# Commercial EPC at lease renewal and re-letting

> Why granting a new lease is both the moment the obligation attaches and the cheapest opportunity to fix it, and how to use the negotiation.

Source: https://commercialepcupgrades.co.uk/epc-at-lease-renewal

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# Commercial EPC at lease renewal and re-letting

The minimum standard attaches to letting rather than to owning, which makes a renewal the moment it bites. It is also, inconveniently and usefully, the moment when the unit may be empty, when both parties are already negotiating, and when the work is cheapest to do. The trigger and the opportunity arrive together, and most landlords only use one of them.

General guidance, not legal advice

Energy performance rules for commercial property in England and Wales have changed repeatedly, and proposals have moved during consultation. This page describes the position as we understand it and is written to be useful rather than definitive. Check the current position and your own obligations with a solicitor or a qualified assessor before committing to capital spend.

## Why the renewal is the moment

Under the minimum standards regime the restriction applies to granting a new letting, so the obligation surfaces when you are doing exactly that. The current minimum is EPC band E.

What makes this more opportunity than problem is that everything which makes the work expensive at other times is absent. There may be a void. The tenant is already at the table. Dilapidations, rent, term and incentives are all in play, and the work can form part of that package rather than being a separate cost with no counterparty.

## Using the negotiation

- Do the work during the void between leases, where there is one. Cheapest version of the same job, and the unit lets better.
- Fold it into the incentive package: a contribution to fit-out that happens to include the lighting is a different conversation from a landlord cost with no return.
- Agree the tenant specification up front, so a new fit-out does not undo a rating you have just paid to achieve.
- Deal with dilapidations and improvement works together rather than sequentially, since the same trades are on site.
- Set the lease terms so the next renewal is easier: access rights, consent to alterations, and who is responsible for what.

## The tenant has an interest too

A tenant pays the energy bill, so the measures that improve the rating also reduce their outgoings. That is a genuine shared interest and it is frequently unexploited, because the conversation is framed as a landlord compliance cost rather than as a reduction in the tenant’s running costs.

Framed properly, a landlord-funded lighting upgrade against a modest rent adjustment can leave both parties better off. Framed as compliance, it is a cost one party resents.

## What to write into the new lease

This is a solicitor’s territory, but the shape of it is worth knowing: rights of access to carry out energy works, control over alterations that could worsen the rating, obligations around reinstatement at expiry, and clarity about who holds and renews the certificate.

A lease drafted without any of that leaves the landlord carrying an obligation they have no practical means of discharging for the length of the term, which is the position a great many landlords are currently in.

## Questions we get asked

### Does the minimum standard apply at lease renewal?

### Why is renewal the cheapest time to do the work?

### Can the tenant be asked to contribute?

### What should go into the new lease?

Sources

- Under the MEES Regulations the minimum for non-domestic private rented property in England and Wales is EPC band E. [The Non-Domestic Private Rented Property Minimum Standard: guidance for landlords and enforcement authorities, under the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, 2017](https://www.gov.uk/government/publications/the-non-domestic-private-rented-property-minimum-standard-landlord-guidance)

Last updated 8 October 2026 .

- [MEES and the minimum The obligation itself](https://commercialepcupgrades.co.uk/mees)
- [Multi-let estates Where renewals are the whole programme](https://commercialepcupgrades.co.uk/buildings/multi-let-industrial)
- [Selling The other transaction trigger](https://commercialepcupgrades.co.uk/commercial-epc-when-selling)

Next step

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