Minimum Energy Efficiency Standards (MEES)

If you’re a landlord in England and Wales, minimum energy efficiency standards are no longer optional—they’re the law. MEES regulations set a legal floor for how energy efficient your rental properties must be before you can let them to tenants. Get it wrong, and you’re looking at penalties of up to £5,000 per domestic property.

This guide walks you through everything you need to know: which properties are covered, current EPC thresholds, the cost cap, funding options, exemptions, penalties, and what’s coming next. Consider this practical guidance for landlords and agents—not legal advice. Always check the latest government guidance before acting.

Minimum Energy Efficiency Standards (MEES): Quick Overview for Landlords

Minimum energy efficiency standards MEES are regulations that prevent landlords from letting properties with the lowest energy performance certificate ratings. The rules apply to most private rented property in England and Wales, covering both domestic and commercial sectors.

Since 1 April 2020, it has been unlawful to let most domestic private rented properties with an EPC rating of F or G without a valid exemption. This applies whether you’re granting a new tenancy or simply continuing an existing one.

Similar minimum standards apply to non-domestic (commercial) property. The current minimum is EPC E, with government proposals to tighten this to EPC B in the early 2030s.

MEES regulations sit alongside the Energy Performance of Buildings Regulations and form a key part of the UK’s net zero strategy. They’re designed to push the worst-performing rental properties out of the market—or force their improvement.

What this article covers:

• Which properties are caught by MEES
• Current EPC thresholds and key dates
• The domestic £3,500 cost cap
• Funding improvements and third-party funding options
• Available exemptions and how to register them
• Enforcement powers and potential penalties
• Proposed changes for domestic and commercial MEES

Is Your Property Covered by the MEES Regulations?

MEES apply to private rented property in England and Wales that is legally required to have an EPC under the Energy Performance of Buildings Regulations. Understanding whether your property falls within scope is the first step to compliance.

An energy performance certificate is generally required when a property is sold, let, or has undergone significant works. EPCs are valid for 10 years from the date of issue.

Domestic properties covered:

• Assured shorthold tenancies (ASTs)
• Assured tenancies under the Housing Act 1988
• Regulated tenancies
• Domestic agricultural tenancies under the Agricultural Holdings Act 1986

Typical domestic exclusions:

• Certain listed buildings where an EPC is not required
• Very short lets (less than 6 months with no right of renewal)
• Very long leases (99 years or more)
• Properties let under a licence to occupy rather than a tenancy

Commercial properties covered:

• Most leased offices, shops, industrial units and other non-domestic premises with an EPC
• Exceptions apply where specific exemptions from EPCs exist (such as certain places of worship or temporary buildings)

MEES currently do not extend to Scotland, which operates a separate regime for energy efficiency in rented properties. Northern Ireland has its own EPC rules and enforcement framework.

Questions to Check Whether Your Domestic Property Is in Scope

Before diving into compliance requirements, run through this checklist to determine whether MEES apply to your property:

1. Is the property in England or Wales? MEES only apply in these jurisdictions.
2. Is the property let (or intended to be let) on a domestic tenancy? This includes ASTs, regulated tenancies, assured tenancies, and domestic agricultural tenancies.
3. Has the property been marketed for sale or rent, or significantly modified, in the last 10 years? If yes, there should be a legal requirement for an EPC.
4. Does the property have a current, valid EPC? Check the online EPC Register at gov.uk to find the rating.
5. What is the EPC rating? Ratings run from A (most efficient) to G (least efficient).

If your property is domestic private rented and required to have an EPC, and that EPC shows a rating of F or G, the property is a “sub-standard property” under MEES. Additional rules apply, and you cannot lawfully let it without either improving the rating or registering an exemption.

If no EPC is legally required (and one has not been voluntarily obtained), MEES do not currently apply. However, this may change as policy evolves and enforcement tightens.

Current Minimum EPC Thresholds and Key MEES Dates

Understanding the timeline of MEES regulations helps you identify when compliance obligations kicked in—and what’s coming next.

