Self Storage EPC, MEES and Solar Rules UK (2026)

As at 17 October 2026, the minimum energy efficiency standard (MEES) for letting a non-domestic building in England and Wales is band E on an energy performance certificate (EPC). The government’s interim response of 18 June 2026 dropped the proposed 2027 step to EPC C. It says EPC B from 2031, for buildings over 1,000 square metres, is only proposed and needs secondary legislation; on 17 October 2026 we found no change to regulation 22, which sets band E.

In England and Wales, the 2015 energy efficiency regulations set two scope tests: a legally required certificate and a fixed term of 6 months to 99 years. The government’s detailed guidance reads properties let on licence as “unlikely to be required to meet the minimum standard”, a reading and not law. This guide cannot say whether a particular building or arrangement is caught. It is general information, not legal advice, and not technical advice.

What is the minimum energy efficiency rule for a business building, and what changed in June 2026?

The minimum is band E. Regulation 22 of the 2015 energy efficiency regulations sets “band E” as the minimum level, and a property is sub-standard where its valid certificate shows a level below it. On 17 October 2026 we found no change to regulations 20, 21, 22 or 27 (searched: both pages of the legislation.gov.uk list of changes to the regulations, 73 effects, by our count 25 amendments from 6 instruments and 48 commencement entries).

Regulation 27 bars the letting of a sub-standard property unless an exemption applies. From 1 April 2018 that means a new letting, an extension or a renewal, and from 1 April 2023 it also means continuing to let. A certificate is valid if it was entered on the register no more than 10 years before it is relied on and no later certificate has been entered.

Local weights and measures authorities enforce the standard. For a breach of regulation 27 lasting under three months, the financial penalty may not exceed the greater of £5,000 and 10% of the rateable value, and may not exceed £50,000. From three months, the limits are the greater of £10,000 and 20%, and £150,000. A publication penalty is added to either: the authority decides which details of the notice, such as the breach, go on the exemptions register.

The guidance lists six exemptions, which this guide does not develop. It says an exemption must be registered before it can be relied on, and applies from the point of registration. The interim response says the 7 year payback test and exemptions “will remain in place”, so that only practical, affordable and cost-effective improvements are required.

What the interim response of 18 June 2026 changes, in its own words:

• The 2027 step. The response says “the previously proposed interim EPC C milestone for 2027 will not be taken forward”, so the 2027 step to EPC C was dropped on 18 June 2026.
• The EPC B proposal. The response says it is proposed that let buildings over 1,000 square metres in England and Wales reach EPC B from 2031 “where cost effective”, and that the change “will only take effect following the successful passage of secondary legislation through Parliament”. So EPC B from 2031 is proposed, not law. Secondary legislation means regulations made under an Act of Parliament.
• Smaller buildings. The response says “the intention is for buildings below 1,000 square metres to continue to be subject to the current minimum standard of EPC E”.
• What is not stated. On 17 October 2026 we found no statement of how the 1,000 square metres is measured, in the response or on the parent consultation page (searched: the visible text of both). The response says further detail will follow, and that the government aims to introduce legislation and updated guidance “at the earliest opportunity”.
• The older target. On 17 October 2026 we found no mention of 2030 in the response, although the consultation page, last updated on 18 June 2026, still quotes “the EPC B target by 2030” in its description of the 2021 consultation.

For scale, the Ministry of Housing, Communities and Local Government’s Table A, published on 30 July 2026, counts 93,343 non-domestic certificates lodged in England and Wales in calendar 2025. Of them, 1,256, or 1.3%, were rated F or G (our calculation: 578 plus 678, as a share of 93,343). Table A counts certificates lodged for any non-domestic use, not the stock of buildings and not self storage, and the next release is expected on 29 October 2026.

Does the standard reach a self storage operator, or its customers?

