

How do MEES exemptions work?

Where a building can't reasonably reach E, the landlord can register an exemption on the government's PRS Exemptions Register, and can then let it. The grounds are: the improvements fail the 7-year payback test; all relevant improvements have been made and it's still below E; wall insulation would damage the building; a tenant, lender, superior landlord or planning authority refused consent; the work would cut the property's value by more than 5%; and a temporary 6-month exemption for some new landlords.

Most exemptions last 5 years, apply only from the day they're registered, and don't pass to a buyer. The details, evidence and registration steps are in MEES exemptions for commercial landlords.

What are the penalties for breaching MEES?

The rules are enforced by local weights and measures authorities. If they think a property may be let in breach, they can serve a compliance notice asking for the EPC, the lease and evidence of improvements, up to 12 months after the suspected breach. Where a breach is confirmed they can serve a penalty notice. The landlord can ask for a review and then appeal to the First-tier Tribunal.

More on what's unlawful today, and the options for a building below E, is in F and G rated industrial units.

What's proposed for 2031?

On 18 June 2026 the government said, in an interim response to its 2019 and 2021 consultations, that "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". Buildings under 1,000 m² (10,764 sq ft) would stay at E, and the previously proposed EPC C step for 2027 has been dropped.

It isn't law. The change "will only take effect following the successful passage of secondary legislation", and the 7-year payback test and exemptions remain. What's settled and what isn't is in EPC B by 2031.

How many industrial buildings does MEES 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.)

The E minimum applies to let buildings of any size. Counting every industrial and warehouse building on the register, including workshops and depots, 5,487 have a latest EPC rated F or G. An EPC doesn't record whether a building is let today, so these figures are an upper bound on breaches, not a count of them.

These are the local authorities with the most floorspace rated C to E, the buildings the 2031 proposal would reach:

What should a landlord or adviser check for each building?

• Whether it's let, and on what kind of lease: MEES only applies to tenancies of more than 6 months and less than 99 years.
• Its current EPC rating, asset rating and floor area, and whether it's over 1,000 m² (10,764 sq ft).
• When the EPC runs out. It lasts 10 years, and a building needs a valid one to be sold or let. See EPCs and lease events.
• Whether an exemption is registered, and when it ends. The public register can be searched on GOV.UK.
• What the assessor recommended on the certificate, as the starting point for costing improvements. See how to improve an industrial unit's EPC.