Published on:

29 April 2025

Updated on:

11 September 2025

Read time:

Karl Carty

Design Director

Sajid Fiaz

Compliance Manager

With the UK's ambitious Net Zero targets driving significant regulatory changes, commercial property landlords face a rapidly evolving compliance landscape.

While our previous guide to EPC for commercial property covered the fundamentals of Energy Performance Certificates (EPCs), this article focuses specifically on recent calculation changes and upcoming regulatory shifts that directly impact your commercial property portfolio.

Recent and proposed changes to EPC calculations

The methodology underpinning EPC assessments continues to evolve as the UK moves toward its Net Zero targets. It's important for landlords to understand both implemented changes and proposed revisions that could affect their compliance strategy.

Current assessment methodology

The most recent significant update to the EPC requirement for commercial property came with the introduction of SBEM (Simplified Building Energy Model) version 6.1, which forms the basis of current assessments.

This methodology:

  • Places greater emphasis on actual energy consumption data rather than theoretical performance
  • Provides more detailed assessment of building services and controls
  • Incorporates updated carbon factors that reflect the UK's increasingly renewable electricity grid

Proposed calculation updates

The Department for Energy Security and Net Zero has proposed several additional methodology changes that, while not yet implemented, signal the direction of future requirements:

  • Low-carbon heating systems: Properties with heat pumps and other renewable heating solutions are expected to receive more favourable treatment in future calculations
  • Gas heating: Conventional gas boilers may face stricter assessment under proposed changes to align with carbon reduction goals
  • Advanced lighting systems: Greater differentiation between lighting technologies, with LED and smart control systems receiving preferential scoring

It's widely understood within the industry that these proposed methodology changes are designed to shift focus from pure energy costs toward actual carbon emissions, better aligning the assessment process with the UK's Net Zero ambitions.

These proposed changes mean landlords should be proactive rather than reactive when it comes to EPC assessments. What might be compliant today could fall short tomorrow without any physical changes to the building.

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Immediate actions to meet EPC requirements for commercial property

1. Reassess your EPC with accurate data

Generic assessments using default values rather than building-specific data typically produce lower ratings. Commissioning a detailed assessment with comprehensive building information can significantly improve your rating:

  • Provide detailed technical specifications for all heating and cooling systems
  • Supply accurate lighting specifications, particularly if LED upgrades have been completed
  • Ensure assessors have access to all building management system information

2. Review heating systems

Current and proposed changes to EPC methodology are shifting how heating systems are evaluated:

  • Recent updates to carbon factors in calculations already provide some advantage to electric heating solutions
  • Industry experts anticipate that properties with gas boilers may face limitations in achievable ratings in future assessment updates
  • Considering low-carbon alternatives now can provide long-term compliance benefits
  • Hybrid systems that combine traditional and renewable technologies offer a practical transition pathway

3. Check EPC expiry dates

EPCs issued before the 2022 methodology changes may present an inaccurate compliance picture:

  • Pre-2022 certificates may overstate your property's current performance
  • Properties approaching the 10-year renewal point should prioritise reassessment
  • Strategic early renewal can help identify compliance issues before they trigger penalties

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Future EPC requirements for commercial property

Beyond the current minimum EPC standard of 'E', the UK Government continues to develop its framework for progressively stricter requirements. While the originally proposed targets (Band C by 2027 and Band B by 2030) have been outlined in our ultimate guide to EPC for commercial property, recent policy developments suggest potential adjustments to the implementation timeline.

What remains clear is the direction of travel toward increasingly stringent energy efficiency standards, with a growing focus on performance-based metrics including actual energy use measurements and operational carbon emissions rather than just theoretical ratings.

Proactive commercial EPC management: beyond compliance

Forward-thinking landlords recognise that EPC performance extends beyond regulatory requirements:

  • Tenant expectations increasingly favour energy-efficient spaces
  • Financing terms often reflect EPC performance, with preferential rates for higher-rated properties
  • Future marketability depends increasingly on demonstrated sustainability credentials

Leveraging BIM for enhanced commercial EPC

Building Information Modelling (BIM) has emerged as a powerful tool for commercial property owners seeking to improve their EPC ratings. This digital representation of a building's physical and functional characteristics offers several advantages:

  • Data-rich assessments: BIM provides accurate building specifications that can significantly improve EPC assessment accuracy compared to default values
  • Energy performance simulation: Advanced BIM tools can model energy consumption under different scenarios, helping identify the most effective improvement measures
  • Retrofit planning: BIM enables detailed planning of energy efficiency upgrades with minimal disruption to tenants
  • Lifecycle management: The model can track implemented changes and predict maintenance requirements, supporting ongoing compliance

BIM enables property owners to model various improvement scenarios digitally before implementation, potentially leading to more cost-effective retrofit strategies than traditional approaches.

For landlords managing multiple properties, BIM provides a centralised system for monitoring compliance status across the portfolio, with the ability to prioritise improvements based on regulatory deadlines and projected costs.

BIM transforms EPC compliance from a reactive exercise into a proactive strategy. By creating a comprehensive digital twin of your property, you can test various improvement scenarios before committing capital, ensuring maximum return on investment while meeting regulatory requirements.

Karl Carty, Design Director

Understanding exemptions to EPC requirements for commercial property

Not all properties will be able to meet the new minimum standards, and while the exact details of future exemption pathways are still subject to final confirmation, the current regulatory framework suggests they may include:

Commercial viability exemption applies when improvements:

  • Cannot be funded through available government schemes
  • Would not pay for themselves through energy savings within seven years
  • Would decrease property value by more than 5%

Technical feasibility exemption covers situations where:

  • Structural limitations prevent improvements
  • Planning restrictions (particularly for listed buildings) block necessary changes
  • Third-party consents cannot be obtained despite reasonable efforts

Cost cap exemption provides financial protection:

  • Current regulations include a £3,500 (including VAT) cost cap for minimum EPC E requirements
  • If improvements to reach EPC E would exceed this cap, landlords should make all possible improvements up to that amount
  • An 'all improvements made' exemption can then be registered
  • Future cost caps for higher rating requirements (C and B) have not yet been confirmed

The exemption process remains somewhat opaque, with uncertainty around evidence requirements and approval timelines. We recommend viewing exemptions as a last resort rather than a primary strategy.

Matthew Edis, Founding Director at SCS

Taking action

The progressive tightening of minimum EPC standards demands strategic planning:

  1. Assess your current position by reviewing existing EPCs and commissioning new assessments where needed
  2. Identify improvement pathways that align with upcoming regulatory stages
  3. Develop a phased implementation plan prioritising high-impact, cost-effective measures
  4. Consider wider landlord refurbishment opportunities that can incorporate energy improvements

Staying ahead of EPC requirements for commercial property isn't just about compliance it's about creating resilient, future-proof assets that attract quality tenants and maintain their value.

With proper planning and expert implementation, energy efficiency improvements can deliver substantial returns while contributing to broader sustainability goals. For expert guidance on navigating EPC requirements for your commercial property, contact OP today.

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Meet the Authors

A seasoned designer with a people-centric, multidisciplinary approach to concept design. He excels in uncovering a company’s essence, valuing each stage of the design process to cultivate a business culture that fuels development.

With a deep understanding of regulatory requirements and a passion for environmental stewardship, Sajid ensures the company's operations align with legal standards and sustainability goals. His expertise in developing and implementing compliance programs and sustainable practices has significantly enhanced our ethical standing and environmental performance. Sajid's ability to balance regulatory demands with business objectives contributes to the company's reputation as a responsible and forward-thinking industry leader.