MEES (Minimum Energy Efficiency Standards) Regulation

The Minimum Energy Efficiency Standards represent one of the most significant regulatory shifts for landlords in England and Wales over the past decade. Whether you’re managing a single buy-to-let or overseeing a larger portfolio, understanding these rules is essential for staying compliant and avoiding substantial penalties.

This guide breaks down everything you need to know about energy efficiency standards MEES—from checking if your property falls within scope to navigating exemptions and preparing for upcoming changes.

Quick overview: what MEES means for landlords and property owners

The Minimum Energy Efficiency Standards apply to most private rented properties in England and Wales, covering both domestic and commercial sectors. Since 1 April 2020 for domestic properties and 1 April 2023 for commercial, it has been unlawful to let a property with an energy performance certificate rating of F or G unless a valid exemption is registered on the official PRS Exemptions Register.

Here’s what you need to know at a glance:

• Current minimum standard: EPC rating of E or above
• Who’s affected: Landlords in the private rented sector (domestic and commercial)
• Consequences of non compliance: Fines up to £5,000 per domestic property and up to £150,000 for serious commercial breaches, plus restrictions on letting

The government has signalled clear intentions to tighten these requirements further. Proposals aim for most privately rented homes to achieve a C rating by 2030, with commercial properties expected to follow a similar trajectory. These upcoming changes mean landlords should start planning improvements now rather than waiting for deadlines.

The rest of this article provides a step-by-step guide covering: checking if MEES applies to your property, improving your EPC rating, accessing funding and exemptions, and understanding enforcement procedures.

Scope of the MEES regulations: which properties are covered?

The MEES regulations apply to private rented property in England and Wales that legally requires an energy performance certificate EPC. This covers the vast majority of rental properties, though certain exceptions exist.

For domestic properties, the following tenancy types fall within scope:

• Assured shorthold tenancies
• Assured tenancy agreements
• Regulated tenancy arrangements
• Domestic agricultural tenancy agreements under the Housing Act 1988 and related legislation

The regulations also capture most commercial (non-domestic) leases granted for office spaces, retail units, and industrial premises where an EPC is required when the property is marketed for sale or rent.

EPC requirements typically trigger when:

• A property is marketed for sale or rent
• A new tenancy is granted
• Major construction or modification works are carried out
• An existing certificate expires (EPCs are valid for 10 years)

Certain property types fall outside the MEES scope:

• Listed buildings where compliance works would unacceptably alter the building’s character
• Very short lettings under 6 months without renewal rights
• Long leases granted for 99 years or more
• Some buildings that genuinely don’t require an EPC under separate legislation

How to check if MEES applies to your property

Use this simple checklist to determine whether your property falls within the MEES regulations:

Question	If Yes	If No
Is the property in England or Wales?	Continue to next question	MEES does not apply
Is the property private rented (not owner-occupied)?	Continue to next question	MEES does not apply
Is there a legal requirement for an EPC?	MEES applies	MEES does not apply

If your property’s rating shows F or G on the energy performance certificate, it’s legally classified as “sub-standard” under the regulations.

If your property has no valid EPC but would normally require one, obtain an EPC before deciding on next steps.

To confirm existing certificates, expiry dates, and historic ratings, use the official EPC register at gov.uk. This government database allows you to search by address and view all registered certificates.

If your property genuinely falls outside MEES scope—for example, a listed building with a formal exemption from EPC requirements—you don’t need to take MEES-specific action. However, voluntary improvements to energy performance can still deliver benefits for tenants and property values.

Key dates and current legal minimum standards

The MEES regulations have been phased in over several years, with different milestones applying to domestic properties and commercial leases.

Domestic property deadlines:

• 1 April 2018: New lets and renewals must achieve at least EPC E (or have a registered exemption)
• 1 April 2020: All qualifying domestic tenancies, including existing tenancies, must reach EPC E or have an exemption

Commercial property deadlines:

• 1 April 2018: No new commercial leases below EPC E without exemption
• 1 April 2023: All qualifying non-domestic leases must be EPC E or exempt

From these dates, it became unlawful to continue letting an F or G rated property unless a valid exemption appears on the PRS exemptions register. Property owners who breach these rules face financial penalties enforced by local authorities.

