The UK government’s is reforming Energy Performance Certificates (EPCs), with significant implications for the film and television production sector. The consultation on these changes closed in February 2025 and clarity on approach is expected this year. Studios, production companies and location managers must prepare for a new era of green compliance.

EPCs rate buildings on energy efficiency from A (most efficient) to G (least efficient). The proposed reforms will likely introduce new performance metrics over the next 2-3 years, expand the scope of EPC requirements, and shorten how long certificates remain valid.

Concerns suggest up to 80% of commercial properties in the UK may become impossible to lease commercially by 2030 without major upgrading works. This affects not only permanent studio spaces but also temporary and pop-up locations frequently used in the industry.

Production companies often lease or license a wide range of commercial premises – from purpose-built sound stages to converted warehouses and historic buildings. The new EPC requirements could introduce several challenges such as:

• Due diligence enhancements: Before signing location agreements or leases, production companies will need to conduct due diligence to ensure compliance with the latest EPC standards and confirm properties can be used for commercial purposes without breaking laws. This is crucial for short-term or pop-up spaces, where compliance may not have been a priority in the past.
• Fit-out hurdles: Meeting higher energy performance standards may require additional investment in fit-outs or temporary modifications, particularly in older or heritage buildings. This could affect both budgets and timelines.
• Contractual considerations: Location agreements and leases may need to be updated to reflect new compliance obligations, including:
  • Clear warranties about EPC status.
  • Clarity on who is responsible for obtaining and maintaining valid certificates.
  • Agreement on what happens if a property fails to meet future commercial hire standards.
  • Cost allocation for upgrade works (landlords often seek to pass the costs of upgrade works on to their tenants, but this remains contentious for short-term occupiers).

A key point of focus here is that many productions are drawn to the unique character of heritage or converted buildings. Country homes are hugely popular for filming, and many have their own filming templates and established procedures for private hire.

However, these properties are likely to face the greatest challenges under the new EPC regime. Exemptions that previously applied are unlikely to be available, and the cost of bringing such buildings up to commercial standards could be significant. Production companies should work closely with landlords and legal advisors to understand the risks and responsibilities involved.

• Review existing agreements: Check current template contracts for EPC-related clauses and update them as needed.
• Engage early with landlords: When considering leases, raise EPC compliance concerns at the outset of negotiations to clarify responsibilities and avoid last-minute surprises.
• Budget for compliance: Factor potential fit-out costs and compliance checks into production budgets and schedules.
• Monitor regulatory developments: Keep up-to-date with the final form of the EPC reforms and any sector-specific guidance that may be issued.

The government’s anticipated EPC reforms represent a significant shift in the regulatory environment for film and TV production spaces. By taking a proactive approach to due diligence and compliance, production companies can minimise disruption and ensure that their sets remain both creative and compliant.

For legal advice on navigating EPC compliance in your location agreements and commercial property leases, contact our property team. As specialists in the media and entertainment industry, we’re monitoring these regulatory developments closely and can help you navigate them.