Is an EPC Required for Commercial Property with No Heating

Energy Performance Certificates, commonly known as EPCs, have been a legal requirement for many properties in the UK for several years. They provide a rating that shows how energy efficient a building is and are designed to help prospective buyers or tenants understand the likely running costs of occupying the space. For commercial properties, the rules can sometimes feel complicated, particularly where the building does not have a fixed heating system. Property owners, landlords, and tenants often question whether an EPC is still required in these circumstances.

What an EPC is and why it matters

An EPC rates a property from A to G, with A being the most energy efficient. For commercial buildings, the certificate provides details on how the building is constructed, insulated, and serviced, as well as recommendations for improvements. The certificate is valid for ten years and is needed whenever a property is sold, let, or constructed. EPCs are an important part of the government’s strategy for reducing carbon emissions and encouraging energy efficiency across the built environment. Without a valid EPC, landlords can face penalties if they try to market a property.

The role of heating in EPC assessments

The presence of a fixed heating system plays a significant part in how the energy performance of a building is assessed. In most cases, an EPC takes into account the boiler or heating system, the controls, and the way heat is distributed throughout the property. Where no fixed heating system exists, assessors face the challenge of rating the building without one of its most influential energy factors. This does not automatically exempt the property from needing an EPC, but it may change how the building is assessed.

When an EPC is still required

If you are selling or letting a commercial property, an EPC is generally required regardless of whether there is a heating system. The assessment will be carried out using standardised assumptions, and the absence of heating will be factored into the rating. For example, if the property is a retail unit, warehouse, or office space without heating, the EPC will still provide a rating, although it may reflect the fact that no fixed system is installed. The law makes no blanket exemption for commercial properties simply because they lack heating.

Possible exemptions from EPC requirements

There are, however, certain exemptions under UK regulations where an EPC may not be required. Buildings that are due to be demolished, temporary structures in use for less than two years, and some industrial sites with low energy demand may not need a certificate. If a building does not use any energy to condition the indoor climate, such as a storage facility or basic workshop, an exemption may apply. That said, exemptions must be applied carefully, and in most cases the property owner should be prepared to prove why the exemption is valid if challenged by enforcement authorities.

Practical examples

Consider a vacant warehouse that has no fixed heating, cooling, or ventilation. In this scenario, an EPC may not be required if the space is purely for storage and no systems are intended to be installed. However, if the same warehouse is being let for office use, or if the new occupier plans to introduce heating and cooling systems, then an EPC would be necessary. Another example might be a retail unit where the landlord has stripped out the old heating before re-letting. Even if no new system is present, an EPC is still usually needed for marketing purposes, and the absence of heating will be reflected in the rating.

Responsibilities of landlords and sellers

Landlords and sellers of commercial property must take care to meet their obligations under the Energy Performance of Buildings Regulations. Failure to provide an EPC when required can result in fines ranging from a fixed minimum to a percentage of the property’s rateable value. Even where the building has no heating, the safest approach is to assume that an EPC is required unless a valid exemption clearly applies. Marketing a property without one can create delays, legal complications, and unnecessary costs.

Minimum Energy Efficiency Standards (MEES)

Since 2018, the Minimum Energy Efficiency Standards have applied to rented commercial property, requiring landlords to achieve at least an EPC rating of E before granting new tenancies. This has since been tightened further, with proposals for higher standards in the future. For properties without heating, this can become complex, as their rating may be low due to limited energy services. However, landlords cannot ignore the requirement simply because heating is absent. They must ensure that the certificate is obtained and that the property complies with the current rules if it is to be rented out.

Seeking professional advice

Because the rules around EPCs and exemptions can be confusing, particularly for commercial properties, it is often best to seek advice from an accredited energy assessor or solicitor specialising in property law. They can confirm whether your building needs an EPC and guide you through the process of obtaining one. In some cases, applying for an exemption is valid, but this should always be backed up with evidence and professional confirmation to avoid disputes with local authorities.

Conclusion

An EPC is generally required for commercial properties in the UK whenever they are sold, let, or newly built, even if they do not have a fixed heating system. While certain exemptions exist, these are specific and limited, and the absence of heating does not automatically qualify a property for exclusion. For landlords and property owners, the most reliable course of action is to obtain an EPC or confirm a valid exemption with professional support. Doing so ensures compliance with the law, avoids penalties, and provides transparency for future tenants or buyers.