Commercial EPC Requirements: When You Need One, and Who’s Responsible
If you own, sell or let commercial property, you’ll almost certainly need a valid commercial EPC at some point. This page sets out exactly when one is legally required, whose job it is to provide it, and what happens if you don’t — in plain English.
When is a commercial EPC legally required?
Under the Energy Performance of Buildings (England and Wales) Regulations 2012, a valid EPC is required whenever a non-domestic building is:
Built — a new commercial building needs an EPC on completion;
Sold — you must make a valid EPC available to prospective buyers; or
Let — you need one before marketing the property to rent, and to grant a new lease.
In short: if money is changing hands on the building — sale or lease — an EPC needs to exist and be available. A certificate is valid for 10 years, so you don’t need a new one for every transaction within that period, as long as a valid one already exists.
The triggers in detail — when exactly does the duty bite?
“Built, sold or let” hides some nuances that catch people out, so here’s the practical version:
Marketing for sale. The duty starts when the property goes on the market, not at exchange. You must commission an EPC before (or as soon as reasonably practicable after) marketing begins, and make it available to prospective buyers — agents should show the rating in the particulars.
Marketing to let. Same principle: an EPC needs to be in hand when the unit is advertised, and it must be given to the eventual tenant before the lease is granted.
Granting a new lease. A new lease to a new tenant always triggers the requirement. That includes subleases — a tenant subletting part of a building is “letting” for these purposes.
Lease renewals and extensions. This is the genuinely grey one. Renewing to the same tenant of the same space is generally understood not to trigger a fresh EPC duty in itself — but the minimum-rating (MEES) rules do apply to renewals, so in practice a landlord renewing a lease still needs to know the building’s rating. Don’t treat a renewal as a free pass.
Construction completion. A newly built commercial property needs an EPC when it’s physically complete — it’s the builder’s or developer’s job to get one and hand it to the owner, and building control will ask for it before signing the building off.
Major alterations. Works that change the number of parts of a building designed for separate use, where heating, hot water or air-conditioning services are also modified, can trigger a fresh EPC on the altered parts. If you’re splitting or combining units, check before the works finish.
What doesn’t trigger a requirement, by itself: simply owning and occupying the building, a rent review, or a change of use with no sale or letting. If none of the triggers above applies, you can lawfully have no EPC at all — until the day you market the property.
Do all commercial properties need an EPC?
Most do, but a handful of building types are exempt — for example certain places of worship, temporary buildings and very small stand-alone buildings. We cover these in full on our commercial EPC exemptions page. Listed buildings are a special case — they’re only exempt where compliance would unacceptably alter their character or appearance, which has to be judged case by case; our EPC for listed buildings guide explains it properly. If you’re not sure whether yours qualifies, it’s safer to assume you need one and check.
Who is responsible — landlord or tenant?
When a property is sold or let, it’s the seller’s or landlord’s responsibility (usually via their agent) to commission the EPC and make it available — not the tenant’s or buyer’s. If you’re a landlord, that responsibility also ties into the minimum-rating rules below.
Do you have to advertise the rating?
Where a commercial property is marketed for sale or let, the EPC rating should be stated in the particulars where applicable. It’s a small detail agents sometimes miss, and it’s part of being compliant — worth a quick check of your own listings, because it’s the easiest requirement on this page to fall foul of by accident.
What are the penalties?
Two separate sets of penalties apply, and they’re wildly different in size — worth keeping straight:
Not providing an EPC when required. Enforced by Trading Standards. For commercial property the penalty is typically 12.5% of the building’s rateable value, with a default minimum of £500 and a maximum of £5,000 per breach — and paying it doesn’t remove the duty, so you still need the certificate afterwards. There can also be a smaller fixed penalty for failing to show the rating in commercial advertising.
Letting below the minimum rating (MEES). This is the expensive one. Letting most commercial property rated F or G without a valid registered exemption can attract penalties of up to £150,000 per property under the current regime — the exact figure depends on rateable value and how long the breach has run, and breaches can also be published on a public register.
In practice, the fine is rarely the worst part. A missing or below-minimum EPC surfaces at the exact moment a solicitor is checking the deal, and stalled transactions cost more than penalties. Set against either number, the assessment fee is trivial — see our commercial EPC cost guide.
The bigger issue for landlords: minimum ratings
Having an EPC is one thing; the rating is another. There’s now a minimum rating you must meet to let most commercial property — covered on our minimum EPC rating for commercial property page. It’s the part that catches landlords out, so it’s worth reading before you market a unit.
Proposed changes: EPC C by 2027, B by 2030?
You may have read that commercial property will need an EPC rating of C by 2027 and B by 2030. Be careful with the word “will”: these dates come from government proposals for tightening the minimum standard, and at the time of writing they have not been confirmed in law — the timetable has been consulted on, debated and widely trailed, but landlords are still waiting for the final regulations. What’s sensible today is to treat the direction of travel as real (minimum standards are tightening) without treating unconfirmed dates as deadlines. We keep a full, current breakdown — what’s proposed, what’s actually law, and what a portfolio should do about it — on our commercial EPC regulations 2030 page.
A note on Scotland and Northern Ireland
The rules above are for England and Wales. Scotland and Northern Ireland have their own EPC regimes (Scotland also has Section 63 obligations for larger non-domestic buildings). If your property is there, ask us and we’ll point you the right way.
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Frequently asked questions
Do commercial properties need an EPC?
Most do — a valid EPC is required whenever a commercial building is built, sold or let. A small number of building types are exempt, but the safe starting assumption is that yours needs one.
Is a commercial EPC a legal requirement?
Yes — it’s required by the Energy Performance of Buildings Regulations when you sell, let or construct a commercial building. Failing to provide one is enforceable by Trading Standards with a financial penalty.
Who is responsible for the commercial EPC — landlord or tenant?
The seller or landlord, usually through their agent — not the tenant or buyer. A tenant subletting part of a building becomes a landlord for these purposes and takes on the same duty.
How long is a commercial EPC valid?
Ten years, unless a newer one is produced in the meantime. You don’t need a fresh certificate for every transaction within that period — one valid EPC covers them all.
What’s the penalty for not having one?
Typically 12.5% of the building’s rateable value, with a minimum of £500 and a maximum of £5,000 — and you still have to get the certificate afterwards. The stalled sale or letting usually costs more than the fine.
When is an EPC not required for commercial property?
When none of the triggers applies — no sale, no new letting, no construction — or when the building type is genuinely exempt, such as certain places of worship, temporary buildings or small stand-alone buildings. Simply occupying your own building requires nothing; the duty starts when you market it.
Do I need a new EPC to renew a commercial lease?
Renewing to the same tenant is generally understood not to trigger a fresh EPC requirement by itself. But the minimum-rating (MEES) rules do apply to renewals, so you still need to know the building’s current rating before renewing.
Do I need an EPC before marketing a commercial property?
Yes — the duty starts at marketing, not at completion. You must commission an EPC before or as soon as reasonably practicable after the property goes on the market, and the rating should appear in the advertising.
Do new commercial buildings need an EPC?
Yes — an EPC is required when construction is completed, and building control will expect it before sign-off. Getting it is the builder’s or developer’s responsibility, and it then covers the building for ten years.
Will commercial properties need an EPC rating of B by 2030?
That’s the government’s proposed direction, with C by 2027 also floated — but at the time of writing these dates are proposals, not confirmed law. Minimum standards are tightening either way, so it pays to know your rating now.
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