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Non-Domestic EPC Changes 2025: What UK Businesses Must Know

Key Non-Domestic EPC Changes at a Glance

Validity period reduced: From 10 years to 5 years for non-domestic EPCs
Higher penalties: Fines increasing from £500-£5,000 to £815-£8,150
Continued carbon focus: Existing carbon metrics maintained, aligned with net-zero goals
New trigger points: EPCs required when certificates expire, not just at point of sale or letting
ACIR improvements: Air Conditioning Inspection Reports redesigned for better usability
Enhanced enforcement: Stricter compliance measures to prevent tick-box approach

The UK Government has recently published a consultation outlining significant proposed reforms to the Energy Performance Certificate (EPC) regime, focusing particularly on non-domestic EPCs. For clarity, Civil Servants use the phrase “non-domestic” in regards to commercial buildings, meaning non-domestic equals commercial. These non-domestic EPC changes, while still in the consultation phase, aim to update and improve the EPC framework, bringing it into alignment with the UK’s carbon reduction objectives and ensuring that businesses have current and relevant energy performance data. This article explores the key proposed changes to non-domestic EPCs and what these could mean for business owners, building managers, and energy assessors in the coming years. EPCs have been phenomenally successful over the past 16 years and represent the United Kingdom’s national measurement system for energy efficiency in buildings. The EPC measurement system has been refined continually over those years and is extremely accurate.

What Are Non-Domestic EPCs?

A non-domestic EPC is an essential tool for measuring and reporting the energy performance of commercial and industrial buildings. The certificate provides a rating from A to G, where ‘A’ represents the highest level of energy efficiency and ‘G’ represents the lowest. EPCs are a mandatory requirement for businesses when selling or letting a property and are valid for up to 10 years. However, with the recent proposals for reform, the landscape for non-domestic EPCs is about to change significantly.

How Will Non-Domestic EPC Metrics Change?

One of the most significant non-domestic EPC changes is the continued emphasis on carbon-focused metrics. The government intends to maintain the existing carbon metric, as non-domestic EPCs are already aligned with the UK’s net-zero goals. This focus on carbon emissions is in line with the government’s broader policy to reduce carbon output across all sectors, especially the commercial and industrial sectors, which are significant contributors to national carbon emissions.

However, the government has also indicated that in the future, there may be consideration of introducing additional metrics, potentially similar to those proposed for domestic EPCs. These could include metrics related to energy efficiency improvements, primary energy use, and other performance-related indicators that would provide a fuller picture of a building’s energy usage and carbon footprint.

How Will EPC Validity Periods Change?

Another key component of the non-domestic EPC changes is the reduction in the validity period for certificates. Under the current regime, these certificates are valid for 10 years, but the government is proposing to reduce this to a much shorter period to ensure that businesses have access to current information.

For non-domestic EPCs, the government is considering reducing the validity period to 5 years. This shorter validity period will ensure that businesses are regularly updating their energy performance data, which in turn will encourage ongoing improvements in energy efficiency. The aim is to keep energy performance data fresh and relevant, especially in a rapidly changing energy landscape. Businesses will need to be proactive in scheduling reassessments to maintain current EPCs, ensuring compliance with the law.

What Are the New Compliance Penalties?

The consultation also highlights concerns about compliance with EPC requirements. It is noted that EPCs, in some cases, are viewed as a mere “tick-box” exercise rather than a tool to help businesses understand and improve their energy performance. This has led to low compliance rates in some sectors, particularly among owners of non-domestic properties.

To address this, the consultation proposes several improvements to enforcement measures. One key suggestion is an increase in penalties for non-compliance. For instance, fines for failure to comply with non-domestic EPC regulations could rise from £500 (the minimum) to £815, with the maximum penalty increasing from £5,000 to £8,150. Similarly, the penalty for failing to comply with Air Conditioning Inspection Reports (ACIRs) would rise from £300 to £800. These increases aim to create a stronger deterrent against non-compliance, ensuring that businesses take their energy efficiency obligations seriously.

Enhanced Enforcement Framework

Beyond financial penalties, the consultation proposes enhanced monitoring and enforcement mechanisms. Local authorities will receive additional guidance and resources to conduct compliance checks, with particular focus on high-risk sectors and repeat offenders. This enforcement framework is designed to complement the non-domestic EPC changes and ensure widespread adoption across the commercial property sector.