No source we read on 17 October 2026 states as law whether the minimum standard reaches a storage operator or its customers. The government’s detailed guidance reasons that the regulations apply only to properties let in the way the Act describes, so properties “occupied under other arrangements”, for example let on licence, are “unlikely to be required to meet the minimum standard”, in a document that is “not legally binding”. That is the government’s reading, not a court’s.

The same guidance adds that the government cannot give a definitive interpretation of the law, “as this is a matter for the courts”. We did not search case law, and none of the sources we read on 17 October 2026 gives a court decision on how the regulations treat a licence.

The guidance sets out three questions. Is the property not a domestic dwelling? Is an energy certificate legally required for it? Is it let for a fixed term, a “term certain”, of 6 months to 99 years? The guidance says a No to any of them means the property “is not covered by the Regulations”. It tells a person letting a property who answers Yes to all three, with an F or G certificate, to “take appropriate steps to comply”.

Regulation 20 of the 2015 energy efficiency regulations puts the last two questions in law. A property is not covered if no energy certificate was or is required for it, or for the building it is part of, under the 2007 certificate regulations, the Building Regulations 2010 or the 2012 energy performance regulations.

It is also not covered if it is let for a term certain of 99 years or more, or of 6 months or less. The 6 month exclusion does not apply if the agreement allows the term to be renewed or extended beyond 6 months from its beginning, or if the occupier has been in continuous occupation for more than 12 months when the term is granted.

Section 49 of the Energy Act 2011 is the duty to make the non-domestic regulations, and section 43 is its domestic parallel. Section 42(1)(b) sets the starting point: a property is within the scheme if it is in England and Wales, “let under a tenancy” and not a dwelling.

On 17 October 2026 we found no definition of the noun in that phrase in regulation 2 of the 2015 regulations or in sections 42, 43, 49, 50, 51, 54 and 61 of the Act (searched: the full text of those eight legislation.gov.uk pages).

The detailed guidance carries “February 2017” on its cover, and its file was last modified on 4 April 2023. On 17 October 2026 we found no sentence about a licence, licensee or licensing on the shorter gov.uk guidance page that links to it (searched: the page’s visible text).

Two arrangements can raise the question: the one between an operator and its customers, and the one between the operator and the building’s owner. The scope questions apply to each arrangement on its own facts, and a later section returns to the second. Our glossary entry on the storage licence agreement explains why a storage agreement is drafted as a licence and why courts look at substance rather than the label.

Does a storage building need an EPC at all?

That depends on the building, and the sources give tests, not a verdict on any type of building. The gov.uk page on energy performance certificates for business premises says one is needed if the premises are let or sold, among other cases. On 17 October 2026 we found no mention of “indoor climate” or of a space being “heated or cooled” on that page (searched: its visible text).

The 2012 regulations define a building as “a roofed construction having walls, for which energy is used to condition the indoor climate”.

The 2017 guide says a building within the certificate rules must have a roof and walls and use energy to condition the indoor climate, through fixed heating, mechanical ventilation or air-conditioning.

Regulation 5 lists buildings that the certificate rules do not apply to. They include “industrial sites, workshops and non-residential agricultural buildings with low energy demand” and stand-alone buildings with a total useful floor area of under 50 square metres.

The 2017 guide goes further. Its glossary lists, among the industrial activities under the low-energy-demand exclusion, “storage and warehouses where, in each case, the air in the space is not fully heated or cooled”. On 17 October 2026 we found no mention of self storage in that guide (searched: its full text, where “storage” appears four times and “warehouse” once). The guide is dated December 2017 on its cover, and its gov.uk page was last updated that month.

Whether a given building, or part of one, is fully heated or cooled is a fact about that building, and a question for an energy assessor.

The 2012 regulations treat a “building unit” as part of a building: a section, floor or apartment designed or altered to be used separately. The 2017 guide says separate use may be indicated by its own access, separate heating and ventilation, or shared heating that the occupier can control independently.

