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    Commercial MEES: planning a portfolio to 2030

    MEES exposure on a commercial portfolio is rarely evenly spread. A handful of assets usually carry most of the risk, and finding them early is what makes the spend manageable.

    11 min readBy Nabhan Islam Reviewed by Awais Sarwar, MSc Updated 9 Sept 2026

    Commercial MEES: planning a portfolio to 2030

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    The short answer

    Minimum Energy Efficiency Standards make it unlawful to continue letting a sub-standard commercial property, currently below EPC band E, unless a valid exemption is registered. Government policy has signalled tighter minimum standards for commercial lettings later this decade, so portfolio planning should identify assets at E and D now rather than only those already failing. The workable approach is a portfolio audit: confirm which certificates are valid, model where each asset would land on reassessment, group assets by lease event, and spend first where a lease expiry or rent review collides with a sub-standard rating.

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    Current minimum standard

    EPC band E

    for continued commercial letting, subject to exemptions

    Direction of travel

    tighter standards signalled

    plan D and E rated assets, not just failures

    Exemptions

    must be registered

    on the PRS Exemptions Register, with evidence, and they expire

    Certificate validity

    10 years

    an old certificate may not reflect current assessment methodology

    Start with what you actually hold

    Most portfolios do not have a reliable picture of their own EPC position. Certificates sit in different agents' files, some have expired, some were lodged against the wrong demise after a reconfiguration, and some reflect a building that has since been refurbished. Before any capital is committed, the register position for every asset should be pulled together into one schedule: address, demise, certificate reference, rating, score, lodgement date, expiry and whether the asset is currently let. That schedule alone routinely changes spending plans, because it exposes assets that are closer to the threshold than assumed and others that are already non-compliant on a live letting.

    • One schedule covering every asset, demise and certificate reference
    • Flag expired certificates and certificates lodged against superseded demises
    • Identify assets refurbished since their certificate was produced
    • Record which assets are currently let, and on what lease events

    Model the near-miss assets, not just the failures

    Assets already below the minimum standard are the obvious problem, but the more expensive surprises are assets at E and D. As standards tighten, those become tomorrow's failures, and the cheapest time to deal with them is during a planned refurbishment or void rather than under pressure at a lease event. Modelling matters here: a reassessment using better evidence — actual plant data, controls, lighting upgrades already installed but never documented — sometimes lifts a rating without capital works at all. Equally, an asset that scored well a decade ago under different methodology may score worse on reassessment, which is exactly the kind of thing you want to know before a rent review, not during one.

    • Treat E and D rated assets as planning problems with a timeline
    • Reassess where undocumented upgrades have already been carried out
    • Expect methodology changes to move some ratings downwards on reassessment
    • Model improvement options by cost per band rather than by measure

    The buildings behind this advice

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    Exemptions: useful, temporary, evidenced

    Exemptions exist for defined circumstances — for example where all relevant improvements have been made and the property remains sub-standard, or where required consents have been refused, or where a measure would devalue the property beyond the permitted threshold. They must be registered on the PRS Exemptions Register with supporting evidence, they apply to a specific property and landlord, and they expire, at which point the position must be revisited. Treating an exemption as a permanent solution is a common and expensive error: an unregistered or unevidenced exemption is no defence at all if enforcement action follows.

    • Exemptions are specific, evidenced and time-limited
    • Registration is required — an unregistered exemption offers no protection
    • Evidence obligations mean advice and quotes need keeping, not discarding
    • Diarise expiry dates alongside lease events on the portfolio schedule

    Sequence spend around lease events

    The financial consequence of a sub-standard rating usually crystallises at a lease event: a new letting, a renewal, a regear, sometimes a disposal or refinancing. That makes lease events the natural sequencing tool. Assets with a sub-standard or borderline rating and an event inside the next eighteen months come first; assets with long unexpired terms and a borderline rating can be scheduled into a planned refurbishment. Coordinating works with voids is where the real savings sit, because works in occupation cost more, take longer and often need tenant consent that is not guaranteed.

    • Rank assets by rating risk against lease event date
    • Use voids and planned refurbishment windows to carry out improvements
    • Factor tenant consent and access constraints into the programme, not just cost
    • Re-lodge certificates after works so the improvement is on the register, not just in a report

    How we handle portfolio MEES work

    We take the asset schedule, confirm the register position, reassess where a certificate is unreliable or expired, and produce a ranked improvement plan with indicative costs and expected band movement per asset. Awais Sarwar leads commercial MEES work personally, so the advice about where to spend comes from the assessor accountable for the resulting certificates. Where a portfolio also carries residential assets, blocks or mixed-use buildings, the domestic and non-domestic workstreams run under one instruction, with fire risk and electrical certification coordinated through our sister brand where those are needed on the same buildings.

    • Register verification and reassessment where certificates are unreliable
    • A ranked improvement plan with expected band movement per asset
    • Certificates re-lodged after works so the register reflects reality
    • One instruction across domestic, commercial and mixed-use assets

    Written by

    Nabhan Islam

    Head of Marketing & Commercial Lead

    Reviewed by

    Awais Sarwar, MSc

    Accredited Energy Assessor — Accredited domestic and commercial energy assessor, listed on the EPC Register

    11 min readLast reviewed 9 September 2026Facts verified 9 September 2026 Checked quarterly

    Sources

    1. The Energy Performance of Buildings (England and Wales) Regulations 2012 legislation.gov.uk
    2. Find an energy certificate GOV.UK

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