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Fit-out contractors should prepare now for the proposed 2031 EPC B standard—not because it is already law, but because design and specification choices can shape a building’s energy performance and EPC assessment. The Department for Energy Security and Net Zero’s current policy direction targets private-rented non-domestic buildings over 1,000 m² in England and Wales, where cost effective. Final legislation and implementation details are still pending.
What is the proposed 2031 EPC B deadline?
In its interim response updated 18 June 2026, the Department for Energy Security and Net Zero said it intends to require private-rented non-domestic buildings over 1,000 m² in England and Wales to reach EPC B from 2031, where cost effective. The government’s statement describes the target as proposed policy, not a binding requirement: read the interim response.
The proposal is targeted, not a universal standard for every commercial property. The government intends that smaller buildings remain subject to the existing EPC E minimum, with no fixed deadline for going beyond that standard. The proposal concerns private-rented buildings; it should not be assumed to cover owner-occupied or other non-domestic properties.
Does the proposal apply to a particular building?
Use the announced policy’s main distinctions as an initial screen. They indicate whether a building may fall within the intended scope, but do not replace final legislation or project-specific advice.
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| Question | Announced policy direction |
|---|---|
| Is the building private rented? | The proposal concerns private-rented non-domestic buildings. |
| Is it over 1,000 m²? | The intended EPC B target from 2031 applies to buildings over 1,000 m². Buildings at or below the threshold are intended to remain at EPC E, with no fixed deadline to go beyond it. |
| Is it in England or Wales? | The announced proposal specifies England and Wales. It should not be treated as a UK-wide rule. |
| Are improvements cost effective, or does a flexibility mechanism apply? | The proposed target is qualified by cost effectiveness. Existing flexibility mechanisms, including the seven-year payback test and exemptions, are intended to remain; detailed implementation is still to be confirmed. |
For buildings outside these stated categories, the June 2026 announcement does not establish that the proposed EPC B target applies. It also does not provide a full comparison with the rules in Scotland or Northern Ireland.
Is the EPC B requirement law yet?
No. The government has announced its intended direction but says further detail will come in a forthcoming consultation response. It aims to introduce legislation and updated guidance at the earliest opportunity. Until legislation is passed and details are published, describe EPC B from 2031 as a proposal rather than a settled legal deadline.
The same June 2026 response says the earlier proposed interim EPC C milestone for 2027 will not be taken forward. That change does not make the proposed 2031 target binding; the final rules and how existing flexibility mechanisms operate remain to be confirmed.
Why prepare if the rules are not final?
Fit-out decisions can become part of the assumptions used to assess a non-domestic building’s energy performance. Government guidance says: “The EPC should be based on the maximum design fit-out specification as used for compliance with Part L of the Building Regulations (in respect of the building’s use class in planning legislation).” See the government’s non-dwelling EPC guidance.
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That connection makes early coordination valuable: a specification agreed for a fit-out may be relevant to the EPC assessment, so clients, designers, contractors and assessors benefit from working from consistent assumptions. Building Regulations also treat certain material alterations and work affecting a building’s energy status or thermal elements as building work, with applicable work required to meet relevant requirements. The precise requirements depend on the work and building.
This does not mean every fit-out triggers MEES compliance, nor does it transfer the landlord’s legal duty to the contractor. It does mean contractors who identify relevant constraints and communicate design assumptions early can help clients plan without promising an EPC outcome that has not been assessed.
What should fit-out contractors do now?
- Screen the building. Ask whether it is private rented, whether its area is over 1,000 m², and whether it is in England or Wales. Treat this as a planning check against the announced proposal, not a legal determination.
- Record energy-related assumptions. Make clear in scope and design documentation which specifications and assumptions may affect energy performance, including the maximum design fit-out specification used for Part L compliance where relevant.
- Coordinate early. Discuss the fit-out specification with the client, design team and EPC assessor so the assessment reflects the intended design and applicable requirements.
- Avoid guaranteeing a rating. Do not promise EPC B—or any particular EPC result—without a building-specific assessment and clarity on the final rules.
- Keep policy status visible. Separate current obligations from proposed future standards in client communications and project records. Revisit plans when the government publishes its consultation response, legislation or updated guidance.
These are prudent project-planning steps, not additional legal duties established by the announced proposal.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What does the government’s tenant-savings estimate mean?
The government estimates that the proposed changes could deliver up to £360 million in tenant bill savings. This is a modelled estimate: it values changes in energy use in 2031 using projected 2031 retail energy prices, and is subject to refinement. It is not a guaranteed saving for a particular tenant, building or fit-out project.
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How is this different from the Future Homes and Buildings Standards?
The proposed MEES change concerns energy-efficiency requirements for existing private-rented non-domestic buildings. The Future Homes and Buildings Standards relate to changes to Building Regulations for new buildings, including Parts L and F. They are distinct policy matters; one should not be treated as a substitute for or confirmation of the other.
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