Do Shops Need EPCs? Rules for Selling or Letting

A vacant shop can hold up a sale or new tenancy for something as straightforward as missing paperwork. So, do shops need EPCs? In most cases, yes: a shop needs a valid commercial Energy Performance Certificate when it is built, sold or let. There are exceptions, but they are narrower than many owners expect.

For shop owners, landlords and agents, the practical point is simple. Check whether a valid EPC exists before marketing the premises, rather than finding out when a buyer, tenant or solicitor asks for it. It keeps the transaction moving and gives everyone a clearer picture of the building’s energy performance.

Do shops need EPCs when sold or let?

A commercial EPC is normally required when a retail unit is constructed, put on the market for sale, or offered to let. It applies to shops on high streets, in shopping centres, retail parks and mixed-use buildings where the commercial unit is separately occupied or marketed.

The certificate gives the property an energy rating from A to G and is valid for 10 years, unless a new EPC is obtained sooner. It also includes recommendations that may help improve the building, although those recommendations are not automatically compulsory.

An EPC should be available early in the marketing process. Waiting until heads of terms have been agreed is not ideal. It can create avoidable questions around the rating, the likely cost of improvements and whether the premises can legally be let.

If a shop has been substantially altered since its last assessment, it is often sensible to arrange a fresh EPC even where a new one is not immediately triggered. A refit may have improved lighting, heating, insulation or glazing. Equally, removing efficient systems can affect the outcome. An up-to-date assessment gives a more useful reflection of the unit as it stands.

The difference between an EPC requirement and MEES

This is where the rules can become confusing. The requirement to have an EPC and the Minimum Energy Efficiency Standards, usually called MEES, are connected but not the same thing.

An EPC records the energy performance of the shop. MEES controls whether a privately rented commercial property can be let. In England and Wales, most non-domestic rented properties need an EPC rating of E or above, unless a valid exemption has been registered.

Since April 2023, the rules have applied not only when granting a new lease, but also to continuing commercial tenancies. That means a landlord cannot simply rely on an old arrangement if a shop has an F or G rating. The position needs attention, even if the tenant has occupied the premises for years.

There are exemptions, and the detail matters. A landlord may be able to register an exemption where all relevant energy-efficiency improvements have been made and the property remains below an E, where works would reduce the building’s value by more than 5 per cent, or where tenant or third-party consent cannot be obtained. Exemptions are not automatic and must be properly evidenced and registered.

A low rating does not always mean a costly overhaul. In some shops, practical changes to heating controls, lighting, hot-water provision or draught reduction can make a meaningful difference. In others, especially older or unusual buildings, the options and likely rating need careful assessment before committing to works.

Which shops may be exempt from an EPC?

Not every retail building needs an EPC. However, an exemption should be checked against the individual property rather than assumed because a shop is small, old or only used part-time.

Common situations that may be exempt include:

• a genuinely stand-alone building with a total useful floor area under 50 square metres

• a temporary building intended to be used for two years or less

• certain industrial sites, workshops or agricultural buildings with low energy demand

• a building due to be demolished, where the required conditions are met

• some listed or officially protected buildings, where EPC compliance would unacceptably alter their character or appearance

The stand-alone point catches people out. A small unit in a parade of shops, arcade or larger retail building is not normally stand-alone simply because it has its own front door. Likewise, listed status does not create a blanket EPC exemption. The question is whether meeting the minimum energy performance requirements would unacceptably alter the building’s character or appearance.

If there is any doubt, it is better to check before deciding not to commission an assessment. Getting the exemption wrong can delay a deal and may expose the responsible party to enforcement action.

What type of EPC does a shop need?

Shops require a non-domestic, or commercial, EPC rather than the domestic EPC used for houses and flats. The assessor considers the building fabric and fixed services, such as heating, cooling, ventilation, lighting and hot water. Loose equipment, stock and a tenant’s plug-in appliances are not the focus of the assessment.

The appropriate assessment level depends on the size, layout and complexity of the premises. Many straightforward retail units can be assessed with a Level 3 Commercial EPC. Larger shops, premises with more complex heating or air-conditioning systems, or buildings with several zones may need a different level of assessment.

A shop forming part of a mixed-use property may need its own EPC where it is separately occupied or has separate heating and access arrangements. A flat above the shop is usually assessed separately as a dwelling. One certificate should not be assumed to cover both parts.

The site visit is usually straightforward. An accredited assessor will measure the premises and record construction details, glazing, heating, lighting, air conditioning where present, and the way the unit is arranged. Access to plant rooms, meters and any rear storage areas can help ensure the assessment is accurate.

Do public shops need a DEC as well?

A Display Energy Certificate, or DEC, is different again. It shows the actual energy use of a public building rather than a calculated energy rating.

A shop open to the public does not automatically need a DEC. The duty generally applies to public authorities occupying buildings with a total useful floor area over 250 square metres that are frequently visited by the public. For example, a council-run public service building may fall within the rules, while an ordinary private retailer does not simply because customers visit it.

Where the operator is a public body, it is worth checking both requirements. The building may need a DEC because of how it is occupied, while a commercial EPC may still be needed when it is sold or let.

A practical check before marketing a retail unit

Before advertising a shop, establish whether an EPC is already registered and still within its 10-year validity period. Check that it relates to the exact unit being marketed, particularly in a building that has been split, combined or reconfigured.

Then look at the rating. If the shop is rented, or will be rented, an F or G rating needs immediate attention because of MEES. Do not assume that a tenant’s occupation or a forthcoming lease renewal makes the issue disappear.

It also helps to gather basic information before the appointment: previous EPCs, plans if available, details of recent refurbishment, and access arrangements for heating equipment and back-of-house areas. This avoids repeat visits and helps produce a certificate that properly reflects the property.

For estate agents handling several units, arranging EPCs before launch is one of the simplest ways to avoid last-minute admin. A dependable assessor, fixed pricing and quick turnaround can make a real difference when a buyer or tenant is ready to proceed.

Getting clear advice for your shop

The answer to whether a shop needs an EPC is usually pretty simple: if it is being sold or let, assume it does until the property has been checked against the exemption rules. The more important question is whether its rating creates a letting issue under MEES.

For retail premises in Melton Mowbray, Leicester, Grantham, Peterborough or Loughborough, Kings Energy Hub can assess the property, explain the result in plain language and help you understand the next practical step. A quick check before marketing is usually far easier than trying to resolve an EPC issue halfway through a transaction.