Which landlords will act first on EPC B by 2031

Will, Founder of Locarum. 15 October 2026.

From 2031, rented commercial buildings in England and Wales over 1,000 m² are due to need an energy rating of B. If you sell lighting, heating controls or other energy upgrades, their landlords are your customers.

They won’t all act at once. Under today’s rules a landlord usually only has to act when a lease changes: a new tenant, a renewal or an empty floor being re-let. So the landlords to contact first are the ones with a lease about to change, and some of those change this year.

Most of what has been written about the rule is for landlords. This guide is for the people who sell to them. It shows how to find those buildings in free public records.

What the government has said

On 18 June 2026 the government said that from 2031 rented commercial buildings in England and Wales over 1,000 m² will need to reach energy band B where the work is cost effective. Smaller buildings stay at the current minimum of band E. The step to band C in 2027 has gone. None of this is law until Parliament passes the regulations, and the detail is still to come.

Commercial buildings over 1,000 m² are about 7% of the commercial buildings in England and Wales and use about 61% of their electricity and 70% of their gas.

Why the next lease matters more than 2031

Today’s rule only applies to a building with a valid energy certificate that the landlord was required to get. A certificate lasts ten years and a landlord only needs a new one when they let, re-let or sell. So a building on a long lease with an expired certificate isn’t caught until that lease ends, the space is re-let or sublet, or the building is refurbished. The government’s own guidance for landlords walks through these cases.

We don’t yet know whether 2031 will work the same way. If it does, landlords will meet the rule one lease at a time. The one with a floor going empty next spring has to decide next spring.

You can see those moments coming in public records. A new energy certificate lodged “to let” means space is being marketed. A unit going empty on the council’s business rates list, a new business paying the rates or a planning application to refurbish all point the same way.

How to read a certificate in five minutes

The free certificate search on GOV.UK tells you most of what you need, if you know where to look.

Start with the floor area, and look at every certificate at the address. A building let in parts usually has one for each part. A 3,000 m² office let floor by floor might have four certificates of 750 m² each. The government hasn’t said whether the 1,000 m² applies to the whole building or to each let part, and today’s rule uses the let part’s own certificate. I’d treat a building like that as possible until the detail is published.

Then look at the date and the heating together. The way certificates are worked out changed on 15 June 2022, when the carbon figure for grid electricity fell by about 73%. Since then a gas-heated building often comes out a band worse on a new certificate and an electrically heated one often comes out better. You can see it in the national figures. Of the commercial certificates lodged in 2021, 18% were B or better. By 2025 it was 43%. So a gas-heated building rated C in 2019 is probably a D today, and its landlord may not know.

Last, read the recommendation report that comes with the certificate. It sorts the assessor’s advice by how quickly each measure pays for itself: under three years, three to seven, and over seven. This is the most useful page for a seller, because “cost effective” in the rule has a precise meaning. A measure is cost effective if it saves more on energy in seven years than it costs to fit. A landlord who wants to skip one has to show it fails that test. If what you sell is in the first two groups, the landlord will find it hard to avoid. The report’s paybacks are estimates and the legal test uses real quotes, but it is the best free guide there is to what a landlord will be expected to do.

Two more checks before you get in touch

First, make sure the building is let. The rule is for rented buildings. If the business paying the rates is a different organisation from the owner on the Land Registry title, which costs £7, it almost certainly is.

Second, search the government’s exemptions register. It is free to search by address or by landlord name. A building on it may already have a registered reason not to do the work, and it is better to know that before the first email than after.

What it costs a landlord to do nothing

Letting a building in breach for three months or more can bring a fine of £10,000 or 20% of the building’s rateable value, whichever is greater, up to £150,000. The rateable value is on the business rates list, so you can put a figure on it for any building.

In my view the fine is the smaller cost. The larger one is a floor that can’t be let. A landlord with an empty floor and a tenant waiting has every reason to do the work now.

An example

This building is invented, but there are thousands like it.

It is a four-storey office of 2,400 m², let floor by floor, with a certificate for each floor of about 600 m². The newest, from 2019, rates it C. It is heated by gas. A property company owns it and a different firm pays the rates on each floor. In August the second floor went empty on the business rates list. The recommendation report puts LED lighting and better heating controls in the under three years group.

Each floor is under 1,000 m², so whether the building is caught depends on detail not yet published. Even so, the landlord needs a new certificate before the second floor can be let. Gas heating and a 2019 rating mean it will probably show D. If they want that floor let past 2031 they will probably need B, and lighting and controls are where they will start. Whoever sells those has a reason to write to the owner and their managing agent this month.

Scotland and Northern Ireland

Scotland has had its own rule since 2016. When a commercial building over 1,000 m² is sold or let the owner needs an assessment and an action plan, then either does the work or reports the building’s energy use each year. Northern Ireland has no minimum standard for commercial buildings.

See the signs as they happen

Lease end dates aren’t published but the signs of one ending are. Locarum shows them for every commercial building as they happen: a unit going empty, a new business paying the rates, a planning application, a new energy certificate or one about to run out. Each comes with its source and date.

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