EPC B by 2031, and what the law actually requires today

Status: LawA privately rented non-domestic property in England and Wales must reach EPC E to be let. That is the enforceable minimum standard now, under the Minimum Energy Efficiency Standard regulations.

Civil penalties reach up to £150,000 per breach, and a breach is published on the PRS Exemptions Register, which is public.

Scotland operates a separate regime and is not covered by this sheet.

Status: ProposedThe government has set out an intention to raise the minimum to EPC B by 2031 for privately let non-domestic buildings over 1,000 square metres, where the improvement is cost effective.

That takes effect only on the successful passage of secondary legislation. It is not currently a requirement, and the final detail, including how the cost-effectiveness test works, is still to be settled.

We describe it as a planning assumption rather than an obligation, because that is what it is.

This is the part most published guidance has not caught up with.

An interim requirement of EPC C by 2027 was previously proposed. It will not be taken forward. A great deal of currently published material still prints "EPC C by 2027, EPC B by 2030" as though it were settled. It was never law, and it is superseded.

If your adviser, your lender’s questionnaire or your compliance calendar still carries a 2027 EPC C date, it is working from a superseded trajectory.

The works that raise an EPC rating are largely the works that reduce consumption. Energy avoided is money kept in the business from the day the work is done. The rating improvement is a requirement you were likely to face anyway.

Doing them together means one set of works, one disruption and one capital decision.

There is also a timing argument. If the requirement passes, the buildings that need work will be competing for the same contractors and the same surveyors in the same window before the deadline. Early movers avoid that squeeze. Late movers pay for it.

We do not publish a worked example of what this is worth. It depends entirely on your consumption, your contracts and your current rating, and any number we printed here would be a sales figure rather than an analysis. We model it from your actual portfolio.

• Know the current rating and expiry date for every let property. An expired certificate is its own problem.
• Establish which properties would be in scope of the proposal, on floor area and letting status, rather than assuming the whole portfolio is.
• Get a costed improvement path for the ones that would be, so the decision is available when the legislation lands rather than starting then.
• Treat the E floor as the live obligation and the B target as the planning assumption. Do not let a proposal drive a capital decision that the current law does not require.