The 2012 regulations require a certificate in these situations. Regulations 6 and 7 cover a building that is to be sold or let. Regulation 7A covers a building that is erected. It also covers one modified so that it has more or fewer parts designed for separate use, where the modification provides or extends fixed heating, hot water, air conditioning or mechanical ventilation.

The guidance on the minimum standard says a property marketed for sale or let, or modified, in the past 10 years “will probably be legally required to have an EPC”. A certificate is valid for 10 years.

What if an operator takes a building from its owner?

Whether the arrangement between an owner and an operator is within the regulations turns on the scope tests above and on that arrangement’s own terms, and this guide does not decide it. Regulation 27 of the 2015 energy efficiency regulations bars the letting of a sub-standard property, and a property is sub-standard only where its valid certificate shows a level below band E. A solicitor can say how the tests apply to that arrangement.

In England, on a material change of use of the whole of a building, regulation 6 of the Building Regulations 2010 lists requirement L1 (conservation of fuel and power) and S2 (infrastructure for the charging of electric vehicles) among those to be met.

The guidance is Approved Document L, volume 2: gov.uk lists the 2021 edition incorporating 2023 amendments as current, and Circular 04/2026, published on 8 September 2026, says the revised edition takes effect on 24 March 2027, subject to transitional provisions.

Our guide to converting a building into self storage states the band E rule in one line, covers the fire requirements, and leaves open whether self storage counts as a “shop” under regulation 5(j). Our guide to licences and registrations covers the other permissions an operator may need.

What do the rules say in Wales, Scotland and Northern Ireland?

Wales shares the England and Wales rules, Scotland has its own certificate rules, and on 17 October 2026 we found no letting standard in Scotland or Northern Ireland.

• Wales. The 2015 and 2012 regulations are both titled for England and Wales, and the June 2026 response is for England and Wales too.
• Scotland, certificates. The Scottish Government’s guide says the Energy Performance of Buildings (Scotland) Regulations 2008 require a certificate when a new building is constructed, when a building is sold and when a building is let to someone new. A certificate is valid for 10 years. An owner who fails to provide one could receive a penalty charge notice, with a £1,000 minimum penalty for a non-domestic property.
• Scotland, a letting standard. On 17 October 2026 we found no Scottish Statutory Instrument with the opening title words of the England and Wales regulations (searched: the legislation.gov.uk title search, which returned no results, while the same tool returned 11 for the words energy performance of buildings).
• Scotland, new rules. Two Scottish Government sources give different dates for the new Scottish certificate rules, and on 17 October 2026 nothing we read says whether they describe one event or two, so this guide prints neither date.
• Northern Ireland. The Department of Finance says that since 30 December 2008 a property needs a certificate when it is constructed or marketed for sale or letting. On 17 October 2026 we found no minimum energy standard on its three undated pages on the energy performance of buildings (searched: the visible text for the words minimum, standard and lowest rating, and for any rating band).

For Scotland more widely, see our guide to self storage in Scotland. This guide says nothing about building standards in Wales or Northern Ireland, or about rates in Northern Ireland.

What do the planning rules allow on a non-domestic roof in England, Scotland and Wales?

Three separate rules cover solar equipment on a non-domestic building: Class J in England, Class 6J in Scotland and Class A of Part 43 in Wales. They sit in different Orders, and this guide never blends them.

On 17 October 2026 we found no solar class for a non-domestic building in the two Parts of the Northern Ireland 2015 Order that we read (searched: Part 9 on industrial and warehouse development and Part 2 on domestic microgeneration; the other Parts were not read).

