Multi-let industrial estates and the 1,000 m² threshold
Updated . Register figures: snapshot 30 Sep 2026.
Today MEES applies to each let "property", which can be a whole building or a unit within one, and the relevant EPC is the one for the space being let. For the EPC B standard proposed for 2031, the government hasn't said how the 1,000 m² threshold will be measured on a multi-let estate: its interim response says the detail will come in the full government response.
How does MEES work on a multi-let industrial estate today?
The regulations apply to a "property", defined as a building or part of a building. On a multi-let estate there may be an EPC for each unit, one for the whole building, or both, produced at different times with different ratings.
DESNZ's full landlord guidance says which one counts: where the space being let has its own EPC, that's the relevant one, even if there's also an EPC for the whole building. Where there's only a whole-building EPC (and one for the unit isn't legally required), the building EPC is the relevant one. The landlord only has to install measures that improve the let property, and it's fine if they also improve neighbouring units.
So each unit is judged on its own EPC. A unit rated F can't be let without an improvement or exemption, but that doesn't stop the landlord letting the units next to it that are rated E or better.
How are EPCs produced for industrial units in a block?
DCLG's guide to EPCs for non-dwellings gives worked examples for industrial units in blocks:
- Units sharing a common heating system: one EPC for all the units can be used for any unit when it's sold or let, though EPCs for separate parts can be produced if needed.
- Units with their own heating: it's permissible to produce an EPC for each unit plus one for the conditioned communal areas, or one EPC for the whole building.
- A unit with no conditioned space at all needs no EPC; a unit where only the office is heated gets an EPC that reflects the conditioned space, with the unconditioned space included in the calculation.
- Detached buildings or units with a total useful floor area under 50 m² don't need an EPC.
Certificates for units in a block can also be based on assessing a representative unit, if the assessor is satisfied the units are the same and visits enough of them to check.
What does the 2031 proposal say about the 1,000 m² threshold?
Very little. The interim response proposes EPC B from 2031 for "all private rented buildings over 1,000 square metres", where cost effective, and says: "Further detail on these proposals and implementation of the threshold will be set out in the forthcoming government response to the public consultations." None of these questions is answered yet:
| Question | What the interim response says |
|---|---|
| Is the threshold applied to the whole building, or to each let unit? | Not stated |
| Which floor area counts: the EPC's, the lease's, or another measure? | Not stated |
| How are estates of several buildings, or buildings with several EPCs, treated? | Not stated |
| Is a unit's own EPC, or the building's, the one that must reach B? | Not stated. Today the unit's own EPC is the relevant one |
| Does it apply to leases already running in 2031? | Not stated |
Why the measurement matters: an illustration
Take a terrace of six industrial units, 2,400 m² (25,833 sq ft) in all, each unit about 400 m² (4,306 sq ft) with its own EPC. If the threshold were applied to each let unit, none would be over 1,000 m² and all would stay at the E minimum. If it were applied to the building, the whole terrace would be over it. This is an illustration of why the detail matters, not a prediction: the government hasn't said which approach it will take.
How do our figures treat multi-let buildings?
Our figures use the floor area declared on each EPC, counting buildings strictly over 1,000 m². Because an EPC can cover a whole building or one unit, a building split into units with their own EPCs can appear as several smaller buildings, and a whole-building EPC as one larger one.
We identify buildings by their UPRN. Where several units share one UPRN, they collapse to the latest certificate, which under-counts. Our published statistics include a check with UPRNs that look multi-unit left out, and the methodology explains each rule.
On those rules, 25,619 industrial and warehouse buildings over 1,000 m² have a latest EPC rated C to E, with 94.02 million m² (1.01 billion sq ft) of floorspace (EPC register, snapshot 30 Sep 2026). Whatever the final rule, the units and buildings on an estate will each need their own check.
What can estate owners and managers do now?
- Map which EPC covers each unit, and whether there's also a whole-building EPC. Note the floor area, rating and lodgement date on each.
- Find the units already rated F or G: they need an improvement or exemption to be let today, whatever happens in 2031.
- Check the leases for who pays for improvements to units and common parts, and whose consent works need. The landlord guidance advises landlords and tenants to consult their lease and take advice.
- Where works need a tenant's or superior landlord's consent and it's refused, the third-party consent exemption may apply. See MEES exemptions.
- Plan EPC renewals around lettings, so a new certificate arrives when it's needed rather than at a lease event under time pressure.
Questions people ask
Is a multi-let industrial estate one building for MEES?
Today MEES applies to each let property, which can be a building or part of one. The relevant EPC is the one for the space being let where it has one, otherwise the whole building's EPC. How the 2031 proposal's 1,000 m² threshold applies to multi-let estates hasn't been set out.
If one unit is rated F, can I still let the others?
Yes. Each let unit is judged on its relevant EPC. The F rated unit needs an improvement to E or a registered exemption before it can be let; units rated E or better can be let.
Who pays for improvements to common parts on a multi-let estate?
It depends on the leases. The landlord guidance says leases may set out which party is liable for improvement costs, and advises landlords and tenants to check their lease and take advice.
Does the 1,000 m² threshold use gross internal area?
The interim response doesn't say how the threshold will be measured. Our figures use the floor area declared on each EPC.
Does a unit with no heating need an EPC?
DCLG's guide says a unit with no conditioned space needs no EPC. Where only part, such as an office, is heated, the EPC reflects the conditioned space, with the unconditioned space included in the calculation.
Sources
- DESNZ: Minimum energy efficiency standards (MEES) in the non-domestic private rented sector, interim response (GOV.UK, 18 June 2026)
- The Non-Domestic Private Rented Property Minimum Standard: guidance for landlords and enforcement authorities (PDF, GOV.UK)
- DESNZ: Non-domestic private rented property: minimum energy efficiency standard, landlord guidance (GOV.UK, updated 5 May 2026)
- DCLG: A guide to Energy Performance Certificates for the construction, sale and let of non-dwellings (GOV.UK, updated December 2017)
- BEIS: Non-domestic private rented sector minimum energy efficiency standards, EPC B implementation, consultation (PDF, March 2021)
Register figures come from the government's EPC register for England and Wales, published under the Open Government Licence. How we got these figures.
This guide summarises the rules to help you find your way. It isn't legal advice: check the current guidance on GOV.UK, or take advice, before acting on it.