Domestic MEES timeline:

Date	Requirement
1 April 2018	New domestic tenancies cannot be granted for F and G properties without a valid exemption
1 April 2020	Prohibition extends to existing tenancies; most F and G domestic properties must be improved to EPC E or have an exemption registered

Commercial MEES timeline:

Date	Requirement
1 April 2018	Most new commercial leases cannot be granted for sub-standard (F or G) properties
1 April 2023	Continuing to let an in-scope commercial property with EPC F or G is unlawful without an exemption

What’s expected next:

• Government ambitions to raise domestic minimum standards to EPC C by 2030
• Proposals to raise commercial MEES to EPC B after 2030 but before 2035
• New EPC methodology expected in late 2026, likely affecting gas-heated properties significantly

Plan on the basis that minimum EPC requirements are tightening over the 2020s and early 2030s, even if exact dates remain under consultation. Waiting until deadlines hit is a risky strategy.

When You Must Upgrade a Domestic Property to at Least EPC Band E

Since 1 April 2020, it has been unlawful to let or continue to let most domestic private rented property with an EPC rating of F or G in England and Wales, unless a valid exemption is registered.

Key scenarios requiring compliance:

• Granting a new tenancy: Before letting to a new tenant, ensure the EPC shows band E or above, or register an exemption on the PRS exemptions register.
• Renewing or extending a tenancy: The same requirement applies—check the rating and address any issues before the new term begins.
• Continuing an existing tenancy: Even without a change of tenant, landlords must ensure properties remain compliant throughout the tenancy period.
• Property remains empty: Genuinely vacant properties not currently let are not required to be upgraded immediately. However, MEES will bite at the point they are next let or re-let.

Encourage yourself to check upcoming lease events and voids now. Addressing energy efficiency improvements during natural gaps in occupancy is far easier than retrofitting around an existing tenant.

Funding Improvements and the £3,500 (incl. VAT) Domestic Cost Cap

MEES regulations include a spending cap to prevent disproportionate compliance burdens on domestic landlords. Understanding how this cost cap works is essential for planning improvements.

For domestic private rented property in England and Wales, the cost of energy efficiency improvements required to meet EPC E is capped at £3,500 (including VAT) per property.

How the cap works:

• If EPC recommendations suggest measures that would bring the property to band E for less than £3,500, spend only what is necessary to reach E—not the full cap.
• If bringing the property up to E would cost more than £3,500, you must install all “relevant energy efficiency improvements” possible within that cap. You may then be able to rely on the “all improvements made” exemption.
• Costs of qualifying works undertaken on or after 1 October 2017 can usually be counted towards the £3,500 cap, provided you retain sufficient evidence (quotes, invoices, receipts).

The domestic cost cap does not apply in the same way to commercial properties. Non-domestic MEES focus on cost-effectiveness and reasonable payback periods rather than a fixed monetary ceiling.

Third-Party Funding Options

You don’t necessarily have to fund improvements entirely from your own pocket. Third-party funding can significantly offset compliance costs.

Available funding routes may include:

• Government energy efficiency schemes (availability varies by region and time)
• Local authority grants for landlords
• Energy supplier obligations (ECO schemes)
• Green finance products and loans

Where third party funding is available, you must fully utilise it to improve the property to at least EPC E (or higher where feasible) before relying on the cost cap.

For the purpose of the £3,500 cap, both landlord contributions and any third-party funding count towards the total spend on improvements.

Check current national and local schemes regularly—available support changes over time and may differ between regions and property types. What was available last year may have closed, and new schemes may have opened.

Combining Third-Party Funding with Your Own Funds

Mixed funding scenarios are common, and understanding how they interact with the cost cap matters for compliance.

• Where party funding does not fully cover works needed to reach EPC E, you can top up with your own funding up to the £3,500 (including VAT) cost cap.
• The combined total of grants, subsidies and landlord contributions must not exceed £3,500—unless you choose to go beyond minimum requirements voluntarily.
• If, after using all available funding and spending up to the cap, the property still cannot reach EPC E, you may be able to rely on the “all relevant improvements made” exemption.
• Keep meticulous records: quotes, invoices, grant award letters, and bank statements. This evidence is essential if enforcement action arises and you need to demonstrate total spend.

