When businesses think about energy and sustainability compliance, they often jump straight to carbon reporting or net zero targets. But there is a quieter, older piece of legislation that still catches many organisations out and it can carry real financial and reputational risk if ignored.
Energy Performance Certificates (EPCs) and mandatory air conditioning inspections are legal requirements for many UK businesses, yet they are frequently overlooked until a lease renewal, sale, audit, or enforcement notice brings them sharply into focus.
This is one of those areas where compliance, cost control and ESG genuinely overlap.
EPCs: more than a landlord issue
An EPC rates the energy efficiency of a commercial building from A to G and is legally required when a property is built, sold or let. Certificates last for ten years, but the rating itself has become far more important in recent years.
Under Minimum Energy Efficiency Standards (MEES), most commercial buildings must now achieve at least an E rating to be lawfully let. Since April 2023, it has been illegal to continue letting sub-standard properties unless a valid exemption is registered.
While landlords hold the primary responsibility, tenants are often affected in practice. Lease clauses, dilapidations, service charges and improvement works can all land with occupiers, particularly where energy performance is poor.
Penalties for non-compliance can be significant, running into tens of thousands of pounds, alongside the reputational risk of public enforcement registers.
The rule many businesses miss: air conditioning inspections
Separate from EPCs is a lesser-known but equally mandatory requirement.
Any business operating air conditioning systems with a combined cooling capacity above 12kW must hold a valid energy inspection report, commonly known as a TM44 inspection.
This threshold is reached more quickly than many expect. Multiple split units are counted together, even if they serve different spaces or were installed at different times.
Key points businesses often overlook:
- Inspections are required every five years
- They must be carried out by an accredited assessor
- A written TM44 report must be held and made available on request
- It applies regardless of how energy-efficient the building is overall
Local authorities can issue fixed penalties for non-compliance and require follow-up inspections. Not knowing the rule is not a defence.
Why this matters beyond “box-ticking”
From a Green Circle Solutions perspective, this is not just about avoiding fines.
EPCs and air conditioning inspections provide:
- Hard data on how energy is actually being used
- Clear, prioritised recommendations to reduce energy waste
- Evidence to support ESG reporting, landlord discussions and investment decisions
- A practical starting point for decarbonisation planning
Poor energy performance directly affects running costs, asset value, resilience and future compliance. With regulation only moving in one direction, businesses that ignore this now often end up paying more later.
A smarter approach
The organisations we see making the most progress treat these requirements as baseline diagnostics, not admin exercises.
They use the findings to:
- Identify quick wins with short payback
- Plan capital investment more confidently
- Reduce energy costs and emissions together
- Future-proof buildings ahead of tighter standards
Done well, this is low-regret action that supports both commercial performance and sustainability goals.
How Green Circle Solutions can help
At Green Circle Solutions, we help businesses:
- Understand whether EPC and air conditioning requirements apply
- Find accredited firms to conduct the inspections
- Interpret reports in plain English
- Prioritise actions that deliver real operational and ESG value
- Integrate energy compliance into wider sustainability and net zero strategies
If you are unsure whether your building or systems are compliant, now is the right time to check, before it becomes urgent.