• England, Class J. Class J of Part 14 of Schedule 2 to the General Permitted Development Order 2015 covers microgeneration solar thermal and solar PV equipment on a building, and “other solar PV equipment on the roof of a building”, other than on a dwellinghouse or a block of flats.
• England, prior approval. Class J(c) makes the developer apply to the council first for a determination on whether its prior approval is needed for the design or external appearance, in particular the impact of glare on occupiers of neighbouring land. The development must not begin before the council says approval is not required, gives it, or 56 days pass without an answer.
• England, other classes. Class K covers stand-alone solar in the curtilage, and Class OA solar canopies over parking; Class OA, and some Class K cases, need prior approval. The 1 MW cap and the bar on a roof slope fronting a highway were removed on 21 December 2023, so a source that still gives either as current does not match the legislation text we read on 17 October 2026.
• Scotland. Class 6J of Part 1B of Schedule 1 to the 1992 Order covers solar PV or solar thermal equipment on a non-domestic building, and Class 6N covers free standing solar in the curtilage. Class 6J was substituted and Class 6N inserted on 24 May 2024.
• Scotland, caps and approval. On 17 October 2026 we found no kilowatt cap, capacity limit or prior approval in either class (searched: the legislation.gov.uk text of each class; Class 6K, read the same way, carries both).
• Wales. Class A of Part 43 of Schedule 2 to the 1995 Order covers solar PV or solar thermal equipment on a building other than a dwellinghouse or a block of flats, and Class B covers stand alone solar in the curtilage. A limit on equipment within three kilometres of the perimeter of an airport or aerodrome was inserted on 1 April 2019.
• Wales, caps and approval. On 17 October 2026 we found no kilowatt cap, capacity limit or prior approval step in either class (searched: the text from the Part 43 heading to Class C).

Class J takes its meaning of microgeneration from the Energy Act 2004, which for electricity counts plant whose capacity does not exceed 50 kilowatts. This guide draws no line between Class J(b), for microgeneration, and Class J(c), for other roof solar: which one an array falls under is a fact about that installation.

Whether a given roof or array is permitted is a question for the council. For a yard with no building, our guide to starting a container storage business covers power; the stand-alone classes above are written for the curtilage of a building, so ask the council whether a bare yard is covered. The table below sets the three rules side by side.

What do business rates and export payments mean for rooftop solar?

The rating regulations in England, Wales and Scotland each carve renewable generating plant out of the plant that counts as part of a property for rating, for days before 1 April 2035, and the Smart Export Guarantee leaves the price of an export to each supplier. Whether an array on a given store changes its rateable value turns on that installation and on where its power goes, and this guide tests none.

• England. S.I. 2022/405, in force from 1 April 2022, amends Class 1 of the plant and machinery schedule so that, for any day before 1 April 2035, “excepted renewables plant and machinery” is left out. The definition covers plant for generating, storing, transforming or transmitting power where the sources relied on are mainly or exclusively one of ten listed, including photovoltaics and solar power.
• Wales. S.I. 2023/1229, in force from 1 April 2024, does the same for any day on or after 1 April 2024 and before 1 April 2035.
• Scotland. S.S.I. 2023/32, in force from 1 April 2023, amends the same class to leave out plant with microgeneration capacity and, for days before 1 April 2035, excepted renewables plant.
• Scotland, a separate relief. The Renewable Energy Generation Relief is for schemes set up to entitle community organisations to a share of profit, and the generation must be “the main use of the property such as a wind farm, but not a wind turbine above a shop”.

The Rating Manual for valuation officers, updated on 21 September 2026, says the plant affected in England and Wales is mostly solar PV and wind turbines assessed with a host property, for example “a solar array on the rooftop of an industrial unit supplying electricity mainly for consumption by the occupier of that industrial unit”.

It says that where power “is wholly or mainly for export and greater than 10kW, it will normally constitute a separate hereditament which will require assessment”. A hereditament is the unit that is rated. The manual adds that the land and settings accommodating excepted plant “remain rateable”. We did not check Northern Ireland rates. Whether an array on a given store is excepted is a question for the valuation officer or the Scottish assessor.

Our guide to self storage on the business rates list reads the official rating list data, and our guide to self storage business rates sets out how the bill is worked out in England.