Self-Funding Domestic Improvements

Where no third-party funding is available, domestic landlords are expected to self-fund relevant energy efficiency improvements up to the £3,500 cap using their own funding.

Self-funding scenarios:

• If the property can be upgraded to EPC E for less than £3,500, spend only the amount required to reach E.
• If the cheapest package of relevant improvements to achieve E would cost more than £3,500, spend up to the cap on recommended measures and then consider registering an exemption.
• Prioritise measures with the best EPC impact within budget. These are typically highlighted at the top of the EPC recommendation report—often loft insulation, heating controls, or efficient lighting.

Choosing and Installing Energy Efficiency Measures

The EPC is your starting point for selecting which improvements to make. Every EPC includes a recommendation report listing potential upgrades and their expected impact on the property’s rating.

Common recommended measures include:

• Loft insulation
• Cavity wall insulation or solid wall insulation
• Efficient boilers and heating controls
• Double or triple glazing
• Low-energy lighting
• Solar photovoltaic panels

Focus first on “relevant energy efficiency improvements”—those that are cost effective and technically suitable for the property. Not every measure will be appropriate for every building.

Where the EPC recommendations aren’t detailed enough, consider commissioning additional reports. A Green Deal Advice Report or specialist survey can help design a package of works tailored to your property.

Installation considerations:

• Use competent, appropriately accredited contractors to ensure performance, safety and eligibility for funding
• Check whether works require planning permission or building regulations approval
• Once works are complete, commission a new EPC to confirm the updated rating for MEES compliance and marketing purposes

Using the EPC Recommendation Table

EPC recommendations are usually presented in a table format that makes prioritisation straightforward.

Typical information shown:

Column	What It Tells You
Measure	The specific improvement (e.g., cavity wall insulation)
Estimated cost range	Typical installation cost (e.g., £500–£1,500)
Typical annual savings	Expected reduction in energy bills
Impact on EPC rating	Potential rating improvement (e.g., from F to D)

The measures are often cumulative—the biggest gains are achieved when you install them in the order suggested.

“Relevant energy efficiency improvements” for MEES purposes are typically those that:

• Appear in the EPC recommendation report
• Are technically feasible for the property
• Cost £3,500 or less in total (for domestic MEES)

If all relevant energy efficiency measures have been installed and the EPC rating is still F or G, you may be entitled to register an “all improvements made” exemption.

Domestic MEES Exemptions and How They Work

Exemptions allow letting below EPC E in limited, tightly defined circumstances. They exist to address situations where improvements are genuinely impossible, unaffordable, or would cause harm.

Key principles:

• Exemptions must be registered on the Private Rented Sector (PRS) Exemptions Register before a sub-standard property is lawfully let
• Most domestic MEES exemptions last for 5 years
• Exemptions are generally linked to the landlord, not the property—if the property is sold, the new owner must reassess and re-register any exemption
• Letting an F or G rated property without a valid, registered exemption is a breach of MEES and can lead to enforcement action and civil penalties

The main domestic exemption categories are:

1. All improvements made
2. High cost exemption
3. Wall insulation exemption
4. Third-party consent
5. Property devaluation
6. Temporary exemption for new landlords

“All Relevant Improvements Made” and “High Cost” Exemptions

These two exemptions address situations where compliance isn’t economically feasible despite good-faith efforts.

All relevant improvements made exemption:

• Applies where you have installed all relevant energy efficiency improvements up to the £3,500 cap, but the property remains below EPC E
• Requires evidence of works carried out, costs incurred, and the updated EPC showing F or G
• Lasts for 5 years, after which you must reassess options and consider whether new measures or technologies have become available

High cost exemption:

• Applies where the cheapest recommended measure needed to raise the EPC to E would itself cost more than £3,500 (including VAT)
• Requires at least one contractor quote—preferably more—showing that no single relevant improvement can be carried out within the cost cap
• Also lasts for 5 years and must be supported by detailed documentation uploaded to the PRS exemptions register

Remember: exemptions should not be used to avoid improvements that are genuinely affordable and technically feasible. Enforcement officers may scrutinise exemption claims.