While the current legal baseline remains EPC E, government policy is clearly moving towards tighter energy performance standards to support the UK’s net zero commitments.

Future trajectory: proposed tighter MEES standards

The government’s stated ambition is for most privately rented homes in England and Wales to reach EPC band C by 2030, subject to consultation and final legislation. Labour’s 2024-2025 announcements revived proposals that had been paused, with potential interim requirements for EPC D by 2025 under review.

Industry expectations suggest commercial properties may face staged requirements:

• EPC C around the mid-to-late 2020s
• EPC B around 2030

These timelines remain subject to policy announcements and may shift, but the direction of travel is clear.

Practical planning steps for landlords and investors:

• Commission EPC reviews now to understand current ratings across your portfolio
• Budget for phased upgrades, recognising that C-level improvements can cost £10,000-£20,000 for harder-to-treat properties
• Prioritise worst-performing buildings first, targeting F and G rated properties immediately
• Factor improvement costs into acquisition decisions and lease negotiations

The gap between the current minimum energy efficiency requirement (EPC E) and the expected future standard (EPC C) is significant. Early planning allows you to spread costs and access funding opportunities before demand peaks.

Landlord responsibilities under MEES

Ultimate legal responsibility for MEES compliance sits with the landlord or superior landlord granting the tenancy. While agents and managing agents can help implement the requirements, they don’t normally remove the landlord’s legal duty to comply.

Core landlord duties:

• Ensure a valid EPC is in place when required
• Achieve at least EPC E before granting or continuing tenancies (unless exempt)
• Keep evidence of improvements, decisions, and funding arrangements
• Review EPC recommendations and determine which improvements can reasonably be installed

Landlords should examine the EPC recommendation report and decide which “relevant energy efficiency improvements” can be installed within regulatory cost or feasibility limits. The regulations define specific criteria for what counts as a relevant improvement.

Tenant communication obligations:

• Inform tenants about planned improvement works
• Coordinate access for assessments and installations
• Seek consent where required for intrusive measures

Where tenant consent is sought but refused, this may form the basis for a third-party consent exemption—but only after genuine attempts to secure agreement.

Domestic MEES: cost cap and “relevant improvements”

For domestic private rented properties, a £3,500 cost cap (including VAT) currently applies. Landlords are not required to spend more than this amount to achieve compliance.

The rules work as follows:

1. Landlords must install all “relevant energy efficiency improvements” up to the £3,500 cap
2. Funding can come from self-funding, third-party sources, or a combination
3. If the property remains below EPC E after installing all measures up to this cap, the landlord can usually register an “all relevant improvements made” exemption

Common improvement measures include:

• Loft insulation (can reduce heat loss by up to 25%)
• Cavity wall insulation
• Efficient condensing boilers (achieving 90%+ efficiency versus 70% for older units)
• Double or triple glazing
• Low-energy lighting
• Draught-proofing
• Heating controls upgrades

Note that commercial MEES operates differently, without the same fixed cost cap. Non-domestic properties are subject to cost-effectiveness and payback period tests rather than a simple spending threshold.

Funding energy efficiency improvements

Landlords can meet MEES obligations using their own funds, external funding, or a combination of both. Using available support can significantly reduce your net costs while achieving compliance.

For domestic properties, the total spend counting towards the MEES cost cap is £3,500 including VAT, regardless of the funding source. This means grants and your own contribution both count towards the threshold.

Practical example: A landlord uses a local authority grant of £1,500 for loft insulation, then spends £2,000 of their own money on a new condensing boiler. The combined £3,500 meets the cap, and the property achieves EPC E.

Keep all invoices, grant letters, and funding agreements as evidence for future enforcement queries. Local authorities may request this documentation to verify your compliance.

