EPCs for Commercial Buildings

1.2 Buildings Requiring an Energy Performance Certificate

An EPC is only required for a building when constructed, sold or let. For the purposes of the regulations, a building is defined as:

“a roofed construction having walls, for which energy is used to condition the indoor climate, and a reference to a building includes a reference to a part of a building which has been designed or altered to be used separately”.

For a building to fall within the requirement for an EPC it must:

• have a roof and walls; and
• use energy to condition the indoor climate. This is the case where the building has any of the following fixed services: heating, mechanical ventilation or air conditioning. Although the provision of hot water is a fixed building service, it does not “condition the indoor environment” and would not therefore be a trigger for an EPC. The same argument applies to electric lighting. Where a building is expected to have heating, mechanical ventilation or air conditioning installed, it will require an EPC based on the assumed fit out.

A building can either be:

• the whole of a building; or
• part of a building, where the part is designed or altered to be used separately.

A car park, for example, open at the sides with lighting, would not constitute a building for the purposes of requiring an EPC.

In terms of the requirement for an EPC, buildings can have multiple tenancies, differing lease agreements, various sub-letting arrangements and different uses (eg mixed retail, residential and office accommodation). In general terms an EPC should reflect the accommodation being sold or let. In practice this means any EPC provided should reflect the energy performance of the space being offered for sale or let.

To determine the requirement for an EPC in a building, the following should be considered:

• Selling or letting a building as a whole
• An EPC can be prepared for the whole building in these circumstances, even if that building is divided into parts designed or altered to be used separately with separate heating systems.

• Selling or letting part of a building


• Buildings with a common heating system. If a building has a common heating system, then the seller or prospective landlord has a choice¹,:
• to prepare (or make available) an EPC for the whole building; or
• to prepare (or make available) an EPC for a part designed or altered to be used separately being offered for sale or let. The assessment should be based on energy use per square metre for the whole building. Such an EPC may also be based on an assessment of a similar representative unit in the same building.


• Buildings with separate parts and separate heating systems. An EPC should be prepared (or made available) for each part of a building that is being offered separately for sale or let. The EPC should reflect the services in those part(s) being offered for sale or let. Again, the EPC may also be based on an assessment of a similar representative unit in the same building.

• Shared or communal areas in buildings with independent heating system
  • In buildings where there is an independently conditioned shared or communal area and where the purpose of the conditioned space is solely or mainly for access to a unit (or part of a building designed or altered to be used separately), the energy consumption of the shared space is allocated to each unit in accordance with the proportion of the floor area of each unit to the total useful floor area of all the units.

Some practical examples include:

• DIY store with warehouse, retail space and offices. If the whole accommodation is offered for sale or let for use together, then an EPC should reflect the whole building
• Industrial estate with units in blocks – if each unit has a separate heating system then each unit should have its own EPC for that unit. If the units share a heating system they could either have a single EPC for all the units or have an individual EPC for each unit. An EPC for an individual unit may also be based on an assessment of a similar representative unit in the same block
• Office block – If the block is served by a common heating system there is a choice to make available either an EPC for the whole building or an EPC for the part being offered for sale or let. If there are separate heating systems, an EPC must be prepared for the part of the block being offered for sale or let, based on the system that serves it. As before this may be based on an assessment of a similar representative unit in the same block.

Use the flowchart below to help determine whether your building requires an EPC:

Click on image to view full size

Section 4 provides guidance on a number of common situations and how the regulations may apply.

It is the action of selling, letting or construction that triggers the requirement for an EPC. Therefore existing occupiers and tenants will not require an EPC unless they sell, assign or sublet their interest.