Is an EPC Required for
Commercial Property With No Heating?

When commercial buildings without heating need EPCs

The 2012 Regulations exempt several categories of building from EPC requirements. The no-heating exemption is one of the most useful for commercial property owners because it covers a large slice of UK industrial plus storage stock.

The exemption rule. Regulation 5(2)(c) of the Energy Performance of Buildings (England plus Wales) Regulations 2012 exempts industrial sites, workshops plus non-residential agricultural buildings with low energy demand. The accompanying Department for Energy Security plus Net Zero (DESNZ) guidance clarifies that this includes any building with no installed heating, ventilation or air conditioning system. The presence of fixed mechanical services is the key test.

What counts as fixed mechanical services:

• Gas, oil or LPG boilers connected to fixed pipework.
• Electric storage heaters or panel heaters wired into the building.
• Air-conditioning units fitted to walls or ceilings.
• Mechanical ventilation systems with ductwork.
• Heat pumps with fixed installation.
• Underfloor heating systems.

What does NOT count as fixed mechanical services:

• Portable plug-in heaters that can be moved.
• Portable air conditioners on wheels.
• Standalone fans plus dehumidifiers.
• Welding heat or industrial process heat (not for occupant comfort).
• Solar gain through windows alone.

Building types typically covered by the exemption:

• Industrial warehouses with no heating.
• Storage units plus self-storage facilities.
• Cold stores plus chilled storage (cooling is not the same as heating but specific rules apply).
• Workshops with no installed heating.
• Garages plus motor vehicle storage.
• Agricultural buildings (barns, sheds, stables).
• Open-sided structures plus canopies.

Building types typically NOT covered:

• Offices, retail units plus restaurants. All need heating for occupant comfort.
• Showrooms with permanent staff. Need heating in winter.
• Light industrial units used for manufacturing or assembly with installed heating.
• Commercial kitchens plus food preparation areas.
• Healthcare plus educational buildings.

Mixed-use buildings. Many UK commercial buildings combine heated office space with unheated warehouse or storage areas. The 2012 Regulations treat each part separately:

• Office portion: needs an EPC. Calculated using SBEM (Simplified Building Energy Model) methodology.
• Unheated warehouse portion: exempt from EPC requirement.
• Boundary depends on physical separation between sections.
• If separately accessible plus measurable, the office EPC covers the heated area only.

Cold stores plus chilled storage. Buildings designed for refrigerated or frozen storage have specific rules. The cooling is for goods rather than occupants, which keeps them within the low-energy-demand exemption in many cases. Check with a commercial Energy Assessor for borderline cases.

Industrial process heating. Some industrial buildings have heat from processes (welding, ovens, furnaces) but no heating system designed for occupant comfort. This is treated as exempt from EPC requirement on the same logic as cold stores. The heat is incidental to the building use, not occupant comfort.

What to do if you are unsure:

• Commission a commercial Energy Assessor for a pre-assessment review. They can confirm whether the property qualifies for exemption.
• Document the no-heating status in writing. Photographs of the empty plant rooms plus floor plans showing no fixed heating help.
• Keep records of any fixed services that have been removed in the past.
• If selling or letting the property, explain the exemption to buyers, tenants plus their solicitors. They may ask for documented exemption case before proceeding.

Commercial EPC methodology. When a commercial EPC is required, it uses the Simplified Building Energy Model (SBEM) rather than SAP/RdSAP used for domestic. SBEM accounts for non-domestic factors like high lighting loads, IT equipment, mechanical ventilation plus cooling. Commercial EPCs cost £150 to £500+ depending on building size plus complexity.

Commercial EPC exemptions are one of the more nuanced areas of UK property regulation. Our full EPC Ratings hub covers Energy Performance Certificates plus MEES regulations across UK homes plus rental properties.