Third-party funding

Third-party funding sources include:

• Government grants (such as successors to the Green Homes Grant)
• Local authority schemes
• Energy supplier obligations (ECO4 and similar programmes)
• Green finance products

If fully funded measures raise the property to EPC E or above, your financial contribution may be zero while still meeting MEES obligations. However, all available funding must be applied to install appropriate improvements before claiming certain exemptions.

Example: A landlord secures ECO4 funding covering full cavity wall insulation costs. Combined with existing loft insulation, the property moves from F to E without any landlord expenditure.

Combination of third-party funding and self-funding

In many cases, external grants cover part of the required works while landlords fund the remainder:

• Local authority scheme covers insulation (£1,200)
• Landlord funds boiler upgrade and controls (£2,000)
• Combined total: £3,200 (within the £3,500 cap)

Planning considerations:

• Apply for available grants before committing to self-funded works
• Prioritise measures delivering the largest EPC uplift within your combined budget
• Document all funding sources clearly
• Time applications to align with your tenancy arrangements

Self-funding

Where no external support is available, landlords may need to fund works entirely from their own resources, still subject to the £3,500 domestic cap.

The obligations work as follows:

• If recommended measures cost less than the cap and would achieve EPC E, all such measures must be installed
• If recommended measures exceed the cap, install as many as possible up to £3,500
• After reaching the cap without achieving EPC E, consider registering a qualifying exemption

Many landlords find that the required investment—often £2,500-£3,500 for typical F-rated properties—delivers returns through higher rental values (E+ properties can command 5-10% higher yields) and reduced void periods.

Selecting and prioritising energy efficiency measures

Every EPC report includes recommended measures showing their expected impact on the property’s rating. These typically appear as a short “top actions” summary plus a longer detailed list.

When reading these recommendations, focus on:

• Measures labelled as cost-effective for the building type
• Works that deliver the largest rating improvement per pound spent
• Items that are technically suitable for your property’s construction

“Relevant energy efficiency improvements” under MEES are those recommended by an EPC (or a recognised assessment such as a Green Deal assessment) that meet cost or payback criteria.

Typical priority order for improvements:

1. Insulation: Loft and cavity wall insulation offer the best returns
2. Heating system upgrades: High-efficiency condensing boilers
3. Glazing improvements: Double or triple glazing where feasible
4. Low-energy lighting and controls: Often lower cost with incremental gains

Practical factors also matter:

• Access requirements and disruption to tenants
• Planning permission for external works
• Building control requirements
• Listed building restrictions where applicable

Using EPC recommendation tables

EPC recommendation tables show the cumulative effect of each measure on the rating. This helps you plan the minimum set of works needed to reach band E or better.

How to use the tables:

1. Identify your current rating and score
2. Review each recommended measure and its projected impact
3. Calculate which combination of works will cross the E threshold
4. Compare costs against the £3,500 cap

“Relevant” measures for MEES purposes are those that are technically suitable and cost no more than the applicable threshold. If you’ve installed all relevant improvements and the rating still falls below E, you may qualify for the “all relevant improvements made” exemption.

Hypothetical example:

Measure	Estimated Cost	Rating Impact
Loft insulation (300mm)	£500	F to E-
Cavity wall insulation	£800	E- to E
Condensing boiler	£2,000	E to D

In this scenario, the first two measures (£1,300 total) achieve EPC E. The boiler upgrade is beneficial but not required for minimum compliance.

MEES exemptions and how to register them

Exemptions allow landlords to legally let a sub-standard (F or G) property in defined circumstances, but only once the exemption is properly recorded on the PRS Exemptions Register.

Key facts about exemptions:

• Most exemptions last 5 years and must be renewed or reassessed at expiry
• Exemptions attach to the landlord and property combination—a change of landlord typically requires re-registration
• Exemptions should not be used to avoid reasonable works; you must demonstrate why improvements cannot be made within the rules

Main exemption categories:

Exemption Type	Typical Duration	Key Requirement
All relevant improvements made	5 years	All qualifying measures installed up to cost cap
High cost	5 years	Cheapest improvement exceeds cost cap
Wall insulation	5 years	Expert confirms wall insulation would cause damage
Third-party consent	Varies	Consent refused or unobtainable
Property devaluation	5 years	Improvement would reduce value by >5%
New landlord temporary	6 months	Recently acquired property

All relevant improvements made and high-cost exemptions

The “all relevant improvements made” exemption applies where you’ve installed all qualifying measures up to the domestic cost cap (or met non-domestic cost-effectiveness rules), but the EPC remains below E.