Wall Insulation, Consent and Devaluation Exemptions

These specialist exemptions address specific technical or practical barriers to improvement.

Wall insulation exemption:

• Relevant where cavity, external or internal wall insulation is the only improvement measure recommended
• Can be used if a relevant expert has advised in writing that the recommended wall insulation measure would have a negative impact on the property’s structure or fabric, or is not technically appropriate
• A written opinion from a suitably qualified professional (such as a chartered surveyor or structural engineer) must be uploaded when registering the exemption type

Third-party consent exemption:

• Available where required consents (from tenants, freeholders, superior landlords, mortgage lenders, or planning authorities) cannot be obtained, or are granted subject to unreasonable conditions
• Duration depends on the nature of the consent issue; once circumstances change, the landlord must revisit improvements
• Requires evidence that you made genuine attempts to obtain consent—upload relevant correspondence and refusal letters

Property devaluation exemption:

• Applies where a suitably qualified independent surveyor confirms in writing that installing a recommended measure would reduce the market value of the property by more than 5%
• Requires a formal valuation report setting out methodology and conclusion
• Lasts for 5 years, after which you must reassess whether the measure is still value-damaging given changed market conditions

Temporary Exemption for New Landlords

A time-limited, 6-month temporary exemption is available for certain categories of “new landlord.”

Qualifying circumstances include:

• A landlord has recently inherited a property with an existing tenancy
• A lender has become the landlord after enforcing security
• A purchaser unexpectedly becomes bound by a tenancy

The 6-month period runs from the date the person becomes the landlord. During this time, they must either bring the property up to EPC E or register an exemption applies to their situation.

This exemption is not automatic—it must be registered on the PRS Exemptions Register with evidence showing how and when the landlord acquired the property.

How to Register a Domestic MEES Exemption

Exemptions are registered online via the PRS Exemptions Register using the government portal. You’ll need a GOV.UK account to access the service.

Information typically required:

• Address of the property
• Type of exemption claimed
• Copy of the current valid EPC
• Supporting evidence: measures installed, quotes, expert reports, or consent correspondence as appropriate

Practical tips:

• Check all information for accuracy before confirming—once an exemption is submitted, the data cannot normally be altered
• Exemptions become effective immediately on registration
• You can cancel an exemption later if the property is improved to EPC E or above, or ceases to be rented
• Assisted digital support is available via government helplines for landlords who have difficulty using online services, but this support does not extend to giving legal advice

For more detail on the registration process, consult the official government guidance on the PRS Exemptions Register.

Enforcement of MEES and Potential Penalties

Local authority trading standards teams are the main enforcement bodies for domestic MEES in England and Wales. They work alongside housing and environmental health officers in some areas.

How enforcement works:

• Authorities may use EPC data, PRS Exemptions Register records, and tenancy information to identify properties covered that appear non-compliant
• Properties showing F or G ratings with no registered exemption are likely targets for investigation
• Suspected non compliance can lead to compliance notices, requests for information, and potential civil penalty notices

Potential penalties for domestic properties:

Breach Type	Maximum Penalty
Letting a property in breach for less than 3 months	£2,000
Letting a property in breach for 3 months or more	£4,000
Providing false or misleading information	£1,000
Maximum total per property	£5,000

Authorities can also “name and shame” landlords by publishing details of confirmed breaches on a publicly accessible register for at least 12 months.

Compliance Notices, Penalties and Appeals

Understanding the typical enforcement process helps you respond appropriately if you’re investigated.

Stage 1: Compliance notice

A local authority will usually issue a compliance notice first, requiring you to supply documents such as:

• The current EPC
• Tenancy agreement
• Evidence of improvements or exemptions

Compliance notices can generally be served up to 12 months after the suspected breach. You must respond within the deadline given—typically 28 days.

