epc-and-mees

---
name: epc-and-mees
description: Turns the Energy Performance Certificate on your leased premises into a lawful-to-let check, the minimum band E standard applied against its two real prohibition dates, each exemption matched to what is actually registered, the PRS Exemptions Register position, who pays for the improvement under your own lease, and the confirmed direction of travel for larger buildings. Use before you sign, renew or extend a lease on a cafe, restaurant, bar or small hotel in England or Wales, or the day you learn your landlord's EPC is below band E.
---

# A sub-standard EPC caught before it becomes your closed door

You give this the EPC with its band and dates, the lease's repair, alterations and service charge clauses, any claimed exemption and its evidence, and the tenancy dates in question. You get back the standard applied against the real prohibition date, each exemption matched to what is registered, and who pays under your own lease. It will not rate the building or decide an exemption's validity. That is an energy assessor's and the landlord's job.

## What it does

1. **Confirm a valid EPC exists before reading its band.** An EPC lasts 10 years from issue. Record the band, issue date and expiry. No valid EPC is its own failure, fined £500 to £5,000 by rateable value.
2. **State the standard, the date it bites, and the penalty for breach.** The 2015 Regulations set the minimum at band E. A sub-standard non-domestic letting on a new, extended or renewed tenancy has been barred since 1 April 2018, and any such letting at all since 1 April 2023, unless exempt. A breach under three months risks the greater of £5,000 or 10% of rateable value, capped £50,000; three months or more, the greater of £10,000 or 20%, capped £150,000.
3. **Match the claimed exemption to its real name and check the register.** 7 year payback, all improvements made, consent, devaluation and the six-month new-landlord exemption are the only ones, each running 5 years bar the last. Consent, devaluation and temporary exemptions must also be registered on the PRS Exemptions Register before being relied on. Record what is claimed, what is registered, and the expiry of each.
4. **Find who pays, from the lease, not the Regulations.** The duty sits on the landlord; funding depends on the lease. The pack's service-charge-check skill records the RICS standard excluding improvement costs above repair from a service charge, so MEES works billed that way break it. Record what the lease says.
5. **Note the direction of travel as a proposal, not law.** Band B by 2031 is proposed for buildings over 1,000 square metres, pending secondary legislation. Smaller units, almost every independent hospitality premises, stay at band E with no new deadline.
6. **Hand the mechanical work to Codex.** Run:

   ```
   codex exec --sandbox danger-full-access --skip-git-repo-check -C "<working folder>" - < CODEX.md
   ```

   Claude hands over the EPC facts, the exemption claimed and its evidence, the register position, the lease liability clauses and any rateable value supplied. Codex returns the status, exemptions, liability and penalty files, deciding and estimating nothing.

## Then it checks

1. EPC band, issue and expiry dates are recorded, with a plain statement on validity.
2. The prohibition date applied is the one that actually governs this letting.
3. Any exemption matches a real name and duration; the register position reads registered, not registered or not stated, never assumed.
4. Liability is quoted from the lease itself, the cross-reference used only where supplied.
5. No file states the 2031 proposal, or an unsupplied rateable value, as settled.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only. Never invent a fact, a number or a quote. Anything sent in someone's name says whose name it is.
- England and Wales only.
- Never rate a building, recommend an improvement or decide an exemption's validity. Never state the 2031 band B proposal as current law.
- Never assume a service charge can recover MEES works without checking the lease and service-charge-check's exclusions.
- A working document for the owner's own solicitor and the landlord's managing agent to check. Not legal advice, not an energy assessment, not a finding that any exemption is valid.