The “high cost” exemption applies where the cheapest relevant improvement would itself exceed the £3,500 domestic cap, making any improvement uneconomic under MEES.

Evidence required:

• Invoices from accredited installers
• Quotes showing improvement costs
• EPC or Green Deal assessment reports
• Calculations demonstrating costs relative to the cap

Both exemptions generally last 5 years. At expiry, landlords must reassess the property—considering any new funding opportunities or technology changes—and either improve the property or renew the exemption with updated evidence.

Wall insulation exemption

This exemption applies where the only relevant improvements identified are wall insulation measures (cavity or solid wall), and a suitable expert has advised in writing that such works would damage the property’s structure or fabric.

Evidence requirements:

• Written report from a suitably qualified professional (chartered surveyor or structural engineer)
• Detailed reasons why the work would be inappropriate
• Specific reference to the property’s construction and condition

Example: An older solid-wall Victorian terrace where internal insulation would cause damp problems and external insulation would unacceptably alter the street-facing facade. A surveyor’s report confirms both options would harm the building.

Like other long-term exemptions, wall insulation exemptions typically last 5 years and must be reviewed at expiry.

Third-party consent exemption

Some improvements require consent from other parties before work can proceed:

• Sitting tenants (for internal works)
• Freeholders or superior landlords
• Mortgage lenders
• Planning authorities

If consent is refused, granted only on unreasonable conditions, or simply unobtainable after reasonable attempts, you may register a third-party consent exemption.

Typical evidence required:

• Copies of correspondence showing consent requests
• Formal refusal letters
• Conditions that make work impracticable
• Evidence of reasonable attempts to obtain consent

The duration generally aligns with the period for which consent is refused. For example, if a tenant withholds consent, the exemption may last until the tenancy ends. When circumstances change, landlords must re-check consent possibilities.

Property devaluation exemption

This exemption applies if a qualified independent surveyor certifies that installing a specified improvement would reduce the market value of the property by more than 5%.

Requirements:

• Surveyor must be suitably accredited and independent
• Recent and relevant experience valuing that property type and area
• Report must specify works considered, valuation impact, and methodology used

The exemption usually lasts 5 years and must be reassessed when it expires or when market conditions change significantly.

Temporary exemption for new landlords

In limited circumstances, new landlords can register a 6-month temporary exemption. This applies when you:

• Inherit a property
• Purchase a property with sitting tenants
• Become a landlord through a court order

Basic evidence to record:

• Date you became responsible for the property
• Documents showing how the property was acquired
• Current EPC rating

This short-term exemption gives you time to assess the property, obtain an EPC if needed, and plan improvement works. Once the 6 months end, you must either have improved the property to at least EPC E or registered an appropriate longer-term exemption.

How to register an exemption on the PRS Exemptions Register

All MEES exemptions must be recorded on the official Private Rented Sector (PRS) Exemptions Register via the government’s online portal.

Registration process:

1. Create an account on the government portal
2. Select the relevant property by address
3. Choose the correct exemption category
4. Upload supporting documents
5. Review and confirm submission

Once submitted, exemption data generally cannot be edited. Double-check all details before confirming.

Exemptions usually take effect immediately upon registration. Keep confirmation emails and reference numbers for your records.

Exemptions can be cancelled if the property is later improved to meet the required EPC rating or if it ceases to be let.

Assisted digital support

Landlords who cannot use the online service can usually access assisted digital support through government helplines or designated email contacts.

Support staff can guide you through the mechanics of the online form but cannot give legal advice or decide whether you qualify for a specific exemption. You remain responsible for compliance decisions.

