MEES and EPC compliance
MEES 2028 and your EPC rating: check the paperwork before the retrofit
What is MEES and what changes in 2028?
MEES, the Minimum Energy Efficiency Standard, prevents landlords in England and Wales from letting property rated below EPC band E unless a valid exemption is registered. The government has consulted on raising that minimum to band C later this decade, and 2027 and 2028 have both been discussed for commercial property, but no higher standard has yet become law.
What is in force, and what is still a proposal
It is worth separating the two, because budget decisions are being made against dates that have moved more than once. Band E is the standard that binds landlords today.
| Property and letting type | Minimum EPC rating | Applies from | Status |
|---|---|---|---|
| Domestic private rented, new tenancies | Band E | 1 April 2018 | In force |
| Domestic private rented, all tenancies including existing ones | Band E | 1 April 2020 | In force |
| Non-domestic private rented, new leases and renewals | Band E | 1 April 2018 | In force |
| Non-domestic private rented, continuing leases | Band E | 1 April 2023 | In force |
| Proposed higher minimum standard, domestic and non-domestic | Band C is the level generally discussed | Dates have been proposed and revised, including 2027 and 2028 | Proposal, not yet law. Check the current government position. |
Letting a substandard property is only lawful where an exemption applies, and exemptions are not automatic: they have to be registered on the PRS Exemptions Register and they are time limited.
A poor rating is not always a poor building
EPC assessment conventions are conservative by design. Where the assessor cannot see documentary evidence for what is installed, they are required to apply a default value, and defaults assume the least favourable plausible construction. A wall that was insulated during a refurbishment, but whose specification never reached the assessor, is rated as though it was not.
That matters because an EPC lasts for ten years. A rating produced years ago may still be carrying assumptions made on a day when nobody could find the commissioning file, while the evidence that would have changed it has been sitting in a SharePoint folder ever since.
So the sequence matters. Before approving retrofit spend on a building, establish whether the rating reflects the building or reflects the paperwork. A reassessment backed by complete evidence is a much cheaper first move than a specification written to close a gap that may be partly administrative.
Evidence that changes what an assessor can credit
- As-built drawings and specifications for the fabric, including insulation type and thickness
- U-value calculations and glazing specifications
- Air permeability and airtightness test certificates
- Boiler, heat pump and chiller efficiency data and model numbers
- Ventilation and HVAC commissioning records
- Lighting schedules, luminaire specifications and control strategies
- Building log book and Part L compliance output documents from the original design
- Records of upgrades made since the last assessment, with dates
Assemble the evidence before you assess
The documents usually exist. They are scattered across handover packs, project drives, contractor emails and legacy systems, under filenames that describe who sent them rather than what they prove.
Classify what you already hold
Findable reads your existing documents and classifies them by content and by building, so energy-relevant evidence stops being invisible.
See which buildings have gaps
Missing and expired documents are surfaced per building, which separates properties that need a reassessment from those that need genuine works.
Hand the assessor a complete pack
An organised evidence pack per building means fewer default assumptions and a rating based on what is actually installed.
The same evidence base serves the safety regime. See the Building Safety Act duties and what the golden thread requires .
MEES and EPC questions
What is the minimum EPC rating a landlord can let at today?
In England and Wales the minimum is EPC band E. It has applied to new domestic tenancies since April 2018 and to all domestic tenancies since April 2020, and to new non-domestic leases since April 2018 and to continuing non-domestic leases since April 2023. Letting below band E requires a valid exemption on the PRS Exemptions Register.
Is EPC C confirmed for 2028?
No. Raising the minimum standard above band E has been consulted on, and band C is the level generally discussed, but a higher standard only binds landlords once the regulations that set it have been made. Treat any published date as a planning assumption and confirm the current position before committing budget.
Can better documentation really change an EPC rating?
It can, because assessment conventions require the assessor to apply cautious default values wherever documentary evidence is not available. When the specification, test results or commissioning records for insulation, glazing, heating plant or lighting controls are produced, the assessor can rate what is actually installed instead of a default.
What evidence does an EPC assessor use?
Assessors work from documents rather than assumptions where documents exist: as-built drawings and specifications, U-value calculations, air permeability test results, heating and cooling plant efficiency data, lighting schedules and control specifications, and commissioning records. The more of that is available on the day, the fewer defaults are applied.
Does MEES apply in Scotland and Northern Ireland?
No. The Minimum Energy Efficiency Standard described here comes from regulations that apply in England and Wales. Scotland and Northern Ireland regulate the energy performance of rented property under their own rules, so a portfolio spread across the UK has to be checked jurisdiction by jurisdiction.
Check the paperwork before you commit the budget
Findable classifies the building documents you already hold, flags what is missing or expired, and assembles the evidence base an assessor, a regulator or a buyer will ask for.