The Smart Export Guarantee covers generators in Great Britain: Ofgem’s generators page says installations must have a total installed capacity of no more than 5 MW, or 50 kW for micro combined heat and power.

It says each licensee must offer a tariff to all eligible generators, that a tariff “must always remain above zero”, and that the licensee determines the payment details, including the amount and the contract length. On 17 October 2026 we found no pence-per-kWh export rate and no mention of Northern Ireland on that page (searched: its visible text). On 17 October 2026 the page printed no date.

What do official data say about energy use in warehouse buildings, and what does one listed operator disclose?

The official data cover a Warehouses group of buildings, not a self storage category. The Department for Energy Security and Net Zero’s non-domestic energy data framework, published on 30 September 2026, puts the median electricity use of its Warehouses group at 25.26 kilowatt hours per square metre in 2024, down from 36.47 in 2012, and median gas use at 52.81, down from 75.86.

The Warehouses group is the set of buildings with Valuation Office description codes beginning CW, in England and Wales. On 17 October 2026 we found no mention of self storage in the report, the methodology note or the 26 sheets of the workbook (searched: the full text of all three). Our calculation from the published medians: median electricity use per square metre fell 30.7% between 2012 and 2024, and median gas use fell 30.4%.

Each figure is a weighted median per building use, in kilowatt hours per square metre of floor area, so it describes a group and not a site. Buildings with no floor area information are left out: 6% of Warehouses buildings, against 18% of all non-domestic buildings. The 2024 medians rest on 78,000 buildings for electricity and 14,000 for gas.

The year 2024 covers January 2024 to January 2025 for electricity and May 2024 to May 2025 for gas, and the gas data are weather-corrected. The electricity figures count supply through the public distribution system, so on-site generation is not included.

For prices, the Department for Energy Security and Net Zero’s Quarterly Energy Prices of 29 September 2026 gives non-domestic averages for April to June 2026 of 24.5 pence per kWh for electricity and 5.3 for gas. The averages include the Climate Change Levy, cover all non-domestic consumers and vary by size band. This guide does not combine the two sets of numbers: one is a median for a building-use group and the other an average across all non-domestic consumers.

One listed operator publishes its own figures. In its results announcement of 18 May 2026, for the year to 31 March 2026, Big Yellow says 85 stores now have solar arrays and its total solar capacity is 9.6 megawatts, against 8.5 megawatts a year earlier. It puts its energy costs at 1.2% of revenue. These are one company’s figures for its own estate, and this guide draws no comparison with any other operator and makes no claim about its performance.

What does this guide not cover?

• The registers. The register of individual certificates needs a government sign-in account, and we created none. We read only Table A, the open count of certificates lodged. We did not read the exemptions register.
• Any particular building. This guide does not say whether any building needs a certificate, falls within the minimum standard or may carry panels. Each is a fact about that building and its arrangement.
• Court decisions. We did not search case law on how the regulations treat a licence.
• Other nations. We did not read Northern Ireland building regulations or rates, Welsh building standards on energy, or the energy section of Scotland’s building standards handbook.
• Costs. This guide makes no claim about the cost of energy improvements or solar equipment. Our guide to the cost to build self storage covers the build-cost side.
• Rules named, not developed. Regulation 14 of the 2012 regulations requires a display energy certificate in some buildings occupied by public authorities and frequently visited by the public. Part 4 covers inspections of air-conditioning systems with an effective rated output of more than 12 kW.
• More rules named, not developed. The gov.uk heat networks guidance says Ofgem is the regulator for heat networks under the Heat Networks (Market Framework) (Great Britain) Regulations 2026. The Quarterly Energy Prices release calls the Climate Change Levy an energy tax. The Streamlined Energy and Carbon Reporting guidance, last updated on 29 March 2019, says it affects listed companies, unquoted large companies and large limited liability partnerships.
• Not researched. Capital allowances for energy-saving plant, fire safety of battery storage, grid connection approval for rooftop solar, roof structure and warranties, and the Energy Savings Opportunity Scheme.

