Retrofit feasibility study · London
Small non-domestic premises in London and MEES
The questionWhich small London shops, offices and cafes are exposed to the minimum energy efficiency standard, and what do their certificates tell the landlord to do?
Of London's certified premises of 1,000 m² or less, 3.3% are rated F or G, below the E floor in law, and 40.4% are below C. Small offices and workshops are the weakest use group.
- Certified premises
- 105,655
- 1,000 m² or less
- Below the E floor
- 3.3%
- rated F or G
- Below band C
- 40.4%
- rated D to G
- Conservation area or listed
- 38.5%
- consent for external work
How the archetype was selected
London units with a lodged non-domestic certificate (CEPC). Take the most recently lodged CEPC per address and keep it where the certificate's total floor area is greater than 0 and at most 1,000 m². The cut matches the size threshold in the government's revised non-domestic proposal, though certificate floor area is only a proxy because the proposal's measurement basis is not yet set. Use groups come from the certificate's property type: A1/A2 or Retail/Financial (retail and financial), B1 or Offices and Workshop (offices and workshops), A3/A4/A5 or Restaurants and Cafes (food and drink), and other.
Key figures
Data month: 2026-09 (CEPC lodgements to 2026-09-02). Shares are of the certified addresses in this archetype unless the row says otherwise.
| Band | Certificates | Share |
|---|---|---|
| A+ to B | 24,894 | 23.6% |
| C | 38,115 | 36.1% |
| D | 27,048 | 25.6% |
| E | 12,131 | 11.5% |
| F | 1,494 | 1.4% |
| G | 1,973 | 1.9% |
| Measure | Value |
|---|---|
| Unit coverage | 77,812 of 179,723 London non-domestic units (43.3%) hold a lodged CEPC; 44,226 (24.6%) rely on a 2017 modelled rating only, not used here |
| Certified premises | 105,655 latest certificates in 81,527 units = 90.9% of London's 116,189 certified non-domestic premises; median certificate floor area 116 m² |
| F or G: below the E floor in law | 3,467 (3.3%); 1,010 (1.0%) on certificates still within 10-year validity |
| Below C (the 2027 milestone, not being taken forward) | 42,646 (40.4%) |
| Below B (proposal revised to over 1,000 m² from 2031, not yet law) | 80,761 (76.4%) |
| Certificate within 10-year validity at 22 October 2026 | 83.8% |
| Comparison: premises over 1,000 m² | 10,533 premises (9.1% of certified), below B 56.9%, below C 26.8%, F or G 1.6% |
| Measure | Value |
|---|---|
| In a conservation area | 39,710 (37.6%) |
| Listed | 6,277 (5.9%) |
| In a conservation area or listed | 40,712 (38.5%) |
| Measure | Value |
|---|---|
| Retail and financial | 47,537 (45.0%) |
| Offices and workshops | 24,611 (23.3%) |
| Food and drink | 17,905 (16.9%) |
| Other | 15,602 (14.8%) |
| Measure | Value |
|---|---|
| Retail and financial | below C 35.5%, F or G 2.7% (0.6% within validity), median 87 m² |
| Offices and workshops | below C 51.9%, F or G 5.8% (1.8% within validity), median 149 m², 45.8% in a conservation area or listed |
| Food and drink | below C 34.2%, F or G 1.4% (0.2% within validity), median 116 m² |
| Measure | Value |
|---|---|
| Under 250 m² | 80,808 premises, below C 41.3%, F or G 3.5% |
| 250 to 1,000 m² | 24,847 premises, below C 37.3%, F or G 2.5% |
| Recommendation | Code | Certificates | Share | Payback category, as lodged |
|---|---|---|---|---|
| Some windows have high U-values - consider installing secondary glazing. | EPC-E5 | 56,966 | 53.9% | LONG on 63.2% of rows |
| Add optimum start/stop to the heating system. | EPC-H7 | 45,071 | 42.7% | LONG 42.0%, MEDIUM 36.3% of rows |
| Consider replacing T8 lamps with retrofit T5 conversion kit. | EPC-L5 | 44,913 | 42.5% | SHORT on 92.0% of rows |
| Solar gain limit exceeded; consider solar control (reflective coating or shading) | EPC-V1 | 44,086 | 41.7% | SHORT on 97.8% of rows |
| Carry out a pressure test, identify and treat identified air leakage. | EPC-E7 | 43,663 | 41.3% | LONG on 70.9% of rows |
| Consider installing solar water heating. | EPC-R3 | 41,653 | 39.4% | LONG on 94.5% of rows |
| Consider installing building mounted wind turbine(s). | EPC-R2 | 38,346 | 36.3% | LONG on 97.5% of rows |
| Add weather compensation controls to heating system. | EPC-H8 | 37,087 | 35.1% | LONG on 61.9% of rows |
Shares count certificates carrying the recommendation; across London, rows are loaded for 97-99% of the latest non-domestic certificates, depending on lodgement year, so these shares are lower bounds. Non-domestic certificates carry a payback category, not a cost.
