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Given the significance of carbon emissions from the existing building stock, this paper aims to provide an international comparative analysis of pioneering policies on minimum energy efficiency standards in the Scottish, English/Welsh, Dutch and French commercial real estate sectors. These are the four national policy regimes to employ these policy instruments to date with varied timelines spanning from 2009 to 2050. The methodological approach employs a document review of policy texts produced by policy makers and other stakeholders. The four policy regimes are evaluated in terms of their policy design focussing on minimum performance standards, forward guidance, scope and exemptions. A key finding is that, given the range of intervening factors, side-effects and uncertainties, there are difficult choices in striking a balance between phasing implementation, providing forward guidance and adjusting policy in response to evaluation. Whilst it was initially expected that most European Union jurisdictions would default to an Energy Performance Certificate related standard, our findings show that there has been a shift towards standards that are linked to actual rather than modelled energy consumption. However, for leased stock where the owner may have limited operational control, the separation of owners' responsibility for compliance and the users' responsibility for operations makes designing consumption-based instruments more challenging. It is concluded that a central issue in policy design has been the trade-off between minimising the financial costs to property owners and occupiers of complying with performance thresholds and maximising reductions in energy consumption. There is growing recognition that regulatory economies of scale may be achieved by targeting large properties which allows for a large proportion of the total area of the stock to be covered whilst exempting a large proportion of transactions or properties. • Policy makers use MEES to improve the energy efficiency of the worst building stock. • Significant policy divergence is observed across the four national policy regimes to date. • MEES should be based on actual energy consumption rather than design-based metrics. • The separation of ownership and use is a barrier to MEES linked to actual consumption. • Regulatory economies of scale may be achieved by targeting large properties. [ABSTRACT FROM AUTHOR]