Questions to put to your adviser

These are questions the sources leave open, for the people who can answer them for a particular building.

• An energy assessor. Does the building use energy to condition the indoor climate, and is its air fully heated or cooled? Which band does its certificate show, and when was that certificate entered on the register?
• A solicitor. On the terms of this arrangement, is the letting within the 2015 regulations, given the 6 month and 99 year provisions and any renewal wording? Does the answer differ between the owner and the operator, and between the operator and its customers?
• The council. Which class applies to the proposed array, and is a prior-approval determination needed first? Do the limits on projection, listed buildings or airports bite on this roof?
• The Valuation Office, or the Scottish assessor. Is the plant on this building excepted from rating, and would power wholly or mainly for export above 10kW make a separate hereditament?
• The electricity supplier. Which export tariff does the licensee offer for an installation of this size, and for what contract length?

Sources

All read on 17 October 2026. Contains public sector information licensed under the Open Government Licence v3.0.

• The minimum standard. The “Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015” (legislation.gov.uk, regulations 2, 20 to 22, 27, 34, 39 and 41) and its list of changes (legislation.gov.uk, both result pages); Energy Act 2011, section 42 and section 49 (legislation.gov.uk).
• The government’s guidance. The guidance on the non-domestic minimum energy efficiency standard (gov.uk, last updated 5 May 2026) and its detailed version (PDF, cover dated February 2017).
• June 2026. The interim response (gov.uk, updated 18 June 2026) and the consultation page for the non-domestic “private rented sector” standards (gov.uk, last updated 18 June 2026).
• Certificates. The Energy Performance of Buildings (England and Wales) Regulations 2012 (legislation.gov.uk); the guide to energy performance certificates for non-dwellings (Department for Communities and Local Government, December 2017); the gov.uk page on energy performance certificates for your business premises (undated).
• Certificate statistics. The Ministry of Housing, Communities and Local Government’s Energy Performance of Building Certificates in England and Wales: April to June 2026 (published 30 July 2026) and its live tables, Table A.
• Building regulations. Building Regulations 2010, regulation 5 and regulation 6 (legislation.gov.uk); Approved Document L and Circular 04/2026 (gov.uk, published 8 September 2026).
• Scotland and Northern Ireland. The Scottish Government’s energy performance certificates guide (last updated 24 August 2026); the Department of Finance’s energy performance of buildings in Northern Ireland (undated).
• Solar planning, England. General Permitted Development Order 2015, Schedule 2, Part 14 and the explanatory note to S.I. 2023/1279; Energy Act 2004, section 82 (all legislation.gov.uk).
• Solar planning, Scotland, Wales and Northern Ireland. The 1992 Order, Schedule 1, Part 1B (Scotland); the 1995 Order, Schedule 2 (Wales); the Northern Ireland 2015 Order, Part 2 (all legislation.gov.uk).
• Rates and exports. S.I. 2022/405 (England), S.I. 2023/1229 (Wales) and S.S.I. 2023/32 (Scotland) (legislation.gov.uk); the Rating Manual page on power generators (gov.uk, updated 21 September 2026).
• Relief and export payments. The Scottish Government’s Renewable Energy Generation Relief (mygov.scot, last updated 30 March 2026); Ofgem’s Smart Export Guarantee generators page (undated).
• Energy data. The Department for Energy Security and Net Zero’s Quarterly Energy Prices: September 2026 (29 September 2026) and Non-domestic National Energy Efficiency Data Framework, 2026 (30 September 2026).
• Heat networks and reporting. The gov.uk heat networks guidance (last updated 11 February 2026) and the Streamlined Energy and Carbon Reporting guidance (last updated 29 March 2019).
• One listed operator. Big Yellow Group PLC’s results for the year ended 31 March 2026 (announcement of 18 May 2026, Investegate copy).