Findings
- Premises of 1,000 m² or less make up 90.9% of London's certified non-domestic premises (105,655 of 116,189), with a median floor area of 116 m². Certificate coverage of non-domestic units is only 43.3%.
- 3.3% of small premises are rated F or G, below the E floor that has applied to continuing non-domestic lets since April 2023. Only 1.0% are F or G on a certificate still within its 10-year validity.
- 76.4% are below B and 40.4% below C. BuildGrade's recorded policy position (18 June 2026) is that the 2027 C milestone will not be taken forward and that the revised B proposal applies from 2031 to buildings over 1,000 m², so for these premises E is the only standard in law.
- Small offices and workshops are the weakest use group, with 51.9% below C and 5.8% F or G (1.8% within validity), against 35.5% and 2.7% for small retail.
- The most frequent recommendation is secondary glazing (53.9%, mostly long payback). Lamp conversion to T5 (42.5%) is lodged as short payback on 92.0% of rows, and 38.5% of these premises are in a conservation area or listed.
What it means for feasibility
Consents
MEES status: the E floor is law (Energy Efficiency (Private Rented Property) Regulations 2015, all continuing non-domestic lets from 1 April 2023), and exemptions are not modelled. Band C by 2027 and band B by 2030 are proposals only: BuildGrade's glossary records that the 2027 C milestone will not be taken forward and that the 2030 B milestone was revised on 18 June 2026 to band B from 2031 for buildings over 1,000 m², where cost-effective, which is not yet law. Check the current government position before relying on it. Heritage: in the 38.5% inside a conservation area or listed, shopfront and window replacement, external plant (for example heat pump condensers) and roof-mounted PV commonly need planning permission, and listed premises need listed building consent. Internal measures such as secondary glazing, lighting and controls usually need no planning permission but may need listed building consent.
Sequencing
- Check the certificate before the rating: only 1.0% of small premises are F or G on a certificate still within its 10-year validity, and an older certificate may predate works since done.
- Start with internal measures that usually need no planning permission, such as lamp conversion (lodged as short payback on 92.0% of rows), heating controls and secondary glazing, checking listed building consent where the premises are listed.
- In the 38.5% in a conservation area or listed, programme planning permission or listed building consent for shopfronts, windows, external plant and roof-mounted PV.
- Plan to the standard in law, the E floor, and treat band C and band B milestones as proposals until legislation says otherwise.
Planning statements are general context for England, not legal advice. Article 4 directions vary by borough and were not checked for these figures.
Sources
- MHCLG Energy Performance of Buildings register, non-domestic certificates (CEPC) and recommendations, lodgements to 2026-09-02 (non-address fields OGL v3; 'Energy Performance of Buildings Data England and Wales (c) Crown copyright.')
- GLA London Building Stock Model (non-domestic units), OGL v3, 2026-09-12
- GLA London Datastore Conservation Areas, OGL v3, 2026-09-12
- Historic England NHLE listed-building polygons, OGL v3, 2026-09-12
- BuildGrade policy glossary and product specification (MEES policy status as at 18 June 2026)
Data month September 2026.
