When is an EPC Not Required for Commercial Property

Energy Performance Certificates, widely known as EPCs, are a familiar requirement for property transactions in the UK. For commercial property, they provide a standardised measure of energy efficiency and are legally required in most cases when a building is sold, let, or constructed. However, there are circumstances where an EPC is not required for commercial property. Understanding these exceptions is important for landlords, business owners, and developers, as it prevents unnecessary costs while also ensuring compliance with the law.

The General Rule for Commercial EPCs

Under current regulations, a commercial EPC is needed whenever a commercial property is built, sold, or rented. It must be provided to potential buyers or tenants at the earliest opportunity, and the certificate remains valid for ten years unless significant changes are made to the building that affect its performance. The purpose of this system is to give transparency on energy efficiency, support informed decisions, and encourage investment in energy saving improvements. While this is the standard rule, there are clear exemptions set out in law.

Buildings That Do Not Require an EPC

Some types of commercial buildings are exempt from requiring an EPC. Properties that are scheduled for demolition and have the necessary consents in place do not need one, since the building will not continue in use. Temporary buildings with a planned time of use under two years are also exempt. Industrial sites, workshops, and agricultural buildings with a low energy demand are another category that does not normally need an EPC. These buildings are often unheated or used for purposes where energy efficiency assessments provide little practical benefit.

Places of worship are also excluded from the requirement. Historic buildings that would have their character unacceptably altered by energy efficiency improvements can sometimes be exempt too, though this is assessed on a case by case basis. Standalone buildings with a total useful floor area of less than 50 square metres, such as small kiosks or site huts, do not require an EPC either. Each of these exemptions recognises that in certain cases, the assessment would be unnecessary, impractical, or out of line with the building’s intended use.

Changes of Use and Lease Renewals

A common area of confusion arises around lease renewals. An EPC is not required when a lease is being renewed or extended between the same landlord and tenant. The requirement applies primarily to new lettings and sales. Similarly, a change of use that does not involve the sale or rental of the property does not automatically trigger the need for a new EPC. However, if the building is sold or let after the change of use, a valid EPC will be required at that stage.

Refurbishment and Construction Scenarios

Another exemption occurs when buildings are undergoing major refurbishment or redevelopment. If the property is not yet complete, or is being stripped back for significant works, an EPC is not needed until it is being marketed for sale or rent as a finished building. Once the refurbishment is complete, a new EPC may be required to reflect the updated condition and performance of the property. This ensures that buyers and tenants have accurate information based on the final, usable state of the building rather than its interim form.

Why Exemptions Matter for Owners and Landlords

Knowing when an EPC is not required saves time and money, but it also ensures that property owners remain compliant with the law. Attempting to market or let a property without an EPC when one is required can result in fines, usually ranging from £500 to £5,000 depending on the property size and rateable value. Equally, commissioning an unnecessary EPC wastes resources. By being clear about the exemptions, owners can focus on compliance where it matters most and avoid unnecessary paperwork.

Practical Examples of Exemptions

Imagine a farmer with a large unheated barn used only for storage. Because the building has a low energy demand, it would not need an EPC if sold. Similarly, a small standalone site office of 40 square metres on a construction site would be exempt. A developer who has obtained consent to demolish a disused warehouse would not require an EPC before sale, as the buyer intends to clear the site. A church being transferred between congregations is another case where no EPC is needed. These examples show how the rules are designed to be practical and proportionate.

Conclusion

EPCs remain an essential part of the UK’s energy efficiency strategy, but there are clear cases where they are not required for commercial property. Buildings scheduled for demolition, temporary structures, places of worship, small standalone units, and low energy demand agricultural or industrial properties are all exempt. Lease renewals and certain refurbishment scenarios also fall outside the rules. For landlords, developers, and business owners, understanding these exceptions provides clarity, avoids wasted costs, and ensures compliance with regulations. When in doubt, it is always sensible to check with a qualified assessor or legal adviser to confirm whether an EPC is necessary in your situation.