Stage 2: Penalty notice

If the authority concludes a breach has occurred, it may issue a penalty notice including:

• A financial penalty
• A publication penalty (publicising the breach)
• Or both

Penalty notices can be served up to 18 months after the date of the breach. The notice will explain how to pay, how to seek a review, and how to appeal.

Stage 3: Review and appeal

You have the right to ask the enforcing authority to review the penalty. If still dissatisfied, you can appeal to the First-tier Tribunal, which can confirm, vary or cancel the penalty.

Seeking independent legal advice is recommended if you receive a penalty notice and wish to challenge it.

Commercial MEES: Where We Are Now and What May Change

Commercial minimum energy efficiency standards follow a similar structure to domestic MEES but with different thresholds and a separate trajectory for tightening.

Current position:

For non-domestic private rented property in England and Wales, it is currently unlawful to:

• Grant a new lease for a property with an EPC rating of F or G without an exemption (since April 2018)
• Continue to let such a property (since April 2023)

Future proposals:

• Government is expected to increase the commercial minimum to EPC B for most rented non-domestic buildings
• The deadline is anticipated between 2031 and 2035, subject to final government decisions
• Evidence from the Climate Change Committee’s seventh carbon budget suggests the commercial sector must cut emissions sharply by 2040
• Improving energy efficiency and installing low-carbon heating are central to achieving these targets

The government has consulted on how and when to implement stricter MEES for commercial property. Further announcements are expected following energy security reviews in 2024–2025.

Commercial landlords and investors should model their portfolios now against prospective EPC B requirements, identify high-risk assets, and plan phased retrofit programmes.

Implications for Commercial Landlords and Tenants

Raising commercial MEES to EPC B will have significant practical and strategic impacts across the sector.

What to expect:

• A significant proportion of existing commercial stock will become “sub-standard” unless upgraded—particularly older offices, retail units and industrial premises
• Many leases now include “green clauses” or MEES-specific provisions allocating responsibility for obtaining EPCs, carrying out works, and sharing data
• Landlords will need robust EPC data, building surveys and costed retrofit plans to manage compliance risk and avoid stranded assets

Exemptions in the commercial context:

• Some buildings may qualify for cost-effectiveness exemptions where measures fail to meet defined payback tests
• These exemptions are expected to be narrowly framed and evidence-heavy
• Commercial exemptions require different evidence than domestic exemptions—consult specialist guidance

Collaboration is essential:

Both landlords and tenants should engage early on compliance planning. Access requirements, service charge constraints and operational disruptions can all affect the timing and feasibility of major energy upgrades. Waiting until a lease renewal to address energy efficiency often means rushed, expensive solutions.

Planning Ahead for Future MEES Tightening

MEES regulations aren’t standing still. Treating EPC E as your long-term target is a mistake—future-proof your portfolio by aiming higher now.

Recommended actions:

• Audit your portfolio: Review EPC ratings and expiry dates across all properties
• Identify vulnerable assets: Flag F and G properties as immediate priorities, but also assess D and E properties that may become sub-standard as standards tighten
• Time improvements strategically: Prioritise works where tenancy events or refurbishments are already planned
• Build MEES into decisions: Factor compliance costs into acquisition due diligence, refinancing decisions and long-term capital expenditure planning

Stay informed:

Official guidance is periodically updated. Check current DESNZ (Department for Energy Security and Net Zero) publications for the latest position. Seek independent legal and technical advice where needed—particularly for complex portfolios or unusual exemption scenarios.

The bottom line:

Early, proactive action on energy efficiency tends to be cheaper, less disruptive, and more aligned with tenants’ increasing expectations for sustainable buildings. Properties that meet higher standards today will be easier to let, more attractive to quality tenants, and better protected against regulatory risk.

Don’t wait for the next deadline to force your hand. Start with an EPC audit this month, identify your worst performers, and build a realistic improvement plan. Your portfolio—and your compliance record—will thank you for it.