Enforcement, penalties, and appeals

Local authorities are responsible for enforcing MEES, using compliance checks, information notices, and financial penalties where necessary. Since the key dates passed (April 2018 for new lets, April 2020 for existing domestic tenancies, and April 2023 for commercial), authorities can act against landlords who let sub-standard properties without valid exemptions.

Typical enforcement tools:

• Compliance notices requiring information about the property, tenancy, and EPC
• Penalty notices for confirmed breaches
• Publication of landlord details on public registers

Financial penalty ranges:

Property Type	First Breach	Repeat/Serious Breach
Domestic	Up to £5,000	Higher penalties possible
Commercial	Up to £50,000	Up to £150,000

Landlords generally have rights of review and appeal if they dispute a penalty, including internal review by the authority and appeals to the First-tier Tribunal.

Non-compliance and compliance notices

Examples of non-compliance include:

• Letting a property with EPC F or G without a registered exemption
• Continuing to let after an exemption expires without renewal
• Failing to provide required information when requested

Local authorities can serve compliance notices asking for:

• Current and historic EPCs
• Tenancy documents
• Evidence of improvement works
• Exemption registration details

Compliance notices can generally be issued for up to 12 months after the suspected breach. Landlords must respond within the stated timeframe—typically 28 days.

Early engagement and clear records can often prevent escalation to formal penalties. Maintain organised files of all MEES-related documents.

Penalties and publication

If a breach is confirmed, local authorities may issue financial penalties and publish details of non-compliance on a public register for at least 12 months.

Factors affecting penalty levels:

• Length of the breach
• Whether it’s a repeat offence
• Whether false or misleading information was provided
• Landlord’s cooperation during investigation

Penalty notices can be served up to 18 months after the date of the breach, giving authorities time to investigate historic non-compliance. Exact penalty bands and thresholds appear in current government guidance.

Right of review and appeal

On receiving a penalty notice, landlords normally have a right to request that the issuing authority reviews its decision. The request must typically be made within 28 days.

Following review, the authority may:

• Confirm the original penalty
• Vary the penalty amount
• Withdraw the penalty entirely

The authority must notify you of its decision with reasons.

If you disagree with the reviewed decision, you may appeal to the First-tier Tribunal (General Regulatory Chamber). The tribunal can consider both the lawfulness and proportionality of the penalty.

Seek independent legal advice where significant sums are involved or facts are complex.

Long-term strategy and next steps for landlords and investors

MEES is part of a broader shift towards higher energy performance standards aligned with the UK’s sustainability goals and net zero targets. The current minimum energy efficiency threshold of EPC E is widely expected to increase to EPC C for domestic properties by 2030, with commercial standards following suit.

Strategic actions to consider:

• Conduct portfolio-wide EPC audits to identify current ratings and improvement needs
• Prioritise upgrades for worst-performing and highest-risk assets (F and G rated properties first)
• Integrate MEES planning into refurbishment cycles and lease events
• Factor improvement costs into acquisition due diligence
• Monitor policy announcements for final confirmation of future thresholds

Commercial opportunities from early action:

• Improved tenant demand—energy efficient properties are increasingly sought by occupiers
• Higher asset values—properties meeting future standards avoid obsolescence risk
• Reduced running costs—benefiting both landlords (void periods) and tenants (bills)
• ESG alignment—meeting corporate sustainability commitments for commercial tenants
• Access to green finance—favourable lending terms for efficient buildings

Government estimates suggest achieving EPC C across the private rented sector could deliver £1 billion in annual energy bill savings by 2030, alongside 10-15% CO2 emission reductions from rentals. Tenants in improved properties can expect annual bill reductions of £200-400.

Your next steps:

1. Review all current EPCs across your portfolio using the official register
2. Identify any F or G rated properties requiring immediate action
3. Obtain updated EPCs for certificates approaching expiry
4. Create a clear improvement or exemption plan for each property
5. Budget for phased upgrades well before enforcement deadlines
6. Consider professional energy efficiency advice for complex or listed buildings

The regulations will continue to evolve. Landlords who demonstrate proactive compliance and plan for higher standards will be best positioned to manage risk, maintain lettability, and achieve sustainable returns from their property investments.