Introduction
Currently, the Minimum Energy Efficiency Standards Regulations (MEES) prohibit landlords from letting properties with an EPC rating below E. Despite this, there have been numerous efforts to raise these standards across all private rented properties. In February 2025, the Government launched a consultation on Improving the Energy Performance of Privately Rented Homes proposing an EPC C rating by 2030. For non-domestic private rented properties, however, the overall aim is more ambitious, with previous consultations proposing an EPC B rating by 2030. Yet, these discussions have been ongoing for years and have lacked clarity, leaving the industry in a state of uncertainty.
Is the current Labour Government on track to provide clear proposals and legislation that the former Conservative Government failed to do? Is the period of uncertainty for commercial landlords nearing an end? Should they be embarking on the journey towards energy-efficient upgrades?
Timeline
December 2020: The Energy White Paper is published and outlines a target for non-domestic private rented properties to achieve an EPC B rating by 2030.
June 2021: The Government publishes the Non-Domestic Private Rented Sector MEES Consultation, outlining implementation milestones (EPC E by 2025, C by 2027, and B by 2030).
January 2023: The Independent Review of Net Zero recommends legislating EPC B for all non-domestic private rented properties by 2025.
March 2023: The Government’s response lacks a firm commitment to legislate higher EPC ratings, focusing instead on reviewing energy performance measurements, with changes expected by late 2026.
September 2023: Former Prime Minister Rishi Sunak announces the scrapping of EPC proposals due to concerns over costs and rent increases.
July 2024: The Climate Change Committee’s (“CCC”) report criticises the scrapping of EPC proposals as a missed opportunity.
July 2024: The Labour Government announces the reinstatement of energy efficiency proposals, targeting EPC C for domestic private rented properties by 2030.
December 2024: The Labour Government’s response to the CCC report said it plans to consult on EPC regulations, with a response to the Non-Domestic Private Rented Sector MEES consultation expected in early 2025.
February 2025: A consultation on Improving the Energy Performance of Privately Rented Homes is published, proposing higher standards for new tenancies from 2028 and all tenancies by 2030.
Late 2025: The Government has yet to provide the anticipated response for the non-domestic private rented sector, leaving the industry without a clear compliance timeline.
So, what can we conclude?
Despite some turbulence, there has been a degree of consistency. When you sift through the seemingly endless consultations, a clear path to achieving the UK’s 2050 net zero target, by way of raising MEES Regulations, emerges. The real challenge lies in the practical implementation of such an ambitious regime. While the Labour Government needs time to consult, the Conservative Government’s 2023 response to the Net Zero recommendation to legislate was never directly addressed, and the proposals were later scrapped. So, there has been former reluctancy towards implementing such a regime and the Labour Government may also face the same delay. For example, these consultations involve a catalogue of questions for industry members and organisations to answer, which previously led the Conservative Government to deem the proposals impractical. Concerns about higher rents and costly upgrades are valid, yet the Labour Government seem determined to face the storm head-on. The question remains whether they will withstand the pressure or perform a touch-and-go manoeuvre.
Time is Ticking
As the year draws to a close, the anticipated response to the Non-Domestic Private Rented Sector MEES consultation, originally expected in early 2025, remains unpublished. This raises the question of whether the Government will deliver this response just in time for Christmas, offering landlords a possibly unwelcome yet practical gift, or if it will be deferred to the New Year. If so, commercial landlords may face a costly list of New year’s energy resolutions to tackle in the coming year.
Overall, landlords should continue to remain vigilant. It is wise to consider starting upgrades, with the hope that a response and implementation proposal will be released soon. It may not be that the target will be an EPC B rating by 2030, but a change is expected nonetheless.