What the government has proposed
The Department for Energy Security and Net Zero's interim response of 18 June 2026 proposes EPC B from 2031 for privately rented non-domestic buildings over 1,000 square metres in England and Wales, where cost effective. Buildings below that threshold would remain subject to EPC E.
The previously proposed EPC C milestone for 2027 will not proceed. Existing flexibility mechanisms, including exemptions and the seven-year payback test, are intended to remain.
The interim response says the higher standard will take effect only after secondary legislation passes. Read this as a proposed policy timetable, not a statement that the EPC B requirement is already in force.
An EPC is not a meter reading
An EPC rates the modelled energy performance of the building and its services. It does not measure the energy your business actually uses.
A reduction in consumption therefore does not automatically improve an EPC rating. Before treating any measure as part of an EPC compliance plan, ask your accredited assessor how it can be recognised in the assessment.
Put your building information in order
- Check the scope. Confirm the property use, lease arrangements, floor area, current EPC and any registered exemption with your advisers.
- Review the whole portfolio. Identify buildings over 1,000 square metres below EPC B, then agree priorities with your assessor.
- Separate the decisions. Keep EPC improvement, operational energy savings and carbon reporting clear in the investment proposal.
- Build an evidence base. Keep consistent meter readings and a record of occupancy, operating hours and changes to the plant.
Where an OH4 pilot fits
An OH4 pilot assesses energy performance at your building using meter readings and an agreed comparison method. It does not promise an EPC uplift or demonstrate MEES compliance.
Discuss the pilot alongside your wider building plan, with your engineer and EPC assessor involved where appropriate.
This guide is general information for England and Wales. Check the latest official guidance and your building's requirements with your professional advisers.