Building units (GLA London Building Stock Model): Contains public sector information licensed under the Open Government Licence v3.0 (Greater London Authority / UCL Bartlett Energy Institute and CASA). Contains OS data (c) Crown copyright and database right, published under the Ordnance Survey presumption to publish.
Energy performance certificates (MHCLG register): Energy Performance of Buildings Data England and Wales (c) Crown copyright.
Listed buildings (Historic England): © Historic England 2026. Contains Ordnance Survey data © Crown copyright and database right 2026. The Historic England GIS Data contained in this material was obtained on 12 September 2026. The most publicly available up to date Historic England GIS Data can be obtained from HistoricEngland.org.uk. Licensed under the Open Government Licence v.3.0.
Conservation areas (GLA London Datastore): Contains public sector information licensed under the Open Government Licence v3.0.
Method note
Every rating here is certified: the most recently lodged energy performance certificate for each address. Modelled ratings, the GLA’s 2017 estimates for buildings without a certificate, are never averaged in; where a population relies on them they are counted separately. Figures come from read-only queries run on 22 and 23 October 2026. Counts that could identify a building are merged or left out, and no addresses or owner names are published.
- Certified means a lodged register certificate (RdSAP/SAP or CEPC). GLA 2017 aggregate rows and modelled (rvEPC) ratings are excluded from every distribution. Modelled ratings appear only as separate counts of units that rely on them.
- The unit of analysis for ratings is the address (UPRN): its most recently lodged certificate, with ties broken as the product does (lodged date, then record order). A stock-model 'unit' can be a whole block, so unit counts and address counts differ. 29.5% of London's latest domestic certificates are past 10 years from lodgement and may predate works since done.
- Recommendation rows are loaded for 79-97% of the latest domestic certificates and 97-99% of the latest non-domestic certificates, depending on lodgement year (some certificates carry no recommendations), so recommendation shares are lower bounds.
- Cost text is reported exactly as lodged and varies with register version (PV, for example, carries '£3,500 - £5,500', '£5,000 - £8,000' and '£9,000 - £14,000'), so the most common text and its share of rows is given. The texts are not current prices. Lighting cost text varies per certificate (most common share under 15%). Non-domestic recommendations carry a payback category (SHORT, MEDIUM, LONG, OTHER), not a £ cost.
- Heritage flags are spatial matches applied to the whole stock-model unit: listed means the centroid is within 5 m of an NHLE polygon or the footprint overlaps one by at least half; conservation area means the centroid is inside a GLA polygon. Every flat in a flagged block inherits the flag, so listed counts can be over or under. Listed matches: 10,294 domestic units by centroid and 5,551 by footprint.
- Tenure is as recorded at lodgement and may have changed since. Certificates with unknown or blank tenure are excluded from tenure shares (tenure-known share given per study). The MEES counts are screening counts, not compliance findings, and exemptions are not modelled.
- MEES status. Domestic: the E floor is law for private lets (since April 2020); band C by 2030 is confirmed policy, not yet law (government response 21 January 2026; needs legislation, and compliance is to be judged on reformed EPC metrics). Non-domestic: the E floor is law (since April 2023); the 2027 C milestone is not being taken forward, and B by 2030 was revised on 18 June 2026 to B from 2031 for buildings over 1,000 m², where cost-effective, which is not yet law. These are BuildGrade's recorded policy positions; check the current government position before relying on them.
- Consent statements (permitted development, conservation-area cladding, listed building consent, flats lacking householder rights) are general planning context for England, not legal advice, and are not computed from the database. Article 4 directions vary by borough and were not queried.
- London only: units outside the 33 London local authorities were not used. Other UK cities are in preparation; the Bristol and Cardiff pilots are not yet live.
- Non-domestic 'small' uses certificate total floor area as a proxy for the revised proposal's 1,000 m² threshold, whose measurement basis is not yet set. One CEPC with no floor area was excluded.