Whole life carbon (WLC) reporting is moving from voluntary best practice to regulatory requirement across Europe, driven by new EU rules on building performance.
Early action is essential to future-proof assets and mitigate risk. As these rules take hold across Europe, project teams will face stronger expectations for clearer data and more consistent reporting. This article sets out the key EPBD timeline, how different European markets are responding, and what project developers should do now to prepare.
The growing regulatory importance of whole life carbon
The built environment accounts for nearly 40% of global energy use and 36% of CO₂ emissions. Historically, regulations focused on operational energy. The new EPBD recast, adopted in April 2024, places whole life carbon at the centre of compliance. From 1 January 2028, new buildings over 1,000 m² must disclose their life-cycle global warming potential (GWP). By 2030, this expands to all new buildings, including major renovations.
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Ahead of the curve
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On track
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Falling behind
Ahead of the curve
On track
Falling behind
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Ahead of the curve
France, Denmark and the Netherlands have whole life carbon rules in place, giving them a clearer basis for compliance and planning.
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On track
Germany, Ireland, Italy and Spain are developing their approaches, with guidance and pilot activity emerging as they move toward future EPBD requirements.
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Falling behind
The UK, Finland, Portugal and Greece have fewer defined measures at this stage, which creates more uncertainty for long term planning.
The following examples highlight how various European countries are implementing (WLC) regulations and setting benchmarks for the built environment.
Mandatory dynamic life cycle assessment (LCA) and embodied carbon thresholds for building permits has been in place since 2022. Thresholds will tighten through to 2031.
Embodied carbon limits for new buildings >1,000 m² have been in place since January 2023. Limits will tighten further from July 2025, with an average cap of 7.1 kg CO₂e/m²/year.
Compulsory embodied carbon LCA for new non-residential buildings >100 m² has been a requirement since July 2021. Limit values will progressively tighten.
WLC reporting is mandatory for new buildings >1,000 m² from 2028, and all new buildings from 2030. National methodology aligns with EPBD.
What this means for project developers
As expectations shift, project developers need to address several immediate priorities. Whole life carbon must be embedded early in planning and procurement. Project developers should avoid attempting to retrofit post design, as late-stage calculations are costly and limit flexibility. Preparing for disclosure is critical, even in regions without mandates. Carbon should also be treated as a strategic risk, not just a compliance issue. Regulatory frameworks are evolving quickly, and early-stage optioneering allows clients to compare carbon impacts before locking in design and procurement decisions. This proactive approach reduces risk and strengthens project resilience.
Competitive advantage: Beyond compliance
Whole life carbon reporting goes beyond regulatory compliance. For organisations that take a proactive stance, it offers a strategic advantage. By embedding WLC requirements early, businesses can future-proof assets, strengthen ESG performance, and unlock new sources of value. Transparent reporting builds stakeholder trust and reinforces reputation as a leader in climate action. Access to green finance is another benefit, as investors and lenders increasingly link funding to carbon disclosure and reduction targets. Early adopters can shape outcomes, reduce risk, and demonstrate leadership in a competitive market. Integrating carbon and cost data also drives operational efficiency, enabling smarter decisions that balance sustainability with financial performance.
What project developers should do now
To stay ahead, project developers should act now. Begin by embedding carbon optioneering during estimating and feasibility stages, so decisions balance cost and impact from the outset. Align internal teams on clear carbon goals and assign responsibilities to ensure accountability. Use cost data as a lever for carbon insights, integrating financial and sustainability metrics for smarter choices. Prepare for disclosure even in regions without mandates, as
transparency is becoming a global expectation. Finally, monitor regulatory developments closely, particularly in markets where frameworks are still evolving, to avoid surprises and maintain compliance readiness.
What’s next
Whole life carbon requirements are reshaping projects across Europe. Linesight partners with project developers to quantify compliance costs and incorporate them into the project. We use our extensive experience to provide cost-effective solutions for our clients. Get in touch to see how we can help you prepare for disclosure and manage regulatory change.
The deadline for Member States to transpose EPBD WLC requirements is 29 May 2026. Engaging with pilot programmes and voluntary guidance now will help organisations anticipate requirements and build confidence ahead of the deadline.