## Built from
- The Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015, SI 2015/962, regulations 22 and 27, https://www.legislation.gov.uk/uksi/2015/962/regulation/27/made, read 14 October 2026: band E and the two prohibition dates, step 2.
- The same Regulations, regulations 31 to 33 and 36, https://www.legislation.gov.uk/uksi/2015/962/regulation/36/made, read 14 October 2026: exemptions and the PRS Exemptions Register duty, step 3.
- The same Regulations, regulation 41, https://www.legislation.gov.uk/uksi/2015/962/regulation/41/made, read 14 October 2026: financial penalties, step 2.
- GOV.UK, "Non-domestic private rented property: minimum energy efficiency standard - landlord guidance", https://www.gov.uk/guidance/non-domestic-private-rented-property-minimum-energy-efficiency-standard-landlord-guidance, updated 5 May 2026, read 14 October 2026: exemption types, the 7 year payback test and durations, step 3.
- GOV.UK, "Private Rented Sector minimum energy efficiency standard exemptions", https://www.gov.uk/government/publications/private-rented-sector-minimum-energy-efficiency-standard-exemptions, updated 5 May 2026, read 14 October 2026: the PRS Exemptions Register, step 3.
- GOV.UK, "Energy Performance Certificates for your business premises", https://www.gov.uk/energy-performance-certificate-commercial-property, read 14 October 2026: the 10 year EPC validity and the £500 to £5,000 penalty, step 1.
- GOV.UK, consultation outcome, "Minimum Energy efficiency standards (MEES) in the non-domestic private rented sector: interim response", updated 18 June 2026, read 14 October 2026: proposed band B by 2031 for buildings over 1,000 square metres, step 5.
- This pack's own service-charge-check skill, built from RICS, "Service charges in commercial property", 2nd edition, June 2025, core principle 3.8, cross-referenced rather than repeated, step 4.

# epc-and-mees

## You are given
The EPC band, issue date and expiry for one leased UK hospitality premises in England or Wales, or a statement that none was supplied. The tenancy type (new, extended, renewed, continuing) and effective date. Any exemption claimed, with its evidence document, or none claimed. The PRS Exemptions Register position as checked by the owner. The lease's repair, alterations and service charge clauses verbatim, and any service-charge-check exclusions finding already produced. Any rateable value held, with its date and source. All judgement on validity and next steps belongs to the owner and their solicitor.

## Produce
Write into `./epc-and-mees-output/`:

1. `epc-status.csv`: `property_address`, `epc_band`, `epc_issue_date`, `epc_expiry_date`, `valid_today`, `source_document`. `valid_today` is calculated only from the supplied issue date against the 10 year term, left empty if the date is missing.
2. `mees-compliance.md`, separate lines only: the band E standard; sub-standard as `yes`, `no` or `cannot be determined`; the applicable date as `1 April 2018 (new, extended or renewed tenancy)`, `1 April 2023 (any letting)` or `not yet applicable`; current lawfulness.
3. `exemptions-register.csv`: `exemption_claimed`, `exemption_recognised`, `evidence_supplied`, `registered_on_prs_register`, `date_registered`, `expiry_date`. `exemption_recognised` is `yes` only for an exact match to 7 year payback, all improvements made, consent, devaluation or temporary (new landlord); else `no`, flagged in `gaps.md`. `registered_on_prs_register` is `yes`, `no` or `not stated`.
4. `liability-position.md`: the lease's repair, alterations and service charge clauses verbatim, then one line on whether a service-charge-check exclusions finding was supplied and its conclusion.
5. `penalty-exposure.md`, only where sub-standard is `yes`: breach duration category, rateable value if supplied, and the penalty from the greater-of formula and cap for that category. No rateable value: the line reads `cannot be calculated without rateable value`.
6. `gaps.md`: no EPC; no issue date; unrecognised exemption name; no register position where claimed; no liability clause; no rateable value where a breach is recorded.

## Rules
- Transcribe, match names and calculate only from supplied facts. Never decide sub-standard without a supplied band, never decide an exemption valid, never estimate a rateable value or a benchmark figure.
- Never calculate a penalty without a supplied rateable value, and never mark an exemption registered because it was merely claimed.
- British English, GBP as `GBP` or £, DD Month YYYY dates, no em dashes; supplied text with one is recorded verbatim and flagged in `gaps.md`.
- Every file ends with: a working document for the owner's own solicitor and the landlord's managing agent to check. Not legal advice, not an energy assessment, not a finding that any exemption is valid.

## Return
Every file's path, the EPC band and validity, the sub-standard conclusion and applicable date, the exemption claimed and whether recognised, the register position, the penalty range or the cannot-be-calculated line, the liability conclusion in one line, and the `gaps.md` count.