Is an EPC Required for Commercial Property with No Heating

Energy Performance Certificates, commonly referred to as EPCs, are a key requirement in UK property law. They provide a rating of how energy efficient a building is, ranging from A for the most efficient to G for the least. For anyone selling, letting, or constructing a commercial property, an EPC is usually mandatory. However, one area that often raises questions is whether an EPC is required for a commercial property with no fixed heating system. To answer this, it is important to understand how the law defines buildings, what is meant by energy performance, and the exemptions that apply.

When an EPC is Required for Commercial Property

The general rule is that any commercial property which is built, sold, or rented must have a valid EPC. This applies to a wide range of properties including offices, shops, warehouses, and industrial units. The EPC must be commissioned before the property is marketed and made available to potential buyers or tenants at the earliest opportunity. Only an accredited non-domestic energy assessor can produce the certificate following an inspection, and the EPC remains valid for ten years unless major works alter the building’s performance.

The Role of Heating in EPC Requirements

The requirement for an EPC is linked to whether the building uses energy to condition the indoor climate. This includes heating, ventilation, and air conditioning systems. A property that has no fixed heating system at all may be treated differently because the methodology used to assess EPC ratings is based on the performance of both the building fabric and its fixed services. Where no fixed services exist, the property may fall within the category of buildings that are exempt from EPC requirements. This is sometimes the case with basic warehouses, storage facilities, or certain industrial buildings.

Exemptions for Certain Types of Buildings

Not all commercial buildings require an EPC. UK law recognises exemptions in defined circumstances. Examples include places of worship, temporary buildings, and properties due for demolition. Importantly, a building that does not use energy to condition the indoor climate is also exempt. This means that if a property has no fixed heating, no mechanical ventilation, and no air conditioning, then no EPC is legally required. However, if even a basic fixed heating system is present, whether electric or gas, this would usually trigger the requirement. Portable heaters are not considered fixed and therefore do not affect exemption status, but any permanent system would.

Why the Distinction Matters

The purpose of an EPC is to provide a measure of energy efficiency. If a building does not use energy for climate control, then such a rating becomes irrelevant. A storage-only warehouse with no heating system may therefore be exempt, while a small retail space with one fixed heater would require certification. For landlords and property owners, understanding this distinction is vital as failure to provide an EPC when legally required can result in financial penalties enforced by local authorities.

Responsibilities of Property Owners and Landlords

If a commercial property is exempt due to the absence of heating or fixed services, the landlord or owner does not need to supply an EPC when selling or renting the property. However, if heating, cooling, or ventilation systems are installed later, the exemption is lost and an EPC must be obtained. It is wise for owners to keep clear records showing the property’s condition and services at the time of sale or rental in case of enforcement checks. Councils may request evidence and can issue fines if they believe an EPC was required but not provided.

EPCs and the Drive Towards Energy Efficiency

Although some properties qualify for exemptions, the wider context is worth considering. EPCs are part of the UK’s strategy to improve energy efficiency and reduce carbon emissions. Even where an EPC is not legally required, commissioning one voluntarily can be useful. It provides a benchmark for future improvements and gives prospective tenants or buyers confidence in the property. If heating or air conditioning systems are later installed, the EPC will already provide a baseline for comparison.

Conclusion

An EPC is generally required for commercial properties that are sold, rented, or built. However, if a building has no fixed heating, ventilation, or air conditioning, it may fall into the exempt category under UK law. The crucial factor is whether the property uses energy to condition its indoor climate. Storage units, warehouses, and similar unheated premises are the most common examples where EPCs are not required. Owners and landlords should seek professional advice if they are unsure, as non-compliance can lead to enforcement action.