How Will Air Conditioning Inspection Reports Improve?

Alongside the non-domestic EPC changes, the consultation also seeks to improve the format and content of Air Conditioning Inspection Reports (ACIRs). Currently, these reports are often lengthy and complex, with an average read time of 40 minutes, which may discourage system operators from engaging with them.

The government is proposing a redesign of the ACIR to make it more user-friendly and to encourage system operators to take action based on the findings. The proposed new format would highlight key information such as the system’s efficiency, maintenance needs, the suitability of controls, and the system’s capabilities under normal operating conditions. Additionally, the redesigned report would include a summary of findings and key recommendations, making it easier for businesses to implement improvements.

Expanding the Scope of EPC Requirements

The government also proposes expanding the scope of EPC requirements, especially regarding trigger points for when an EPC is needed. Currently, an EPC is required when a property is marketed for sale or rent, and the certificate is valid for up to 10 years. However, these non-domestic EPC changes suggest that businesses will need to renew their EPCs more frequently, particularly when an existing EPC expires.

Additionally, a new trigger point may be introduced for the private rented sector. This would require an EPC to be obtained whenever the current certificate expires, ensuring that rented properties are always compliant with energy efficiency standards. The consultation also suggests that properties should not be marketed for sale or let without a valid EPC. This is a move towards greater transparency and accountability, ensuring that all properties are clearly rated in terms of energy efficiency.

What Will Be the Impact on Businesses and Building Owners?

These proposed non-domestic EPC changes will have a significant impact on businesses, particularly those that own or operate large commercial properties. The reduced validity periods and expanded scope of EPC requirements will require business owners and property managers to stay vigilant about energy performance and ensure they are regularly reassessed to meet the updated regulations.

The increased penalties for non-compliance, coupled with the push for more frequent updates, will likely encourage businesses to take energy efficiency more seriously. There may be an increased demand for qualified energy assessors and compliance professionals to help businesses navigate the changes and ensure their buildings meet the required standards.

The potential introduction of new metrics, as well as the proposed changes to the ACIR, will also create new opportunities for businesses to improve their energy efficiency. With more detailed and user-friendly reports, businesses will be better equipped to identify areas for improvement and implement energy-saving measures.

Preparing for EPC Reform: Next Steps

As these proposed non-domestic EPC changes move through the consultation phase, businesses need to be aware of the potential implications. The shift towards shorter EPC validity periods, increased penalties for non-compliance, and the expansion of EPC requirements are all designed to create a more dynamic and effective energy performance regime.

By staying informed and engaging with the consultation process through the Department for Energy Security and Net Zero, businesses can better prepare for the upcoming changes and ensure that they meet the new energy performance requirements. The continued focus on carbon emissions and energy efficiency aligns with the UK’s broader sustainability goals, and businesses that act now to improve their energy performance will not only ensure compliance but may also benefit from cost savings and a competitive advantage in the marketplace.

Frequently Asked Questions About Non-Domestic EPC Changes

When will the non-domestic EPC changes come into effect?

The proposals are currently in the consultation phase. Once the consultation closes and government reviews responses, the changes are expected to be implemented progressively from 2025 onwards. Businesses should monitor government announcements for confirmed implementation dates.

Will existing 10-year EPCs remain valid until expiry?

This will be clarified in the final regulations. However, property owners should prepare for the possibility that existing certificates may need to be updated sooner than their current expiry date, particularly if new trigger points are introduced.

How much will the increased frequency of assessments cost businesses?

Costs will vary depending on property size and complexity. However, the shorter 5-year validity period means businesses should budget for assessments twice as frequently as under the current regime. This may be offset by improvements in energy efficiency and reduced operational costs.

What happens if my property is already rated A or B?

Even high-performing properties will need to renew their non-domestic EPCs when the 5-year validity period expires under the proposed non-domestic EPC changes. The assessment ensures data remains current and reflects any building modifications or changes in occupancy patterns.

Do the non-domestic EPC changes affect Display Energy Certificates (DECs)?

The consultation addresses both EPCs and DECs. Public buildings subject to DEC requirements should review the consultation documents for specific proposals affecting their compliance obligations, as similar reforms may be introduced for Display Energy Certificates.