Care home MEES and EPC compliance: what applies, and what solar changes

Most care home operators first meet the Minimum Energy Efficiency Standard (MEES) through a lease renewal, a refinance, or a sale-and-leaseback — not through a regulator. That is because MEES is a rule about letting, not about running a care home. This page sets out who it catches, what the numbers are, what is proposed for 2031, and what a solar installation actually does to an EPC rating. Every figure is taken from the government's own consultation documents and dated; the 2031 proposal is not yet law.

Who MEES applies to — and who it does not

The non-domestic MEES regulations prohibit a landlord from letting, or continuing to let, a non-domestic building with an Energy Performance Certificate rating below E. The prohibition has applied to all existing leases, not just new ones, since 1 April 2023.

• Caught: a care home operated under a lease from a third-party landlord; a group company leasing from its own property-holding vehicle; a sale-and-leaseback arrangement; premises leased to an operator by a local authority or NHS body.
• Not caught: an owner-occupied home with no lease in place. It still needs a valid EPC when it is sold or let, but MEES imposes no minimum on it while owner-occupied.
• Exemptions exist — for example where all relevant improvements have been made and the building still falls below E, or where works would devalue the property — but they must be registered on the PRS Exemptions Register and last five years. They are not a way round the rule.

The practical consequence: if you are the tenant operator, the compliance obligation sits with your landlord, but your lease almost certainly passes the cost of statutory compliance to you. The right time to settle who pays for the works is at the lease negotiation, not after a sub-E rating surfaces at renewal.

The numbers: E now, B proposed for 2031

Two standards matter, and they are often conflated:

• EPC E — in force. The floor for any let non-domestic building since 1 April 2023.
• EPC B — proposed. In its June 2026 interim response to the non-domestic MEES consultation, the government proposed raising the minimum to EPC B by 2031 for buildings over 1,000 m², with buildings under 1,000 m² remaining at E. The previously floated interim step of EPC C by 2027 was dropped. The 2031 target is subject to secondary legislation and could change; treat it as the direction of travel, not a deadline you can rely on yet.

For care homes this split matters. A purpose-built 60-bed home is typically well over 1,000 m² and would be in the EPC B cohort; a converted 20-bed Victorian house may sit under the threshold and stay at E. Check the floor area on your existing EPC before you plan against 2031.

Source: gov.uk — Non-domestic PRS MEES: EPC B implementation (consultation and interim response). Figures verified June 2026; if you are reading this well after that date, check the consultation page for the current position before planning against it.

What a solar installation does to the rating

A non-domestic EPC rates the building's modelled carbon emissions per square metre against a notional benchmark building. It is not a measure of your bills. On-site renewable generation reduces the modelled emissions, so solar PV improves the rating — but by how much depends on the array relative to the floor area and on the rest of the building:

• On a modest, reasonably insulated building, a roof-filling array can move the rating a full band or more.
• On a large building with poor fabric, single glazing and an old gas boiler, a small array may not move the band at all — the fabric and heating dominate the model.
• Battery storage does not by itself change the EPC; it changes how much of the generation you use, which affects the bill, not the certificate.

The honest order of operations is fabric first where it is cheap, then heating, then generation — but solar is the one measure in that list that pays for itself while it improves the certificate, which is why it tends to be the first thing a landlord will fund.

Before relying on permitted development for the array itself, check the planning position — our guide to planning permission for care home solar covers Class J, listed buildings and prior approval.

Solar as a compliance spend that pays back

A care home's 24-hour load means it self-consumes far more of its generation than a typical business — 40–60% against 20–30% — so the same array pays back faster on a care home than on an office. That turns MEES from a pure cost into a project with a return: the cost and payback guide shows what an installation costs by home size, the funding routes page covers the zero-capex PPA and the tax-relief routes, and the capital allowances page explains why the full cost can be set against tax in year one. If the home is let, the lease may allow the landlord to fund the works and recover them through rent — which is where the PPA structure is often the easiest thing to agree.

A checklist for the lease renewal

1. Get the current EPC and its expiry date. Certificates last ten years; many care home EPCs date from the 2016–2018 wave and are due.
2. Read the floor area on it. Over 1,000 m² puts you in the proposed EPC B cohort.
3. Check the lease for who bears statutory-compliance costs. This is usually the tenant; negotiate it if you can.
4. Commission a desk assessment of what fabric, heating and solar measures move the band, in that order, with costs and paybacks side by side.
5. Register any exemption properly if one genuinely applies; an unregistered exemption is no defence.

We produce the desk assessment from your existing EPC, a year of half-hourly electricity data and a roof survey, and we are not an installer: the recommendation is the same whether the answer is fabric, heating, solar, or nothing yet. Where solar is part of the answer we introduce you to MCS-certified partner installers. See how the same numbers play out for solar panels for nursing homes and solar panels for residential care homes, or start from the full guide to solar panels for care homes.

Frequently asked questions

Do care homes have to comply with MEES?

Only if the premises are let. The non-domestic Minimum Energy Efficiency Standard applies to privately rented non-domestic property: a landlord cannot let or continue to let a building with an EPC rating below E. An owner-occupied care home is outside MEES, though it still needs a valid EPC on sale or letting. Sale-and-leaseback structures, group companies leasing from a property vehicle, and homes commissioned by a local authority in leased premises are all caught.

What EPC rating does a care home need in 2026?

E is the floor for any let non-domestic building, and has been since 1 April 2023 for existing leases as well as new ones. The government’s June 2026 interim response proposes raising that to EPC B by 2031 for buildings over 1,000 m², with smaller buildings staying at E; the earlier interim target of EPC C by 2027 was dropped. The 2031 proposal is subject to secondary legislation and is not yet law.

Does installing solar panels improve a care home’s EPC rating?

Usually, yes. A non-domestic EPC is calculated from the building’s modelled carbon emissions per square metre against a benchmark; on-site renewable generation reduces the modelled emissions and therefore improves the rating. The size of the move depends on the array relative to the floor area and on what else the building has — a large array on a modest building can move a full band; a small array on a large, poorly insulated one may not.

Who is responsible for the EPC — the operator or the landlord?

The landlord is the person who must comply with MEES, because it is a prohibition on letting sub-standard property. In practice the operator usually pays for the works under the lease’s repairing and statutory-compliance clauses, which is why the question belongs in the lease negotiation and not after it.

This page is independent guidance published by solarpanelsforcarehomes.co.uk (SEO Dons Ltd). It is not legal advice; the MEES regulations and the 2031 proposal should be checked against the current gov.uk text before any lease or capital decision.