In June 2026 the government published its interim response on minimum energy efficiency standards (MEES) for rented commercial property in England and Wales. The headline is clear. Privately rented non-domestic buildings over 1,000 m² will need to reach EPC B by 2031, where the improvements are cost-effective.
Some of the earlier proposals have gone. The interim EPC C target for 2027 has been dropped, and buildings under 1,000 m² stay at the current minimum of EPC E. The seven-year payback test and the existing exemptions remain.
For FM teams, that payback test is the important part. The measures a landlord will be expected to carry out are the ones that pay for themselves within seven years. In most buildings, controls work comes near the top of that list.
Why your landlord will be asking you first
When a landlord or asset manager starts planning for EPC B, the first question usually lands with the FM team: what is in the building, how well does it work, and what would it cost to improve? You know the plant, the schedules and the problem areas better than anyone.
The expensive measures are easy to list: new heat pumps, new glazing, a new chiller. The cheaper measures are often more valuable, because they pass the payback test easily and they make the expensive ones work better when they come.
How an EPC sees your controls
A non-domestic EPC is produced from a model of the building, usually built in SBEM (the Simplified Building Energy Model). As well as the fabric and the plant, the assessor records how the heating, cooling, ventilation and lighting are controlled. The features that count include:
- Central time control, so plant only runs to an occupancy schedule
- Optimum start and stop, so plant starts as late and stops as early as comfort allows
- Local time and temperature control, with sensible zoning rather than one setpoint for the whole floor
- Weather compensation on heating circuits
- Metering with monitoring and targeting, including alarms for out-of-range consumption
- Lighting controls, such as occupancy and daylight sensing
Many buildings already have most of these on the BMS. The problem is that the assessor has to be able to see evidence of them. If there is no current points list, control strategy or schematic, a feature that works perfectly well can be entered as if it is not there at all.
The paperwork gap
We see this regularly. A building has a capable BMS, but the O&M manual is from the original installation, the strategy has been changed several times since, and nobody has an up-to-date description of what the system actually does. The EPC ends up worse than the building deserves.
Closing that gap is one of the cheapest EPC improvements available. It usually means a BMS engineer surveying the system, fixing what has drifted, and producing a clear, current record of the controls.
Beyond the certificate
An EPC is a model. The energy bill is real. Controls improvements are one of the few measures that improve both. Plant that stops running out of hours, heating and cooling that stop fighting each other, and sensors that read correctly all show up in actual consumption within weeks.
That matters for ESOS too. Phase 4 has a compliance deadline of 5 December 2027, and participants are expected to report progress against the actions they committed to in Phase 3. Measured savings from controls work give you something concrete to report.
Your checklist for this quarter
- Find the most recent EPC for each building and check its expiry date and rating
- Check whether there is a current BMS points list, control strategy and schematic
- Walk the BMS front end: are time schedules, setpoints and optimiser settings still sensible?
- Check that sub-meters are logging and that someone is looking at the data
- Note any controls that are overridden in hand, disabled or showing faults
- Ask your BMS contractor for a controls review before the next EPC is commissioned
Where we come in
JKF Controls has worked on Trend, Tridium, Distech, Delta and Schneider systems since 2008. We review existing controls, put right what has drifted, and document the system properly, so your building gets the EPC it deserves and the energy savings to go with it.
Sources: UK government interim response on non-domestic MEES, June 2026 (Written Ministerial Statement HCWS126), as summarised by Jones Day and the Energy Managers Association; ESOS Phase 4 guidance via TÜV NORD. Correct as of 29 October 2026.